Overview: Paying Human Subjects

Monetary payments to human subjects (persons participating in a study sponsored by the University) can be made through iOU "other check" requests for direct payment to subjects or by requesting an iOU advance check to be used for cash disbursements to subjects. An iOU reimbursement request should be made to cover expenses for non-cash incentives.

Note:  Stanford or SLAC National Accelerator Laboratory employees who participate in a study conducted by their department or related to their regular employment must be paid through the Payroll system.

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Policy Considerations

When paying Human Subjects, study administrators have certain responsibilities:

  1. Fiduciary responsibility to ensure proper accounting for funds spent in the study. Adequate controls must be in place for the distribution of the funds and costs must be allocable to the PTA charged.
  2. Appropriate tax treatment for the compensation:
    • All Human Subject payments are considered income to the recipient. Stanford will issue a 1099 for every U.S. resident who is paid $600 or more in a calendar year by Stanford. However, if the Human Subject is a non-U.S. resident, a Stanford employee or SLAC National Accelerator Laboratory employee, the compensation will be reported to the IRS no matter what the payment amount.
    • If payments are made to a non-resident alien, tax withholding rules apply. This means that either the Human Subject or the department needs to pay the 30% Federal withholding tax at the time the money is disbursed. See examples.
    • If compensation is under $100, but it is anticipated that the individual will be receiving $600 or more during the calendar year (and they are not a Stanford or SLAC National Accelerator Laboratory employee), administrators must collect the subject's Social Security Number (SSN) and forward it to T&R with the backup documents. SSN is required for any payment of $100 or more.
    • If administrators elect to retain tax documentation for payments under $100, the administrator assumes responsibility for tax compliance. Tax ID information should be collected for these payments, if possible, to be made available if requested by the IRS or other tax authorities. Administrators should complete Human Subject Certification Form (for Incentives under $100).
  3. Human Subjects are protected under California State laws and HIPAA regulations. As a result of these privacy requirements, certain business processes must be followed.
    • Human Subject iOU transactions will not be viewable by anyone but the originator, approvers, individuals with authority over accounts charged, and authorized central office staff.
    • It should be noted that the first 30 characters of the business purpose of an iOU Other Checks transaction will appear in the expenditure reports of the designated project, task and award. It is extremely important that the subject's name NOT be included in the first 30 characters of the business purpose. It is recommended that the statement of business purpose be generic, i.e., "Human Subject Payment."
    • The University is aware that many studies are sensitive in nature and information concerning Human Subject participants is confidential. In those instances, the study should not be named in the requisition, but can be referred to by a protocol number or other study identifying number.
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Methodology

Payments to human subjects should be made through in iOU in one of the following ways:

Notes:

  • Study Administrators may choose to thank Human Subjects with non-cash items such as a gift certificate or a t-shirt.
  • For gifts valued under $100, administrators need only keep a record of the Human Subject's name and address, the value of the incentive given, and the Human Subject's signature evidencing their receipt of the item. This list plus a receipt for the purchase of the gift certificates or incentives should be sent to T&R. If you cannot get the recipients' signatures, you must complete an Attestation Form to attest to the fact that the money and/or gifts were distributed only to participants in the study and that their cost is allocable to the PTA charged.
  • Non-cash gifts are especially useful for those individuals that may not have SSN's, non-resident aliens or for studies where a small incentive is appropriate. Non-resident aliens and Stanford or SLAC National Accelerator Laboratory employees may receive non-cash incentives. Incentives valued under $100 (or less than $600 to one individual in a calendar year) will not be tax reported.
  • If the value of the incentive is $100 or more, it will be treated as income and is subject to the same tax reporting as cash.
  • Whenever possible, Stanford strongly urges use of non-cash thank you gifts for Human Subject study participants.
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Forms

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Human Subject Payment Matrix


Human Subject Payment Matrix
Incentive Payment method What information must you collect? Backup information required by central office (T & R or Payroll)
Payment or non-cash incentive under $100. (For non-resident aliens, also see section below.)
Non-cash incentives under $100 Request iOU reimbursement to cover expense of incentives List of participants to include:

Human Subject name, address, signature and date of interview or activity, $ value of incentive.

Or

Attestation
Fax the following iOU Reimbursements backup documentation:

Human Subject name, address, value of gift incentive, purchase receipt, and Protocol ID number.

Or

Attestation
Cash under $100 Request Advance through iOU to be used to obtain cash to pay Human Subjects

(Non-resident aliens may not be paid cash using the advance method)

Or

Request check(s) payable directly to Human Subjects through iOU Other Checks
List of participants to include:

Human Subject name, SSN (required for SU or SLAC National Accelerator Laboratory employee), address, signature and date of interview or activity, and amount

For Stanford or SLAC National Accelerator Laboratory employees:
SSN, Name, and Protocol ID number. Indicate that the recipient is an employee (if clearing advance) so that a 1099 can be produced

For Non-employees:
Human Subject name, SSN if available, address, signature, date of interview/activity, amount, and Protocol ID number;

Or

Certification that required information is on file and available in department.

Payment or non-cash incentive of $100 or more. (For non-resident aliens, also see section below.)
≥$100 cash incentive Request Advance through iOU to be used to obtain cash to pay Human Subjects

(Non-resident aliens may not be paid cash using the advance method)
List of participants to include:

SSN, Human Subject name, address, signature and date of interview/activity, amount.

Clear advance in iOU Reimbursements with the following: Human Subject name, SSN, address, signature and date of interview/activity, amount, and Protocol ID number.

Indicate that the recipient is a Stanford or SLAC National Accelerator Laboratory employee so that a 1099 can be produced.

Check for ≥$100 payable directly to human subjects Request check(s) payable directly to Human Subjects through iOU Other Checks SSN, Human Subject name, address, signature and date of interview/activity, amount. Copy of green card, or other non-resident documents if applicable. Name or protocol number of study, SSN, Human Subject name, address, signature and date of interview/activity, amount, and Protocol ID number.
Refer to the following documents for additional information for Non- employee, Non-US residents:
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