Research Study Participation - Paying Human Subjects
General
- Participants in approved research study projects may be compensated for their time, effort and expenses related to their participation. Compensation can be in the form of cash, check, gift cards, or other De Minimis items (e.g. t-shirts).
- If the amount paid to an individual during a calendar year is $600.00 or more (regardless of payment type), the University is required to report the payments to the IRS. The department will need to obtain an IRS form W-9 or W-8Ben from the individual participant and turn it into the Accounting Office. Therefore, the participant should be informed that anonymity may not be maintained within the research study program.
- Anonymous participant studies require proof of anonymous requirement attached and witness verification for disbursement of payments. The documentation requirements must be securely maintained by the department in the event of an audit.
Methods of Payment
- Cash Payments - Cash used to pay participants must be physically protected from loss at all times and should be reconciled periodically throughout the study. Procedures should be maintained where more than one individual employee is witnessing the cash transactions.
- If cash payments are made to the participants, the researcher must request a cash advance.
- The cash advance received is to be used only to pay research participants, it cannot be used to purchase any other items.
- All cash payments must be recorded in a log or other research document (see example form), and at a minimum, include the following information:
- Research study conducted, to include date range of the study
- Date and amount of the cash transaction
- Study participants name (non-anonymous study) or the ID code assigned by the researcher for the participant (anonymous study)
- Signature of receipt by participant, when reasonable to do so
- Print name and signature of the individual employee completing the cash transactions
- Print name and signature of the individual witnessing the cash transactions (when required)
- University Check - Payment by university check is preferred, but may be used only when the participants are not anonymous. Payments of any amount can be processed on an Accounts Payable voucher to an individual. A check will be issued and mailed directly to the Research Subject. An IRS form W-9 or W-8Ben is required for all research subject payments in a calendar year, exceeding the IRS limit of $600.00.
- Gift Cards - Gift cards are considered to be the same as cash. The same requirements that apply for cash payments also apply to payments made using gift cards; see Cash Payments above.
- To purchase gift cards, the department will need to complete an Accounts Payable Voucher made payable to the business where the gift cards are to be purchased.
- Generally, businesses will not accept returns of unused gift cards. Thus, if a researcher is not sure how many participants will need to be compensated, it may be difficult to use this option. The researcher may have to wait until all participants have completed the study in order to know the exact number of gift cards to purchase. The cards would then need to be delivered or mailed to the participants.
- Another option would be to purchase limited number of gift cards periodically throughout the research study, as needed, with the end result of zero gift cards leftover.
- If required, gift cards may be mailed to the recipient's. The same requirements that apply for cash payments also apply to gift cards that are mailed, with the exception of the participant signature.
- De Minimis items - Items given to a study participant, in place of cash, check or gift card, should be de minimis in amount, such as providing t-shirts or coffee mugs for participating. For non-grant funding the de minimis amount should be no more than $25 per participant. If purchasing items with grant funding, the items purchased must be specifically approved in the grant budget. Regardless of funding source, the items purchased must meet NDSU allow ability requirements (e.g. no alcohol, tobacco, etc.).The same requirements that apply for cash payments also apply to payments made by providing a product to the participant; see Cash Payments above.
- To purchase items, the department will need to complete an Accounts Payable Voucher made payable to the business where the items are to be purchased.
- If the items purchased cannot be returned for a refund, than the researcher will want to follow the same process as they would when purchasing Gift Cards in sections b and c above.
Paying Employees for Research Study Participation
If the participant in a research study project is a current NDSU employee, the following conditions must be met in order to treat the remuneration the same as if paid to a non-employee:
- The employee's participation is totally voluntary and not part of their University duties;
- The employee participation is on their own time;
- The employee does not perform any service while participating in the research study, that would be performed in the course of their regular duties for the University; and
- The employee is being paid the same as all other participants of the study, with no added benefits or prerequisites for participating. It is the responsibility of the paying department to assure all of the above conditions are met.
If all of the conditions are met, these payments will not be processed through payroll. If all of the conditions are not satisfied, these payments are to be treated as additional compensation to the employee, and will be required to be processed through payroll, and reported as taxable income on the employee's W-2.
Cash Advances
Cash advances are to be requested when paying research study participants in cash. Reimbursements to employees who personally pay cash to a study participant are not allowed and will not be reimbursed. The employee receiving the cash advance will be responsible to NDSU for the return of all cash not appropriately accounted for and/or used for an unallowable university expense. Cash advances may not be made from state appropriated funds.
The following are the procedures in obtaining a cash advance:
- Complete the 'Cash Advance Request' form and attach it to an 'Accounts Payable Voucher'.
- The voucher is made payable to North Dakota State University with Customer Account Services on line 2.
- An explanation of what the cash is for and the specific denominations required need to be in the description section of the voucher.
- The check will be given to Customer Account Services, who will then notify the employee when the cash is ready for pickup. Identification and evidence of adequate means to secure the cash will be required at time of pick up.
- The cash advance request should be submitted and received by the Accounting Office ten (10) business days before the cash is needed.
- The maximum time period for a cash advance is four (4) months. All receipts and documentation must be submitted by the end of the allotted time or prior to fiscal year end, whichever comes first.
- If the research study is longer than four (4) months, the following will need to be completed:
- Take out the advances, as needed, in equal increments over the period of the activity, or
- Turn in any leftover advance money at the end of the 4 month limit, and request a new cash advance for the next four month time frame.
- All cash advances need to be maintained following the proper cash handling procedures to safeguard the assets of the University; contact Customer Account Services for further information on cash handling procedures.
- All unspent cash is required to be deposited at Customer Account Services; do not turn in your unspent cash to the Accounting Office or Grant & Contract Accounting Office. Due one (1) month from the end date requested or by the end of the grant; whichever is first.
- To close the advance, provide a copy of the cash advance voucher request, tracking spreadsheet saved as a pdf (with confidential information hidden), deposit receipt (if applicable) via email to accounting ndsu.accounting@ndsu.edufor non-grant funds and to the applicable grants officer for grant funds. Due one (1) month of the end date requested for or by the end of the grant, whichever comes first.
8. Retain advance details of distribution in department. Should follow the voucher record retention period.
Lost or Stolen
If the cash advance, gift cards or items purchased, are lost/stolen, the employee responsible should notify their department head immediately, and do the following:
- Contact the NDSU Police Office to file a report.
- Inform the G&C Office (grant funding) or the Accounting Office (non-grant funding).
- For cash advances, the department will need to complete another Cash Advance Request form and AP Voucher to replenish what was stolen, using the expense account code of 631005 – Cash Short, using a local fund only; grant funding cannot be used for lost/stolen cash, gift cards or other items.
- Include with the AP Voucher, a statement from the NDSU Police department that a report was filed on the lost/stolen cash/items.
- Once the AP Voucher is processed, the check will be given to Customer Account Services (CAS). The employee in charge of the cash advance will be required to visit with CAS to review cash handling procedures