UC IRVINE ADMINISTRATIVE POLICIES AND PROCEDURES

Business and Financial Affairs

Accounting

Sec. 701-03: Payments to Research Participants (Human Subjects) - Procedures

Responsible Office: Accounting & Fiscal Services
Revised:
September 2018

References / Resources

Contact: Accounts Payable Manager at (949) 824-5286

Contents

A. Policy
B. Definitions
C. Responsibilities
D. Procedures
E. Reimbursement of Expenses to Participants

A. Policy

It is not uncommon for human research subjects (participants) to be paid for their participation in research. Payment for participation in studies is not considered a benefit, it is compensation for time, effort and for study-related expenses. It could also be considered a recruitment incentive.

The amount and schedule of all participant payments must be presented to the UCI Institutional Review Board (IRB) at the time of initial review. The IRB reviews both the amount of payment and the proposed method and timing of disbursement to assure that they are neither coercive nor present undue influence [45 CFR 46.116, 21 CFR 50.20]. Compensation can be in the form of money, certificates, products, or other incentives. In some cases, payments are made to the parents or legal guardians of the participants.

Investigators must not deviate from the amount, type, or timing of compensation without amending their protocol and securing IRB approval.

B. Definitions

Anonymous: Use of 'anonymous' in this section refers to a participant’s identity not being disclosed to Accounts Payable when processing a participant payment. If a participant is 'not anonymous' or 'non-anonymous', their identity is revealed in the documentation provided.
Participant Payment Types: Payments may be made to participants using the following methods:
  1. Direct Deposit or University Check (only if participant is not anonymous)
  2. Gift Card *
  3. Cash *
  4. Money Order *
    * See Part C. Responsibilities.

C. Responsibilities

Researchers/departments must:

  1. Keep track of how much is paid to each participant and obtain and keep on file a completed Acknowledgement of Patient Compensation form for each participant.
    • Note: If the amount paid to a participant during a calendar year is $600 or more, participant anonymity cannot be maintained because the University is required to report such payments to the Internal Revenue Service. Completing the Acknowledgement of Patient Compensation form ensures that participants are notified of this.
    • Deadline: By January 5th please submit to Accounts Payable for 1099 processing your:
      • log of anonymous participants who received $600.00 and over; along with
      • the Acknowledgement of Patient Compensation forms.
  2. Record in a log or other research document (such as the Certification of Payments to Anonymous Persons form) participant payments by Gift Card, Money Order and Cash, and include:
    • Date of the transaction
    • Signature of participant acknowledging receipt of payment
    • Subject ID code (alpha/numeric code assigned by researchers to protect the identity of participants)
    • Protocol name or number
    • Amount of payment
    • Name of the person making the payment.
  3. Physically safeguard Cash, Gift Cards and Money Orders from loss at all times:
    • Place them in a safe or a locked receptacle, and keep the receptacle in a properly secured area (see BUS-49 Section IX for more details for cash amounts of $2,500 or more).
    • They should be reconciled regularly (not less frequently than quarterly and upon termination of any award) by research personnel employed by the University or fiscal officer.
    • In the event of a theft, the loss must be reported to the UCI Police Department.
  4. Ensure an individual who is not involved in other study procedures (for example an administrative assistant or fiscal officer) witnesses payment transactions.

D. Procedures

Procedure to access funds will depend on the preferred Participant Payment Type and whether the participant is anonymous or not:

Procedure Anonymous Participant Payment Types Non-Anonymous Participant Payment Types
1. Direct Deposit or University Check: N/A Direct Debit or University Check
2. Corporate Card: Gift Card / Money Order Gift Card / Money Order
3. Cash Advance: Gift Card / Money Order / Cash Gift Card / Money Order / Cash
4. Personal Funds Reimbursement: Gift Card / Money Order / Cash Gift Card / Money Order / Cash
  1. Direct Deposit or University Check

    Payment by Direct Deposit or University Check may be used only when participants are not anonymous.

    1. If the participant is not already in UCI’s financial system (KFS) the researcher/department should submit Vendor Onboard Request for the participant.
    2. If/when the participant is onboarded in KFS, prepare a Disbursement Voucher (DV) payable to the participant using reason code ‘C’, and attaching the following supporting documents:
      1. IRB approval letter showing the expiration date;
      2. portion of the IRB approved protocol showing the payment amount; and
      3. departmental Compensation Form or patient payment letter that shows the amount due.
  2. Corporate Card
    1. Procedure for purchasing Gift Cards or Money Orders, from a retailer of your choice, using a Corporate Card:
      1. Purchase a small number of Gift Cards or Money Orders at one time:
        • so that the retail limit on the Corporate Card is not exceeded;
        • because it is easier to track and safeguard smaller numbers of Gift Cards and Money Orders (Part C.3. above); and
        • most Gift Cards are not refundable and all purchased Gift Cards will be charged to the study, used or not.
      2. Retain receipts so they can be included with your reimbursement request.
      3. Gift Cards and Money Orders should be distributed to participants within 30 days of purchase.
    2. Reimbursement: Initiate an ENT document to pay the amount owed on the Corporate Card directly on behalf of the cardholder.
      Note: Fees for Money Orders may not be charged to federally sponsored projects.
    3. If you do not have a Corporate Card and wish to apply for one:
      1. You must have a TEM profile in KFS:
        • If you have been previously reimbursed for travel, you should already have a TEM profile
        • If you don’t have a TEM profile it is easy to set up a profile.
      2. Click here to apply for a Corporate Card. Please specify in the description field that the card will be used to purchase gift cards for research participants.
  3. Cash Advance

    Cash Advances may be used to pay participants with Cash, Gift Cards, or Money Orders.
    (Note: Fees for money orders may not be charged to federally sponsored projects.)

    1. Prepare a Human Subject Cash Advance Payment Request Form (Cash Advance Form), payable to research personnel employed by the University and named in the IRB narrative, with the following information in the "COMPLETE DESCRIPTION OF PAYMENT" area:
      i. Length of time the cash advance will be needed, to a maximum of four months iv. Amount to be paid to each participant
      ii. Expected date Accounting will receive documentation supporting the payments to participants v. Dollar amount of the advance
      iii. Number of participants to be paid vi. Name and protocol number of the research project
    2. Email the approved Cash Advance Form and a copy of the IRB approval letter to Accounts Payable.
    3. Each cash advance must be cleared upon completion of the research or by the date specified on the cash advance, whichever comes first. When warranted, due dates may be extended by the Accounts Payable Manager or the Accounts Payable Assistant Manager.
    4. To clear a cash advance, send a completed Certification of Payment to Anonymous Persons, and a copy of the Cash Advance Form, to Accounts Payable. If total payments reported on the form are less than the cash advance amount, attach a check payable to "UC Regents" for the difference.
  4. Personal Funds Reimbursement

    Submit a Disbursement Voucher (DV), using reason code 'C':

    • made payable to the employee who has used personal funds (do not include a Social Security Number);
    • for the total amount to be reimbursed;
    • approved by the PI (Chair or Dean, if employee is the PI); and
    • attach:

E. Reimbursement of Expenses to Participants

If a participant has signed an IRB-approved consent form allowing their travel expenses to be paid for by the study, the PI should obtain funds, pay the participant's expenses, and settle the funds, using a method described in Part D. Supporting documentation for the reimbursement should be retained in the departmental records. In order to protect the anonymity of the subject, no receipts should be sent to Accounting.