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:
April 2005

References / Resources

Contact: Disbursing Manager at (949) 824-5286

A. Policy

University of California policy provides that human research subjects (participants) may receive benefits, financial or otherwise, for their participation in approved research projects. Participants may be compensated for their time, effort and expenses related to their participation. 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. The UC Irvine Institutional Review Board (IRB) is required to approve, in advance, the method and amount of compensation to any human research participant. Investigators may not deviate from the amount, type or timing of the payment without first obtaining a modification to their approved human subjects protocol.

If the amount paid to an individual during a calendar year is $600 or more, the University is required to report such payments to the Internal Revenue Service. Therefore, anonymity of participants cannot be maintained.

B. Methods of Payment to Participants

  1. University Check

    Payment by University Check is preferred, but may be used only when participants are not anonymous.

    1. Prepare a Check Request (see Section 701-06) payable to the participant.
    2. Prepare a privacy waiver that states the following and includes the participant's printed name, signature, and date:

      "I understand that I will no longer be an anonymous participant in this study. I also understand that my personal information, including my name, address, and social security number, will be released to the Accounting Office for the purpose of payment to me and for tax reporting, if required."

    3. Send the approved Check Request, copy of IRB approval letter, and copy of the privacy waiver to the Accounting Office, Disbursing, Zot Code 1050.
  2. Payment by Cash, Non-University Check, or Money Order

    All fund transactions must be recorded in a log or other research document, 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
    1. Payment by Cash

      Cash used to pay participants must be physically protected from loss at all times (see Section 704-12) and reconciled periodically by study. An individual who is not involved in other study procedures should witness cash transactions.

    2. Payment by Non-University Check
      1. For each study, a non-interest bearing checking account should be opened in the name of the Principal Investigator (PI) and the department chair or administrator. The minimum opening balance may be obtained from the Disbursing Manager at (949) 824-5286. If studies require only a few payments, funds for multiple studies may be commingled in one account. However, it is not generally recommended because the recipient of an advance must maintain a separate balance for each study.
      2. Only negotiated checks (not "un-cashed" or "outstanding" checks) may be charged to federally sponsored projects. Checking account fees (monthly charges, check printing charges, etc.) may not.
      3. The checking account should be reconciled monthly. An individual who is not involved in other study procedures should perform a supervisory review and approve the reconciliation.
    3. Payment by Money Order
      1. If a cash advance is obtained, use the entire amount to purchase money orders in the denominations necessary for payment to participants. Fees for money orders may not be charged to federally sponsored projects.
      2. Money orders on hand should be reconciled periodically to the total amount purchased. An individual who is not involved in other study procedures should perform a supervisory review not less frequently than quarterly and upon termination of any award.
  3. Gift Certificates and Products

    For information on payment alternatives, contact the IRB.

C. Options for Funds Management

  1. Cash Advance
    1. Prepare a Check Request, payable to the Principal or Co-Investigator, with the following information in the "COMPLETE DESCRIPTION OF PAYMENT" area:
      • Length of time the cash advance will be needed, to a maximum of four months
      • Expected date Accounting will receive documentation supporting the payments to human participants
      • Number of participants to be paid
      • Amount to be paid to each participant
      • Dollar amount of the advance
      • Name and protocol number of the research project
      • Payment method to Principal Investigator or Co-Investigator (check or electronic funds transfer).
    2. Send the approved Check Request and a copy of the IRB approval letter to the Accounting Office, Disbursing, Zot 1050.
    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 Disbursing Manager.
    4. To clear a cash advance, send a completed Certification of Payment to Anonymous Persons, and a copy of the cash advance Check Request, to the Accounting Office, Disbursing, ZotCode 1050. If total payments reported on the form are less than the cash advance amount, attach a check payable to "UC Regents" for the difference.
  2. Petty Cash

    In certain circumstances, payments to participants may be made from a petty cash fund. The fund must be established in accordance with Section 704-12, Petty Cash Procedures. To receive additional petty cash funds, complete a Certification of Payment to Anonymous Persons and process the request for reimbursement through Pay Quest.

  3. Personal Funds Reimbursement

    A Check Request, made payable to the employee for the total amount to be reimbursed, should be approved by the PI (Chair or Dean, if employee is the PI). Send the Check Request, a copy of the IRB approval letter, and a Certification of Payment to Anonymous Persons, to the Accounting Office, Disbursing, ZotCode 1050.

D. Certification of Payment

A completed Certification of Payment to Anonymous Persons form is required to clear a cash advance, reimburse a petty cash fund, or reimburse an employee who has used personal funds. The following information is required:

  • Chargable accounting unit (location, account, cost center, fund, project, sub, object, and source)
  • IRB protocol number or exemption registration number
  • Name of Principal Investigator or Co-Investigator
  • Date paid
  • Amount paid
  • Participant's ID number
  • Whether the payment was made in cash or by check
  • Signature or initials of the person who made payment
  • Dollar total on each page and grand total on last page
  • Principal or Co-Investigator's signature and date

E. Reimbursement of Expenses to Participants

If a participant's expenses will 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 this Section. For a participant's travel expenses, the department should also prepare a travel voucher and retain the receipts (hotel folio, invoice itinerary, meal receipts, transportation, etc.) in the departmental records. In order to protect the anonymity of the subject, no receipts should be sent to Accounting.