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Payments to Research Study Participants

About this Policy

Payments to Research Study Participants

Policy Number: 27011

Effective Date:

Last Updated:

Responsible Office:
UM System Controller’s Office

Responsible Administrator:
UM System Controller

Policy Contact:

Campus Sponsored Program Office


  • Finance

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This document describes how human research Participants taking part in a study approved by the campus Institutional Research Board (IRB) are compensated for participating in University research projects.  This policy provides authoritative guidance regarding issuing and controlling payments to research study Participants.

Reason for Policy

This guideline is necessary to ensure the proper handling of confidential research subject information and ensure compliance with reporting requirements associated with compensating research study Participants. 

Policy Statement

All payments to human Participants are treated with utmost confidentiality. Research studies often involve individuals who participate in the study. As needed, Participants may be compensated for their participation. The method of compensation should be designed to:

  • Ensure the confidentiality of research Participants
  • Provide timely, convenient compensation to Participants to facilitate, not hinder, the study
  • Record compensation in the accounting system for both financial records and IRS Form 1099 purposes
  • Document that compensation was for participation in a study
  • Ensure appropriate internal controls and adequate safeguards exist for items of value used to compensate, whether Cash, checks or other

Determining Method of Compensation
The method of compensation must be determined before the research begins and should take into account the following:

  • Confidentiality
  • Nature and subject matter of the study
  • Nature of the Participant population
  • Dollar amount and time period of payments
  • Variability in the amount of payments
  • Number of payments and Participants involved in the study
  • Location of the study

If the ChartField string debited for the subject payments is a sponsored project and involves payments other than checks or Cash, the department may consult Sponsored Program Office to ensure that the sponsor allows this type of payment. If there are no sponsor restrictions, then the PI should ensure that all allowability criteria are met in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200 and the terms and conditions of the award. SPO can help request approval from the sponsoring agency, if necessary.

Available Methods of Compensation
Research Participants could receive funds from the University for reimbursement and/or compensation.  

The types of payments to Participants may include:

  • Reimbursement to a participant, such as mileage.
  • Paying expenses associated with participant, such as hotel or rental car.
  • Compensation payment direct to participant via:
    • Check
    • Gift Card – prior approval required from Campus Accounting
    • Cash
    • Merchandise
    • Survey Resource

Control and Distribution of Non-Cash Items and Cash
Non-Cash items should be controlled similar to Cash using an approach to ensure that the items are secured and used for their intended purpose. For non-Cash items and Cash, the department must create control procedures.

  • Segregation of Duties: Establish a purchase, documentation and distribution process to ensure duties are segregated between these roles.
  • Purchase: Document Cash/items purchased, including any control numbers.
  • Security: Store the Cash/items in a secure locked location until distribution to research Participants.
  • Receipts at Disbursement: When distributing Cash/items, obtain a receipt.
    • Receipts should include the participant's name, address, social security number, the amount/value of item, and date of payment.
      • Exceptions may be granted by the campus accounting office when the payment must remain confidential.  At a minimum, a unique identifying number for the participant, the date of distribution, and the dollar amount should be documented.
    • Receipts must be signed in ink by the research subject to document acknowledgement of the payment.
    • When items are mailed to Participants, two people must be involved in the process to ensure the item is put in the envelope and delivered to Campus Mail for each compensated event.
  • Verification: Assign someone other than those involved in the research, the responsibility of following up and verifying that the Cash/items were distributed and accounted for. The responsible person should audit the completed receipts and account for the number of items used on the Verification of Receipts for Subject Payment Form.

Reporting Compensation to IRS
The University has tax reporting obligations related to Participant payments and there may be tax implications for recipients who receive compensation for their participation in a research study or reimbursement of expenses not in accordance with the University Accountable Plan Business Expense Reimbursement. 

Departments need to maintain records on any Cash or non-Cash compensation provided (unless the transaction is recorded in the accounts payable system) in sufficient detail to enable tracking for IRS 1099 reporting purposes. The department must maintain a spreadsheet with required 1099 information, such as name, permanent mailing address, social security number, and the payment date and amount. Gift card recipient information must be provided to Campus Accounting.  Recipient information for other forms of compensation is submitted to Accounts Payable Shared Services (APSS) once compensation is disbursed. If the study continues after December 31, the information available should be sent to APSS by January 4 of the following year.


Cash - Currency or coin.

Participants - Individuals who agree to participate in an event or program funded under a sponsored agreement and who will receive a payment for their participation as allowed by the programmatic guidelines and approved by the funding agency. These individuals are the objects of a human subject study, but they are not contributors to the program objectives; and their contribution in and of itself does not constitute an employee- employer relationship, consultant relationship, or service provider relationship.


Campus Accounting Office:

  • Assist in determining most appropriate method of compensation
  • Authorize requests for gift cards as a compensation method.
  • Collect and process gift card logs containing tax-related information for recipients.
  • Approve exceptions to policy

Accounts Payable Shared Services:

  • Collect and process tax-related information for recipients

Principal Investigator (PI):

  • Obtain prior approval from Institutional Research Board (IRB) for research project.
  • Ensure confidentiality and proper protocol procedures are followed.
  • Ensure payment and method are allowable in the terms and conditions of the award and University policy.

Institutional Research Board (IRB):

  • Approval of human research study.


  • Work with Campus Accounting to determine method of compensation.
  • Obtain prior approval from Campus Accounting (required by Gift Card Policy) when using gift cards as compensation method.
  • Establish a purchase, documentation, and distribution process.
  • Initiate transactions, maintain records, reconcile, and complete related reports.
  • Record and submit required tax-related information for recipients

Additional Details



Related Information

Policy 22307 on Awards, Gift and Prizes
Policy 22308 on Gift Cards
Policy 22310 on Expense Reimbursements


Updated 6/1/2021 to add the nature of the participant population in determining the method of compensation and removed the reference to a student or employee for determining the method of compensation.  Receipts at disbursement was updated for the types of data to be collected when the payment is confidential.

Formerly Accounting Policy Manual 60.50 – Payments to Research Study Participants (revised 12/14/2007)


Reviewed 2021-06-01