Paying Human Subjects Directly

See also the Job Aid: Transaction Justification/Documentation Standards for All Non-Sponsored and Sponsored Transactions

1. Prior to payment.

   Confirm the individual receiving payment is a valid human subject at the time of the research participation and that IRB approval was current at the time of subject contact. (See Appendix A: Required Confirmations Prior to Payment)

2. Determine form of compensation and the correct form to use.

   The form needed to process the payment depends on what type of compensation is being issued or needed. Use the list below as a general guide. If a particular type of payment is not listed here, contact the Helpline at 612-624-1617 for assistance.

   Making Direct Payments to Human Subjects - Options Available:

   1. Request a cash advance (to distribute cash to Subjects on-site) (see Appendix B for appropriate handling of cash advances):

      1. Process a TA (Travel Authorization form in the Forms Library) and a Cash Advance in the financial system.to request an advance for the employee responsible for disbursing the cash to the subjects.
      2. Process an Employee Expense Worksheet and process it in the Expense Module (Expense Report) to account for the distribution of the cash advance. Include the number of payments made and the denominations in the documentation.

   2. Pay the Subject by check (non-reimbursement):

      1. Use a Check Request Form
      2. Use a Zero Balance Account to issue payment.
   3. Non-cash payments (i.e. gift certificates, T-shirts, etc.), when purchasing items to distribute to subjects, the vendors should be paid by:
      1. Using the University's Procurement Card
      2. Processing the vendor invoice.
      3. Complete a Check Request Form to request payment (if an invoice cannot be obtained).

   4. Reimburse expenses incurred by subject by check (for expenses such as travel, parking, daycare):

      Use a Check Request Form for US residents and for nonresident aliens
      1. Use a Zero Balance Account to issue payment.
      2. Payments to U of M employees should be sent to the Cluster and processed in the Accounts Payable Module.

3. Complete the payment document, while maintaining confidentiality

   It is required that the confidentiality of the study and the human subject(s) be maintained. The only explanation that is required on the payment document is: "Details are on file in department and available for audit". Attachments identifying the Human subject(s) or the name of the Study should NOT accompany the payment document.

   Therefore, when completing the appropriate form(s) requesting reimbursement or payment, include only the name and address of the payee, social security number, account string and amount. Journal entries for payments made using Zero Balance Accounts should only designate the account string and amounts.

4. Obtain required approvals and forward document for processing.

5. Maintain payment records

   To protect the confidentiality of subjects, all details must be maintained in the departments. Departments are required to maintain proof of payments made to research subjects for both cash and non-cash payments. This can be in the form of a log or pre-numbered department receipts. The recipient is required to sign the log or the receipt to indicate the payment was received, unless it is a non-cash payment of nominal value. Non-cash payments under $10 are not required to have a signature.

6. Report total payments of $600 and over

The necessary reportable payment details will not be available centrally for all subject payments, such as non-cash payments, cash payments (made on-site) and payments made from Zero Balance Accounts. As a result, University departments are required to report the names, addresses, social security numbers and total amount of payments made by the University to individual subjects that receive cumulative payments/value of $600.00 or more during a calendar year. This information must be forwarded by mail to the Disbursement Services Tax Desk by December 31st every year.