- Is it possible to pay research participants without collecting their Social Security Number (SSN)?
- When do I need to submit a modification to the IRB?
- Should I attach the Research Participant Substitute W-9 to the HawkIRB application?
- Can I save SSNs for future payments to subjects?
- Does this information apply to VA research projects (IRB-03)?
- How does the UI Cash Handling Policy apply to my project?
- Should I attach the Cash Handling Plan proposal to the HawkIRB application?
- What happens if I am using eVoucher, and subjects are paid directly from Accounting Services?
- What if a Principal Investigator is personally funding a research project?
- Can I mention compensation amounts in recruitment materials?
1. Is it possible to pay research participants without collecting their Social Security Number (SSN)?
Yes. For non-VA payments under $100, or cumulative payments of less than $600 in a single calendar year, you do not need to collect a Social Security Number. This provides additional privacy protections for subjects, and meets IRB expectations that no more that the minimal amount of information required to conduct the research project will be collected. All other contact information found on the substitute W-9 form is required regardless of the compensation thresholds. (The Research Participant/Substitute W-9 is a form that collects basic participant information, like name and address, and includes a signature to certify accuracy of the information.) For a comprehensive description of the University of Iowa policies for research subject compensation, please visit the Grant Accounting Office website here.
2. When do I need to submit a modification to the IRB?
A modification is required to be submitted to the IRB when a SSN is collected and no longer needs to be collected under the new compensation thresholds. For those studies providing compensation of $25.01 up to $100.00, the informed consent document should be updated to remove the SSN section and Question X.2 should be updated from Yes to No. A modification is not required for studies exceeding compensation of $100.00 where an SSN\TIN is collected but the only change would be to update internal practices to the new substitute W-9 collection process outlined in the Guidelines for Research Payment and Compensation policy.
3. Should I attach the Research Participant Substitute W-9 to the HawkIRB application?
No, the Research Participant/Substitute W-9 is now a standardized form maintained by the UI Grant Accounting Office therefore attaching this document to the research application is not required. The link to the W-9 form can be found here. This form should be completed during the initial informed consent process and must be completed prior to research activities occurring. You can reference the W-9 form in Question VII.E or Section X of the HawkIRB application when describing the compensation plan or SSN collection.
4. Can I save SSN\TIN for future payments to subjects?
No, please see the HSO Guidelines for Research Payment and Compensation. If a study will provide multiple payments over a period of time, the Social Security Number or Taxpayer Identification Number must not be kept in the research files for future payments. The identification number must be discarded in a confidential manner once the Research Participant/Substitute W-9 form has been sent to Accounts Payable and a Vendor ID has been assigned to an individual.
5. Does this information apply to VA research projects (IRB-03)?
No, this policy only applies when compensation is issued from UI Accounts Payable. For any IRB-03 projects working with the VA Research Office to issue compensation, the SSN is required for any amount of monetary compensation. For more information on the VAHCS policy for research subject compensation, please see VHA HANDBOOK 1200.05 paragraph 59.
6. How does the UI Cash Handling Policy apply to my project?
U of I Policy University Cash Handling Policies and Procedures apply when the type of research subject compensation using cash, check, or cash equivalent (Cash or cash equivalent is defined as coin, currency, checks, money orders, credit cards, accounts receivable charges, electronic funds transfers, tokens, gift cards, parking tickets and/or stamps) Please click here to review the University of Iowa policy on cash handling.
To review a template for use when creating a cash handling procedure, go to the Accounting and Financial Reporting web site.
7. Should I attach the Cash Handling proposal to the HawkIRB application?
No, Human Subjects Office does not need to see the Cash Handling Plan you propose to the Accounting and Financial Reporting Office. The Cash Handling plan describes how your department handles separation of duties with regard to accounts, and names department staff responsible for different accounting aspects. The HawkIRB application should only contain an Accounting and Financial Reporting approval of such plan--this is most commonly an email from accounting services, stating "your cash handling plan has been approved."
8. What happens if I am using eVoucher, and subjects are paid directly from Accounts Payable?
If research compensation is being generated via a check from the eVoucher system AND is issued from Accounts Payable directly to the subject, cash handling is not applicable. Therefore approval of a cash handling plan is not required. HawkIRB may remind you to attach a cash handling approval memo before the project is submitted, but if both criteria are met, this is not required. However, if research compensation is provided via a check directly to the subject by the research team, please follow the UI cash handling policy.
9. What if a Principal Investigator is personally funding a research project?
If personal funds of the Principal Investigator or a member of the research team are being used to either to provide monetary compensation or to purchase items that meet the UI definition of cash equivalence (Cash or cash equivalent is defined as coin, currency, checks, money orders, credit cards, accounts receivable charges, electronic funds transfers, tokens, gift cards, parking tickets and/or stamps), UI policies on cash handling would still apply. Grant Accounting approval of a cash handling plan will be required.
10. Can I mention compensation amount(s) in recruitment materials?
Yes, It is acceptable to include the compensation amount in recruitment materials. However, recruitment materials (i.e., the initial presentation of information about a research study to potential subjects) should not over emphasize the amount of compensation for participation. For more information, please see the HSO/IRB policy located here.
Any questions related to the University’s policies and procedures on Research Subject Compensation should be directed to The University of Iowa Grant Accounting Office.
For any questions related to policies and procedures on cash handling should be directed to The University of Iowa Accounting and Financial Reporting (cash-handling@uiowa.edu). The Human Subjects Office is not able to provide answers to specific questions on cash handling or W-9 requirements.
