2026 IRS reporting change for research subject compensation 

• 1099 reporting has changed as of Jan 1, 2026
• Research subject compensation threshold change for tax reporting from greater than $599 to greater than $1999.
• $100 compensation threshold for collection of SSN has not changed.
• PI responsible for updates. 
• Submit a modification updating the IRB applications and/or informed consent documents. (as needed)
• Subject reconsent is not necessarily required solely for the threshold change.
• Subjects should be informed of the change.
• Describe respective notification plans as part of the modification.  
  • It could include a phone call, conversation at next visit, etc.
  • Note to file documentation if there is not formal reconsent. (e.g. signed consent)