Policy

The University of Iowa balances a responsibility to maintain various levels of confidentiality for information about human research subjects with record keeping requirements of the State of Iowa, grantor agencies and the Internal Revenue Service.  Payments to subjects in research studies will be recorded as a form of compensation.  Payment may be a type of remuneration including, but not limited to: checks, cash, gift certificates, personal property and other items of value.  

  • Note: University Cash Handling Policies and Procedures apply when the type of payment is made using cash, gift certificates, personal property or any other item of value.  As described in the policy, all University of Iowa units and staff handling these types of payments are required to undergo the departmental and staff certification process.  The policy can be found here: Research Subject Compensation Policy & Procedures

The University of Iowa has adopted the following procedures to assure that these transactions will be reported in accordance with state and federal income reporting requirements with an appropriate level of confidentiality.  

Procedure

Each individual payment to a research subjects exceeding $100 will require the following information:

  • Name of subject
  • Citizenship
  • If not a U.S. Citizen, the following information will be needed.
    • Immigration (visa) status
    • Tax residency country (may not be the same as citizenship country)
    • Permanent foreign address
    • U.S. address
  • Social Security or Taxpayer Identification Number
  • Mailing Address
  • Amount paid or value of the item given as compensation

For check payments of $100 or less, the Accounts Payable Office will need all of the above information except for social security number.

Tax Considerations for Non-Resident Aliens 

  • Federal regulations require that appropriate tax must be withheld at the time of payment.  The rate may vary from year to year.  
  • At year-end, a 1042S tax form is mailed to the individual to be used in preparation of his/her tax return.

Research subject payments to either employees of The University of Iowa or non-employees are charged to institutional account #6240.  Payment is processed through the e-Voucher electronic application.  A notation of “miscellaneous compensation” is the default in the description field. This is what will be printed on the check stub. Once the form is created on-line & routed electronically (through Workflow) for the appropriate approvals, it is directed to Accounts Payable.  The e-voucher can be used to make a single payment to one research subject or payments to multiple subjects (Bulk Voucher).  The Bulk Voucher cannot be used when paying a non-resident alien research subject.  All payments will be mailed to the research subject unless the “Hold Check” box is marked.

Non-employees

Research subject payments to a non-employee of The University of Iowa exceeding a total of $599 from all University of Iowa sources during any calendar year will result in a form 1099 (Miscellaneous Income) being issued to the individual with a copy sent to the Internal Revenue Service.

Employees

Research subject payments to University of Iowa employees will be issued from Accounts Payable and will be separate from an employee’s monthly or bi-weekly payroll check.  All research subject payments are taxable income, however, employees will only receive a 1099 Form at year end if the accumulation of payments exceeds $599. 

Confidentiality

  • Subjects will be asked to provide the basic information including name, mailing address and social security number.  The subjects should be informed that the information allows the University to meet government reporting obligations and precautions are in place to keep this information secure.  Subjects may be given the opportunity to waive receipt of payment/s should they wish to not provide identifying information.  The Institutional Review Board requires this notification in the language of the Consent Form.   
  • Subjects having a compelling need for confidentiality or a concern that a connection may be made between their identity and a particular research project may be paid from a general use departmental account.  The identifying information and the use of institutional account #6240 would still be required.  An adjusting entry (CV) to move expense totals from the general use account to the project account will then be made at the department level.
  • For confidentiality reasons, we have used the notation “Miscellaneous Compensation” in the description field on the e-voucher form.  This is what will print on the check.
  • The information to pay a research subject will be entered on-line into the e-Voucher application and will routed electronically (through Workflow) for the necessary approval/s.  In order to protect subject confidentiality, assure the two necessary approvals are received and expedite the payment process, we will request that the minimum number of approval levels have access to these forms in Workflow.  Keep in mind that the initiator of the form & one other approval is the equivalent of two required signatures. 

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. 

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.

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.

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.

The above policies related to collection of SSN only apply 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.

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.

The 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."

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.

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.

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.