Payments to Human Research Subjects (A-72)
Original Implementation:July 21, 2009
Last Revision: None
It is recognized that during the conduct of research studies utilizing human subjects that participants may incur personal costs for which they are entitled to reimbursement. It is also desirable in some instances to provide a reward or recognition to participants for the time and effort they have devoted to participation in a research project.
At the time of application to the Institutional Research Board (IRB) for approval of the conduct of research studies utilizing human subjects, the principal investigator (PI) should present a rationale to establish the appropriate level of compensation for participants in the study, if any.
- Any reimbursement or incentive to participants in a research study must not involve coercion or constitute undue inducement or influence an individual’s decision to participate in the study.
- Subject to university policy, compensation may be offered as cash, gift cards, gifts (e.g., t-shirts or coffee mugs), and/or reimbursement for personal expenses such as travel and child care costs. Gifts should be provided to participants at the completion of the relevant activity. Payments by check should be avoided as they require disclosure of personal information to the business office.
- Use of Grant Funds – Reimbursements or incentives for participation in a research study must be detailed in the grant application and in the application to the SFA IRB by method and amount. The payments must be approved by the funding agency and the SFA IRB.
- Informed Consent - It is critical that participants are informed during the consent process that if, either in one or multiple studies in a given calendar year, the total payments and/or gift values exceed $100, their social security number (SSN) and contact information shall be provided to the Business Office for tax purposes. Further, study participants should be informed that if they receive payments that total more than $599, they shall receive a tax form from SFA at the end of the calendar year.
Finally, participants should be told that they can elect not to receive payments to avoid disclosure of this information to the Business Office. - Documentation - PIs are required to maintain a tracking list or spreadsheet with individual code numbers and payments. If compensation is by gift or gift card, the PI must record the individual’s name, SSN, address, and signature at the time of payment. Unless the study guarantees participant anonymity, the PI must also keep a master list linking code numbers and individual participant names, which must be kept in a password protected computer and/or locked filing cabinet. The tracking spreadsheet or other documentation with study and individual code numbers must be kept indefinitely to allow for an audit of expenditures if required.
Cross Reference: Ethical Principles and Guidelines for the Protection of Human Subjects in Research: The Belmont Report; Title 45, Part 46 of the Code of Federal Regulations, as amended; 45 C.F.R. §46.
Responsible for Implementation: Provost and Vice President for Academic Affairs
Contact for Revision: Director of the Office of Research and Sponsored Programs
Forms: Business Office forms and IRB forms