Revision Date: January 01, 2026
Policy Sections
3. Payments to Study Participants – U.S. Citizens and Permanent Residents
4. Use of Third-Party Payment Systems
6. Annual University Tax Reporting Process
1. Overview
This procedure describes the process of tracking payments to Human Research Study Participants (“Participants”) for tax reporting purposes. It applies to all members of the Yale University (“Yale”) community involved with the remuneration and/or reimbursement of Participants in research conducted under the purview of the Yale-designated Institutional Review Board (“IRB”) (Yale IRB or an external IRB authorized by the Yale Human Research Protection Program (“HRPP”) to provide review of research on behalf of Yale). For details on the current University-approved remuneration methods and their uses, refer to Procedure 3417 PR.01 Human Research Study Participant Remuneration Process.
Note: this procedure only discusses the tax implications of remuneration for human research study participation. Substantiated expense reimbursements, paid in accordance with University policy, are not addressed in this procedure.
2. Definitions
Custodian
An employee designated as responsible for the management and safekeeping of the funds related to a spend authorization (cash advance). This individual must have direct knowledge of the study and its related expenditures.
Delegate (Workday Preparer)
An individual who has been assigned authority in Workday to prepare expense reports and spend authorizations on behalf of another person.
Human Research Study Participant (“Participant”)
A Human Research Study Participant is a living person who volunteers to take part in a human subject research project.
Human Study Participant Payment Tracker System
A mechanism used to manage and document the disbursement of cash or gift card payments to participants in human research studies, specifically U.S. citizens and permanent residents who meet the specified thresholds. This system ensures all payments are accurately tracked for tax reporting purposes.
3. Payments to Participants - U.S. Citizens and U.S. Permanent Residents
Participants can be paid in three ways:
- OnCore Bank Cards – OnCore System
- Cash/Gift Cards – Spend Authorization Process
- Supplier Invoice Request (“SIR”) - Workday
For detailed guidance on the current University-approved remuneration methods, refer to Procedure 3417 PR.01 Human Research Study Participant Remuneration Process. Prior to payment, each Participant must complete and submit the required tax identification information to the Custodian (or delegate). For cash and gift card payments, the Custodian (or delegate) is responsible for safeguarding the tax identification information. For Supplier Invoice Requests (“SIR”), a Form W-9 is collected in Workday through the supplier onboarding process.
A. OnCore Bank Cards
Prior to payment, or within a reasonable amount of time following payment (e.g., monthly), the Custodian must record and store the Participant’s relevant information (e.g., W-9 or W-8B forms) with the study records.
OnCore automatically add funds to existing cards or issues new cards to new users following participant check-in to the study visit.
The OnCore team must send a report of all study subject payments to studyparticipanttaxreporting@yale.edu. The report, including participant names and associated tax identification information, will be analyzed by the Compensation Compliance Senior Analyst (“CCSA”) within the University Controller’s Office for completeness of information needed for proper tax reporting. The CCSA will follow up with departments regarding any missing relevant information.
B. Cash and Gift Cards
In addition to the standard spend authorization process (refer to Procedure 3305 PR.01 Spend Authorization Process for Expense Advances for additional guidance) each time a payment is made via cash or gift card, the Custodian (or delegate) must complete a record within the Human Study Participant Payment Tracker System. Individual Participant payments totaling $500 or less do not need to be reported.
For access to the system, please email studyparticipanttaxreporting@yale.edu.
C. Supplier Invoice Request (“SIR”)
Supplier Invoice Requests follow the Workday supplier invoice process.
4. Use of Third-Party Payment Systems
The use of third-party payment systems (e.g., AWS/MTurk, Bovitz Inc/Forthright, Prolific, etc.) is allowable for those studies that involve off-campus Participants. Payments to these Participants must not exceed $500 per study per Participant.
5. Payments to Participants for Studies Conducted in the U.S. - Non-U.S. Citizens and Non-U.S. Permanent Residents
Payments to Participants who are non-U.S. citizens and non-U.S. permanent residents should not be processed via cash, gift card, or OnCore bank cards. These payments should be processed through the current Workday accounts payable process, with the Tax department responsible for reviewing all remuneration payments.
The study team is responsible for collecting the necessary additional information (e.g., W-9 or W-8B form) to determine the U.S. tax status of a Participant (e.g., Resident Alien or Non-Resident Alien).
Typically, payments made to non-resident aliens are subject to a 30% federal income tax withholding and are reported on IRS Form 1042-S.
The Payment Planning Tool for Paying Individuals provides information on required forms and documents.
For further information, contact internationaltax@yale.edu.
For studies conducted outside of the U.S., involving non-U.S. persons, for tax purposes, contact internationaltax@yale.edu.
6. Annual University Tax Reporting Process
The University Controller’s Office must submit the tax filings associated with Participant payments by January 31st of the calendar year following the calendar year of payment.
The Form 1099 reporting process begins in September, involving the review of payments and contacting departments for missing or inaccurate social security numbers (“SSN”)/ Individual Taxpayer Identification Number (“ITIN”).
Departments must provide requested updated information to the University Controller’s Office by January 15th of the calendar year following the calendar year of payment.
Income tax withholding is required for individuals who have not provided a valid SSN/ITIN. The tax liability will be calculated by the University Controller’s Office with the backup withholding rate of 24% and grossed-up for the tax of the total 1099 payments made and charged to the department owning the study.
Note: this section does apply to tax reporting for payments made directly from Workday.
7. Requesting an Exception
In rare situations, the collection of a Participant’s SSN/ITIN may not be feasible. In such situations, exceptions to this procedure must be approved by the Controller’s Office, in consultation with HRPP, IRB, and the YSM Controller’s Office, as appropriate.
Related Information
Procedure 3417 PR.01 Human Research Study Participant Remuneration Process
Human Study Participant Payment Tracker System
Procedure 3305 PR.01 Spend Authorization Process for Expense Advances