3417 PR.01 Human Research Study Participant Remuneration

Revision Date: 
February 16, 2010

1. Overview

This procedure addresses the methods to disburse remuneration to persons who volunteer in human research studies. Remuneration to human research study participants can take the form of cash, checks, gift certificates, toys, etc., depending on the study, as appropriate and approved by the Yale Institutional Review Board (IRB).

Confidentiality Considerations:

If a study is designed in a manner that restricts information (e.g., a human research study participant’s name and other identifying information) to the Principal Investigator (PI) or to a research team member responsible for the remuneration, then the appropriate method of remuneration is typically cash and/or non-cash remuneration such as gift cards.

If a study is designed in a manner that does not restrict information (e.g., a human research study participant’s name and other identifying information) to the PI or to a research team member, then remuneration may take the form of check as well as cash and/or non-cash remuneration such as gift cards.

2. Remuneration Methods for Human Research Study Participants

There are several methods to receive the necessary funds in order to provide human research study participants with their appropriate remuneration. All methods are considered and treated as an advance (except for checks to the human research study participants) to the requestor (PI or designee) and the applicable forms require business office approval (see section 4 below):

Remuneration by Cash Advance or through Petty Cash Funds

Cash Advance: The preferred method for requesting funds for the purposes of human research study participant remuneration is to complete form 3417 FR.01 Human Research Study Participant Advance Requestand submit the form to either Treasury Services with a valid Yale University ID for cash or to Accounts Payable for a check. The advance can be disbursed to the PI or designee as follows:

  • Remuneration in the form of cash up to $500 and travelers checks for amounts in excess of $500.
  • Remuneration in the form of a check payable to the PI or designee.

The cash, travelers checks or check would be used for distribution to human research study participants or can be used to purchase gift certificates or other forms of compensation for distribution. These funds are to be treated as a Human Research Study Participant advance (expenditure type #034181).

Replenishing/Clearing an Advance: Advances must be reconciled, replenished or cleared monthly as appropriate. In order to replenish or clear the advance, form 3417 FR.0Human Research Study Participant Replenishment/Clearing must be used and the total payments charged to expenditure type 833800. This form must be completed and submitted with required information (see section 3 below). This form can be submitted to either Accounts Payable for replenishment by check (allow three days to process) or visit the Treasury Services window for cash up to $500. Traveler checks are issued for or amounts greater than $500. The amount paid to human research study participants must be indicated on the form. 

Non-cash remuneration can be cleared from the advance by completing and submitting form 3417 FR.02 Human Research Study Participant Replenishment/Clearing with the required information (see section 3 below).

Partial replenishment of an advance will be disbursed to the PI or his/her designee only if the amount of the replenishment is supported by the completion of form 3417 FR.02 Human Research Study Participant Replenishment/Clearing with the required information (see Section 3 below)There should not be any commingling of advances among Principal Investigators.

Specialized Petty Cash Fund: Specialized petty cash funds (refer to Procedure 2815 PR.01) may be used to issue remuneration of cash or travelers checks to the human research study participants or can be used to purchase gift certificates or other types of compensation for distribution. If specialized petty cash funds are used for remuneration to human research study participants, such funds should be requested by completing form 2815 FR.03 Petty Cash Fund Request as the funds are disbursed. 

Replenishing/Clearing a Specialized Petty Cash Fund: The specialized petty cash fund must be reconciled, replenished or cleared monthly. In order to replenish or clear the specialized petty cash fund, complete form 3417 FR.01 Human Research Study Participant Replenishment/Clearing, indicating the amount of the reimbursement and include the required information (see section 3 below). When closing the specialized petty cash fund, any excess funds must be returned using the process outlined in Procedure 2815 PR.04 Closing a Specialized Petty Cash Fund.

Partial replenishment of the specialized petty cash fund will be disbursed to the PI or his/her designee only if the amount of the replenishment is supported by completing form 3417 FR.02 Human Research Study Participant Replenishment/Clearing with the required information (see Section 3 below). There should not be any commingling of advances among Principal Investigators.

Remuneration by Check

For remuneration to human research study participants using a check, complete form 3401 FR.02 Check Request (CR) payable directly to the human research study participant for any remuneration of $100 or more. Since human research study participants must be set up in the University’s vendor database in order to receive a check, the study coordinator (or equivalent) should first determine if the human research study participant is already in the University’s vendor database. If not, the study coordinator (or equivalent) must complete form 3205 FR.01 Vendor Setup Request upon enrolling the human research study participant in the study. 

The department must issue individual payments of less than $100 to study participants either from funds obtained from the cashier’s window (in advance) (only with a valid Yale ID) or from a designated departmental petty cash fund maintained for this purpose only. Payments of less than $100 can also be made through the use of gift certificates or in certain cases non-cash compensation as approved by the IRB. For payments of less than $100 non-cash compensation, 3417 FR.02 Human Research Study Participant Replenishment/Clearing form must be completed to replenish/clear the advance or replenish the petty cash fund.

If the payee is not a U.S. citizen or U.S. lawful permanent resident, and remuneration is permissible pursuant to the immigration rules, additional documentation may be required (refer to Check Request for International Payees).

Non-cash Remuneration Using EMS

The Expense Management System (EMS) may be used to purchase non–cash remuneration (gift cards, books, etc).  For such purchases, expense type 034181 Human Research Study Participant Advance must be selected in the EMS system and Form 3417 FR.02 Human Research Study Participant Replenishment/Clearing must be used to clear the advance.

Reimbursement of Expenses

For reimbursement of expenses to Human Research Study Participants, complete form 3417 FR.02 Human Research Study Participant Replenishment/Clearing and charge the appropriate expenditure type (e.g. for mileage charge 871040).

3. Required Information and Supporting Documentation for Human Research Study Participant Remuneration

Form 3417 FR.02 Human Research Study Participant Replenishment/Clearing must be completed to support all human research study participant remuneration. The following information is required on the form:

  • IRB protocol #;
  • PI name;
  • date of human research study participant intervention, participation, interview, etc.;
  • human research participant name or identification number;
  • amount of disbursement; and
  • researcher receiving remuneration for distribution. 

In addition, form 3417 FR.02 Human Research Study Participant Replenishment/Clearing must be approved and signed by the PI or designee but not the person who distributed the funds. Also, each advance for each study must be separately accounted for, monitored, and reconciled. There should not be any commingling of advances among Principal Investigators.

The information below is required as part of the research record supporting remuneration to human research study participants:

  • date of intervention, participation, interview, etc.;
  • date of disbursement of remuneration;
  • type of intervention, participation, interview, etc. with human research study participant for which remuneration received (completion of survey, MRI, etc.);
  • type of disbursement (cash, gift card, etc.);
  • amount of disbursement;
  • researcher disbursing the remuneration;
  • human research participant name or identification number; and
  • IRB (HIC/HSC) protocol number.

4. Roles and Responsibilities

Researcher

The PI or his/her designee (i.e., someone with direct knowledge of the study) is responsible for:

  • safeguarding the funds, including gift certificates or other compensation, until they are distributed;
  • issuing individual remuneration to human research study participants participating in the study;
  • maintaining appropriate supporting documentation verifying participation in the study for each human research study participant remuneration (e.g., receipts should be pre numbered), remuneration logs, study participants identified to the extent possible, and
  • depositing unused funds using a Receipt Identification Form (RIF) to the advance, or closing the specialized petty cash fund and returning any cash or unused gift certificates to the department’s business office.

Department Business Office

The department business office must authorize all forms regarding human research study participant remuneration. The department business office is responsible for:

  • Ensuring the required information (see Section 3) and appropriate signatures are included on all forms regarding human research study participant remuneration;
  • Ensuring the research study associated with the remuneration request has an IRB-approved protocol congruent with the funding source being charged (if applicable); 
  • Ensuring the research study associated with the remuneration request has remuneration noted in the sponsored project budget of the funding source being charged (if applicable); and
  • Following up with researchers to reconcile, clear or close outstanding advances.       

5. Tax Information

Remuneration made to a human research study participant may be considered taxable income to the participant.

For non-confidential human research study participants, if the total remuneration made by Yale to a U.S. study participant during a calendar year is $600 or more, the University is required to provide the human research study participant with an Internal Revenue Service (IRS) Form 1099-MISC, Miscellaneous Income. The University is required to report all remuneration to a human research study participant who is neither a U.S. citizen, U.S. permanent resident nor resident alien, on an IRS Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding; such remuneration may be subject to federal income tax withholding. Please refer to Check Request for International Payees for additional information regarding documentation requirements as well as withholding and reporting for individuals who are neither U.S. citizens, permanent residents nor resident aliens.

All participants should be informed that all human research study participant remuneration is taxable income to the recipient.