Human Subject Compensation - Disbursements

Institution Review Board (IRB)

Research at UCSD using a human subject must be approved by the Institutional Review Board (IRB) which is an independent committee that protects the rights and well-being of research subjects. As part of the protocol and informed consent process, the IRB reviews all aspects of compensation and reimbursement made to a human subject including amount, proposed distribution method, timing, and if a human subject is either a UCSD student or employee.

The IRB’s approval is limited to the payment and protection of a human subject. The IRB does not have the authority to override IRS/UCSD policy. If there is a need to have a human subject paid in a manner inconsistent with UCSD policies and procedures, contact the IRB Office to ascertain if an exception can be made.

Before payment can be initiated, Principal investigators must renew their IRB approvals annually. The continuation of research after expiration of IRB approval is a violation of the regulations [21 CFR 56.103(a)]. If the IRB has not reviewed and approved a research study by the study’s current expiration date, i.e., IRB approval has expired, research activities should stop. No new subjects may be enrolled in the study.

Confidential Subject Information

On occasion an investigator might feel that it is a breach of a research subject’s privacy to collect their SSN/ITIN; however, UCSD is obligated by law to collect and report a human subjects’ income. The IRS receives the recipient’s name, identification number, street address and total income from UCSD. The information provided to the IRS neither identifies the recipient as a study participant nor the purpose of the payment.

As there are privacy and confidentiality issues, the department is responsible for maintaining a human subjects’ information. As the W-9 contains the person’s SSN/ITIN and other potentially sensitive data, it should be protected. The best way to safeguard sensitive data is to securely transmit the W-9 to Disbursements and not retain a copy in the departmental file.  

Accounting for Payments

Review the current practice of expensing up-front purchases (cards) for a federally sponsored study as most awards indicate that these costs can only be expended to federally funded studies once payment has been distributed to the human subject.

To fulfill UCSD’s tax reporting responsibilities, UCSD is required to obtain the subject's SSN if they will be paid $600 or more in a calendar year to report compensation on IRS Form 1099-MISC. If cumulative payments to a human subject will total $600 or more in one calendar year, the first payment of the calendar year will require a W-9 for U.S. Citizens and Resident Aliens.

Human subject participants should consult with their tax advisor regarding reporting requirements.

Compensation to human subjects who are UC employees will also be subject to 1099 reporting if paid $600 or more in a calendar year and will be reported on tax form 1099-MISC.

Non-Resident Alien

All Non-Resident Aliens receiving payments of any amount should be paid via direct payment through Oracle using the non-PO payment request form within Services & Support. Non-resident aliens receiving compensation are required to complete a GLACIER record prior to receiving payment as federal and state tax withholdings apply. If an account in Oracle does not exist then you will need to submit a new payee request in PaymentWorks to start the registration and Glacier process.

Compensation in Confidential Studies

In certain circumstances, research studies are performed in which the privacy of the subject must be protected and the confidentiality of the data[1] maintained. If the study has been determined to be confidential, the procedures for cash, gift cards, and other non-checks are as follows as these forms of compensation can be processed for up to $600 to any one subject in a calendar year:

• Because the study is confidential, it is unnecessary to identify the name of the subject as is for non-confidential studies; an identifying code must be assigned to each subject
• A listing of these codes, along with the dollar amounts paid to each must be attached to (Certification of Cash Payment to Human Subjects)
• A cross-reference of the coded identification, including the subject’s name, amount received, and date, must be maintained by the Principal Investigator for a period of three years following the submission of the final financial report, unless the terms of the award provide for a different period
• This information is required to be available upon the request of internal/external and the Internal Revenue Service (IRS)
• If amount totals $600 or more then you are required to complete the Human Subject Compensation Income Reporting Record (OnBase) to manually report the income to the tax office.

Total payments to any one subject during the course of a study totaling $600 or more in a calendar year must be paid via direct payment, issued in the form of a check or ACH.  This information will be reported to the IRS, and Form 1099-MISC, will be sent to the payee during the tax season of the calendar year in which the payment(s) were made.