How to Pay Research Participants
Payments to research subjects can raise issues that cut across regulatory, financial, and academic areas. The issues to be addressed include ethical treatment of subjects, financial stewardship, documentation, and grants management.
Dartmouth is responsible for properly accounting for all payments made to individuals to ensure fiscal accountability and meet federal reporting obligations. The Research Participant Payments Policy provides documentation and reporting requirements to faculty/staff involved in processing payments to research subjects while still maintaining appropriate levels of confidentiality and minimizing administrative burden when possible.
Methods
1. Gift Cards and Certificates
Preferred Method When
Gift cards and certificates are preferred for most studies. In purchasing gift cards and certificates, researchers and grant managers should reasonably estimate the number and timing of purchases in advance of use to mitigate having excess cards to secure and track. Gift cards or certificates purchased for research should not be used for purposes other than distribution to research subjects. If gift cards and certificates purchased from sponsored funds are not utilized for the project prior to the end date, the value of the unused gift cards must be reimbursed to the grant.
For long term studies with recurring payments to the same participants, please see below for additional options.
Documentation in Study/DRA file
Payee name, address, and social security number (if cumulative payments during the calendar year could reach $600) plus documentation showing receipt of payment by recipient, with participant's signature must be maintained.
If identifying information about research participants will not be collected, the Principal Investigator is responsible for establishing a way to track the gift cards or certificates given to participants for reporting purposes. The documentation can be a single receipt per recipient or listing with verification of amount received and participants' signature as applicable.
If recipients are offsite and cards are mailed or are distributed electronically, documentation must include reconciliation of cards purchased and distributed, and certification that all cards charged to the grant were distributed to participants.
Purchasing and Process Requirements
Gift cards can be purchased with a procurement card or corporate card. Receipts should be attached to the iExpense expense report for corporate card purchases or the PCard eForm for procurement card purchases.
2. Virtual Incentives – reloadable card
Preferred Method When
Virtual Incentives is a company that specializes in managing digital incentives and payments. Virtual Incentives cards may be appropriate for large-scale studies where the confidentiality of the participants must be maintained, and individual participants receive multiple payments over the course of the study.
Participants must be informed of potential fees assessed for use/non-use of the Virtual Incentives card.
Documentation in Study/DRA file
Payee's full legal name, address, and social security number (if cumulative payments during the calendar year could reach $600) must be maintained.
Virtual Incentives cards are assigned to individuals but use a code in the system to maintain confidentiality. Records must be maintained in the study files to identify individuals associated with the codes in the Virtual Incentives system for audit and tax reporting, if required.
An administrator(s) must be named for each grant that uses Virtual Incentives cards. This person is responsible for maintaining the records and managing the reloading of the cards.
Process Requirements
Contact Accounts Payable for detailed information regarding the program to determine if this option is appropriate. It can take several weeks to setup the program, receive the cards, and gain access to the system, so it is essential to plan ahead.
3. Drawing
Preferred Method When
Eligibility for a prize may be appropriate when the nature of the study requires limited incentive, such as one-time participation in an online survey.
The consent form and recruitment materials (as applicable) must state the chances of winning.
To avoid confusion with state-regulated gambling activities, the drawing may not be called a "raffle" or "lottery".
Documentation in Study/DRA file
Prize winner legal name, address, and social security number (if cumulative payments/prizes during the calendar year could reach $600).
Process Requirements
Prizes with a value of $600 or greater must be reported to the IRS. If the value is $600 or greater, provide the name, address, and social security number to Accounts Payable for tax reporting through the General Request eForm and select the “Tax Reporting” request type.
4. Other Items of Value (e.g. hats, tangible gifts)
Preferred Method When:
Depending on the nature of the study, other items of value may be appropriate.
Documentation in Study/DRA file
Payee name, address, and social security number (if cumulative payments during the calendar year could reach $600).
Purchasing and Process Requirements
The items may be purchased with a procurement card or corporate card. Receipts should be attached to the iExpense expense report for corporate cards or the PCard eForm for procurement card purchases.
Item(s) with a value of $600 or greater must be reported to the IRS. If the value is $600 or greater, provide the name, address, and social security number to Accounts Payable for tax reporting.
5. Electronic Payment to Participant/Accounts Payable Payment
Payment may be made to the individuals via Accounts Payable. This option requires an individual to register in Dartmouth’s vendor portal and choose their payment method (check or electronic transfer).
Documentation in Study/DRA file
Legal Name of Payee: Full legal name (Initials or nicknames should not be used in place of first names). The name of the Payee must correspond to the name for the tax identification number provided.
Payee's Legal Mailing Address: Legal or business address (street, city, country, and zip/postal code) for tax purposes of the person receiving the payment must be provided.
Social Security number of the payee. If an international student or visitor has not been assigned a social security number, indicate the individual's country of citizenship.
Process Requirements
Completed Payment Request eForm should be submitted with appropriate approval per the Dartmouth College Signature and Requisition Authority Policy.
Cumulative participant payments of $600 or more in a calendar year must be reported as taxable to the IRS. Dartmouth College will issue Form 1099-MISC or 1042-S (Foreign Person's U.S. Source Income), as required.
If you have any questions about a particular situation, please contact the Finance Center or Accounts Payable prior to submitting the Payment Request eForm.
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