Policy

Payments to Research Participants Policy (GEN 1.5(1))

University of Wisconsin-Oshkosh

 

PURPOSE

To outline the procedure for making and tracking payments to human subjects for participating in research studies while maintaining both participant confidentiality and financial accountability.

Specifically, this policy aims to achieve the following goals in line with the research-enhanced mission of the University of Wisconsin-Oshkosh:

  • Provide timely, convenient compensation to research participants to facilitate the completion of research studies.
  • Maintain participant confidentiality in line with ethical human subject treatment.
  • Provide sufficient financial documentation for the university and IRS purposes.

RESPONSIBLE OFFICER

 

SCOPE

This policy applies to all faculty, staff, and students engaged in human subject research with the university. It also has a minor affect on the Controller and Financial Services office on their processing of payments.

This policy applies to all U.S. persons (citizens and U.S. Resident Aliens, but not nonresident aliens). UW employees are treated the same as non-UW employees when participating as research participants. As per the IRS, research payments are not considered wages and thus, payments to UW employees are not required to be processed through Human Resources/payroll. These policies do not apply to non-resident aliens whom must be processed through the traditional methods with IRS Form 1042S regardless of payment amount due to immigration and taxation documents imposed by Homeland Security and the IRS (see SYS 235, Attachments 7&10).

BACKGROUND

 

DEFINITIONS

Research means a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge.

A human subject/research participant is a living individual about whom an investigator (whether professional or student) conducts research, obtains (1) data through intervention or interaction with the individual, or (2) identifiable private information.

POLICY STATEMENT

The University has adopted policies and procedures that comply with the federal government regulations on the Protection of Human Subjects as stated in the Code of Federal Regulations (45 CFR 46). The University’s Institutional Review Board for the Protection of Human Subjects (IRB) has the responsibility of implementing these policies and assisting investigators in ensuring that the rights and welfare of participants are adequately protected. The IRB shall review all research proposals that involve humans.

Faculty, staff, and students of the University of Wisconsin-Oshkosh frequently conduct research with human subjects. Compensation and/or incentives to participate may be used when deemed appropriate by UWO’s Internal Review Board (IRB) and available resources. As per current standards, cash or cash equivalent payments are considered acceptable forms of compensation with the dollar amount to be specified for each individual study.

  • Effective immediately, if a one-time payment of $100 or less is being made to a research participant, it will be considered de minimis and the requirement to obtain a W-9 may be waived. Researchers are encouraged, though not required to obtain social security numbers and/or taxpayer identification number from the participant to the extent that such information is consistent with the confidentiality protections of the IRB.
  • If the researcher is aware that the participant will be getting multiple de minimis payments and may exceed the IRS limit of $600 per individual per calendar year, it is the researcher’s responsibility to obtain the required documentation. As per current policy (SYS 235, Attachment 10), required documentation includes social security number and/or taxpayer identification number and a W-9 form from the recipient.
  • De minimis payments only apply to research participant Any other payments are subject to the rules and regulations of the university and are not subject to this policy.

Payment Procedures

Payments to participants are to be processed with the methods listed below. In all cases, researchers must maintain a record of all payments and participants. The Principle Investigator is responsible for ensuring all procedures are followed and records of all transactions are maintained for a minimum of five years.

All completed documentation must be submitted to the Financial Services office in Dempsey 236.

  • De minimis payments of $100 or less – Researchers must keep a record of all payments that include the participants legal name, signature or initials, home address, and social security number. However, as per the above policy and IRB ethical standards, participants are not required to provide their social security number if the payment is considered de minimis.
  • Payments over $100, or multiple de minimis payments cumulating to $600 or more – Payments must be submitted to the Financial Services office on the required form and reported to the IRS on Form 1099-MISC, Miscellaneous Income.
  • Regardless of payment amount, if data collection is anonymous as per the HHS regulations (45 CFR 46.101.b), documentation of individual participant information is not required.

RELATED DOCUMENTS

A “Use of Human Participants Application Form”, which includes a description of the University’s policies and procedures, can be obtained from the Office of Grants and Faculty Development and is also available online.

POLICY HISTORY

  • 10/11/2017: Amendment Approval
  • 02/25/2026: Technical revisions to align with WCAG 2.1 AA digital accessibility standards

SCHEDULED REVIEW