GAP 200.420, Processing Payments to Research Participants

  1. General
  2. Summary of Alternatives
  3. Payment Alternative Descriptions

 


 

I. GENERAL

This document details and differentiates the alternatives available to members of the Duke community when compensating individuals for participation in a research program. It also details the advantages and disadvantages of each alternative, and provides relevant contact information.

 

II. SUMMARY OF ALTERNATIVES

Duke University supports one (1) primary and three (3) alternative methods of compensating individuals for participation in a research study. These methods are:

  1. Duke check (primary and preferred method), via Employee Travel & Reimbursement using the Experimental Subject Form
  2. Cash, via the Cashier's Office using the Sponsored Programs/ Research Short-term Cash Program
  3. Gift card, typically purchased with the Duke Corporate Card or via Accounts Payable
  4. Non-monetary item, typically purchased with the Duke Corporate Card or via Accounts Payable

Because of significant internal control and administrative advantages, the preferred method of compensating individuals for participation in a research study is with a Duke check, via Employee Travel & Reimbursement using the Experimental Subject Form. Under specific circumstances and with prior approval, compensation via cash, gift card, or non-monetary item may be appropriate.

Please note that all methods of payment are potentially taxable income to the recipient, so tax reporting information may be required. Therefore, a related IRB form should be completed for each subject who is entitled to receive compensation for participation in an IRB-approved research study. Refer to section III. D. of this document for details on the required IRB forms.

There are no exceptions to the four payment alternatives listed above without prior written senior officer approval. Each payment alternative is detailed further below.

 

III. PAYMENT ALTERNATIVE DESCRIPTIONS

A. Payment via check (preferred)

Financial Services strongly recommends the use of Duke checks when compensating research subjects. Although this method may require incremental administrative effort, payment via Duke check substantially reduces the potential for loss or misappropriation of funds.

Payee information should be transmitted to Employee Travel & Reimbursement electronically or on paper using the Experimental Subject Form. Once the necessary information is received by Employee Travel & Reimbursement, including the appropriate IRB form, checks will be available for distribution to the department or individual participants within seven (7) business days.

Questions regarding payments to research participants via Duke check should be directed to Employee Travel & Reimbursement at (919) 668-3877.

B. Payment via cash

All cash payments to research participants must be made using funds obtained through the Sponsored Programs/Research Short-term Cash Program (the Program). This Program was created in 2005 and will have very limited application because of the inherent risks associated with disbursing cash; however, in appropriate circumstances, this option will be made available.

Research programs that involve a very high number of low dollar payments to non-employees or for which payments via check are impractical (e.g. research subjects are unable to negotiate checks due to status as minors, illegal immigrants, etc.) may seek permission to use this program. All requests to establish Sponsored Programs/Research Short-term Cash Funds are subject to review and approval by the University's Assistant Vice President/Deputy Treasury.

Questions regarding the Program should be directed to the Cashier's Office at cashier at duke.edu or (919) 684-8214. For further information, please refer to GAP 200.032, Sponsored Programs/Research Short-Term Cash Funds.

C. Payment via gift card or non-monetary item

In certain situations, the distribution of gift cards or non-monetary items (e.g. Duke memorabilia) to research subjects in exchange for participation in a program may be appropriate. For example, a researcher conducting a study on drug addiction may prefer to issue gift cards rather than Duke checks or cash, based on concerns about ultimate use of the funds by study participants. Or, a researcher conducting a study on teenagers may prefer to issue gift cards to a shopping mall or non-monetary items rather than Duke checks or cash, based on the perceived preference of the recipient population. Such scenarios should be discussed in advance with Employee Travel & Reimbursement, in order to minimize the related administrative issues.

Gift cards and non-monetary items are typically purchased using a Duke Corporate Card or Accounts Payable check, and are acceptable if approved in advance by Employee Travel & Reimbursement. Please note that the Internal Revenue Service (IRS) considers gift cards monetary in nature; Duke is therefore required to collect tax information on all gift card recipients for IRS reporting purposes, regardless of the dollar value of the gift card. When non-monetary items are distributed, recipients must provide only their names unless the value of the non-monetary item is clearly in excess of $100.

Questions regarding the issuance of gift cards or non-monetary items should be directed to Employee Travel & Reimbursement at (919) 668-3877.

D. Institutional Review Board (IRB) forms

Potential research subjects for whom compensation for participation will be appropriate should be told before signing a consent form that identifying information (subject's name, mailing address, social security number) must be collected as a prerequisite to payment by Duke University . A subject may decline to provide the information, but if it is not collected the subject will not be paid. Likewise, a subject may waive his/her right to payment if he/she does not want to provide the requested information.

An IRB Personal Data Disclosure Form should be completed for each subject who is entitled to receive compensation for participation in an IRB-approved research study conducted within the Schools of Medicine or Nursing, or DUHS. The current version of this form may be accessed on the IRB website.

A Research Participant Payment Verification Form should be completed for each subject who is entitled to receive compensation for participation in an IRB-approved research study in any other school, center or other unit at Duke. The current version of this form may be accessed on the ORS website.

The appropriate IRB form must be signed by the research subject and authorized by a member of the Duke research team prior to submission to Employee Travel & Reimbursement or other appropriate Duke University office as referenced in this document. Please note that the IRB forms are designed to supplement, not replace, the Experimental Subject Form or other required forms referred to above.

It is not necessary to submit any other documentation in support of a payment request to Employee Travel & Reimbursement if an IRB form and an Experimental Subject Form are submitted. Please do not send consent forms or protocols to Employee Travel & Reimbursement.

Questions regarding the IRB Personal Data Disclosure Form may be directed to the DUHS IRB Office at (919) 668-5111. Questions regarding the Research Participant Payment Verification Form may be directed to the Non-Medical Institutional Review Board at (919) 668-1777.

 

 

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.