GAP 200.420, Processing Payments to Research Participants

I.    Purpose

II.   Summary of Payment Methods

III.  Procedures

IV.  Forms

 

I. Purpose

When, in the course of conducting research programs that involve individuals, Duke University and Duke University Health System Principal Investigators (PI) may provide compensation using one of five (5) approved payment methods. This procedure describes the circumstances and documentation necessary for each method to satisfy all applicable Federal (regulatory), Sponsor (project specific) and Duke University (internal controls) requirements.

 

II. Summary of Payment Methods

Duke University supports five payment methods for compensating study participants: two primary and three alternative methods. These methods are:

1. Duke ClinCard (primary and preferred method)
2. Duke check (preferred alternate method)
3. Cash
4. Gift card purchased with the Duke Corporate Card (contingent upon prior approval from Employee Travel & Reimbursement)
5. Non-monetary item purchased with the Duke Corporate Card 

Duke ClinCard, a reloadable debit card, is the primary preferred method of paying individuals for participation in a research study. If the use of Duke ClinCard is not applicable, payment via Duke check is the preferred alternative method. Under specific circumstances with prior approval from the designated Duke Representative, payments via cash, gift card, or non-monetary item may be appropriate.

Please note that all methods of compensation are potentially taxable income to the recipient, therefore tax reporting information must be obtained from the participant. A related IRB form should be completed for each participant receiving compensation.

Payments to non-residents for US tax purposes are subject to tax withholding and reporting on a form 1042S. Therefore, payments to non-residents, must be issued using a Duke check. A completed Experimental Subject Payment Form and related IRB form are required for payment. 

There are no exceptions to these five payment methods without prior written approval by the applicable management center in partnership with Employee Travel & Reimbursement.

 

III. Payment Alternative Descriptions

A. Payment via Duke ClinCard (primary preferred)

The research project team should use the Duke ClinCard to provide compensation to research study participants whenever possible. The Duke ClinCard, a reloadable debit card, provides increased efficiencies and internal controls, reducing the potential for loss or misappropriation of funds. Research project teams should note there is a nominal fee associated with this payment method.

Participants are registered in the Duke ClinCard system and assigned a ClinCard.  Completed Personal Data Disclosure Forms are saved to the Protected Data Directory to be reviewed by designated departmental approvers within five business days.  Upon review and approval, funds will be loaded to the participant’s card immediately. 

Questions regarding payments to research participants using the Duke ClinCard should be directed to clincard-request@duke.edu.

B. Payment via check (alternate, preferred)

If Duke ClinCard is not a viable option, Grant Managers and PIs should use Duke checks to provide compensation for research participants. This method is the alternate preferred method, and substantially reduces the potential for loss or misappropriation of funds.

When submitting a request for payment via Duke check, the project research team will use the Protected Data Directory to save the relevant research participant information. Upon review and approval by Employee Travel & Reimbursement. Checks are distributed to the department or individual participants within seven (7) business days.

Questions regarding payments to research participants via Duke check should be directed to clincard-request@duke.edu.

C. 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 method may be appropriate in research programs that involve a very high number of low dollar payments to non-employees or for which payments via check are impractical. The project research team should submit a request to establish a Sponsored Programs/Research Short-term Cash Fund by submitting the Request to Establish a Research Subject Short-term Cash Fund to University Cashiering, as described in GAP 200.032, Research Subject Payments Using Short-Term Cash Funds. All such requests are subject to review and approval by the University's Assistant Vice President & Associate Treasury.

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

D. Payment via gift card or non-monetary item

In certain situations, it may be appropriate to distribute gift cards, including electronic gift cards, or non-monetary items (e.g. Duke memorabilia) to research participants in exchange for participation in approved research studies. Such payments should receive prior written approval  from Employee Travel & Reimbursement.

All gift cards and non-monetary items are purchased using a Duke Corporate Card. Please note that the Internal Revenue Service (IRS) considers gift cards monetary in nature. Therefore, the project research teams are 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, the project research teams are only required to collect the participants’ 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 employeetravel@duke.edu.

 

IV. Forms

When engaging research participants and reviewing the methods of compensation, the project research team must inform these individuals that they are required to submit one of the following two forms which includes identifying information (participant’s name, mailing address, social security number). If participants decline to provide the information, Duke University will be unable to issue payments.

The Personal Data Disclosure Form or Research Participant Payment Verification Form must be signed by each research participant (as required) and authorized by a member of the Duke team conducting the research program.  Please note, these forms are designed to supplement, not replace, the Experimental Subject Payment Form. These required forms must be completed before Duke University will issue payment to research participants: 

1. Personal Data Disclosure Form: for Research Participants: for individuals participating in University or Health System IRB-approved study.
2. Research Participant Payment Verification Form: For individuals participating in an IRB-approved study conducted in any other school, center or academic unit. 

A participant may decline to provide the information, but if it is not collected the participant will not be paid. Likewise, a participant may waive his/her right to payment if he/she does not want to provide the requested information.

A Personal Data Disclosure Form for Research Participants or a Research Participant Payment Verification Form should be completed for each individual who is entitled to receive payment for participation in an IRB-approved research study conducted within the University or Health System. The current version of this form may be accessed on the corresponding IRB website.

Research programs are not required to submit consent forms or study protocols to support payment requests. These documents must be maintained by the Research Coordinators. Submission of the relevant IRB and Experimental Payment Forms is required to initiate the payment.

Questions regarding the Personal Data Disclosure Form for Research Participants may be directed to the School of Medicine Finance Office at SOMFClinicalResearch@duke.edu.

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.