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. This 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.
The IRS treats research subject payments – checks, cash, gift cards or other items of value – as taxable income to the recipient. IRS reporting requirements for Dartmouth depend on the amount paid and the recipient's tax status. For U.S. Citizens or lawful permanent residents, Dartmouth is required to report the Name, Address, and Tax ID (Social Security Number) of any individuals who receives payments of $600 or more in a calendar year. For non-resident aliens, Dartmouth is required to report the payments, regardless of the amount of payment, and withhold 30% from the payment.
As stated in guidance from the Committee for Protection of Human Subjects at Dartmouth (CPHS), "payment to research subjects may be an incentive for participation or a way to reimburse a subject for travel and other expenses incurred due to participation." The CPHS is responsible for reviewing and approving all research projects involving human subjects.
Payments are typically of two types:
Payments for research participants must follow Dartmouth College financial policies and procedures.
Faculty/staff responsible for authorizing/disbursing payments to research subjects are responsible for the following:
Requests for payments, including complete documentation, should be processed as quickly as possible to avoid unnecessary delays for research subjects. All requests for research participant payments must be in compliance with the CPHS approved protocols for the study. Any payment received by the research participant should accrue as the study progresses; compensation should not be contingent upon the research participant completing the entire study. However, payment of a small portion as a bonus or incentive for completing the study is an acceptable practice so long as the amount is not coercive. Payment to subjects who withdraw from the study can be made at the time they would have completed the study (or completed a phase of the study) had they not withdrawn unless it creates undue inconvenience or a coercive practice.
Department Research Administrators (DRA) can provide assistance and guidance on Dartmouth financial policies and the selection of the appropriate payment mechanism for the study and assisting or preparing and submitting required forms for approval and appropriate processing.
Stipend Payments and Travel Reimbursements
The CPHS approved protocol should describe the approved reimbursements for the study including the distinction between reimbursement for travel and stipend payments.
Reimbursement of Participation-Related Expenses:
Acceptable mechanisms for initiating stipend payments and travel reimbursements to participants are listed on Finance website under how to pay research participants.
Alternate mechanisms should not be used without consultation and approval by the Controller's Office.