Research Participant Payments Policy

Policy Statement

Background

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:

1. Travel reimbursements: for out-of-pocket expenses such as parking and/or mileage. Travel reimbursements are not taxable.
2. Stipends: provide a reasonable remuneration to participation (e.g. time). Stipends may be taxable and reportable to the Internal Revenue Service (IRS) if certain conditions apply (see "IRS Reporting" below).

Policy

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:

• Obtaining approval from CPHS for any plans that include payments to research subjects.
• Assuring that payments are processed for only approved CPHS protocols and in accordance with the approved protocol. Any deviation from the approved protocol with respect to subject payments must be reviewed and approved by the CPHS. The Principal Investigator and/or Study Team are responsible for working with the CPHS to obtain approvals for changes.
• Maintaining accountability of funds received and disbursed to research participants.
• Obtaining all required information from research subjects.
• Ensuring documentation of payments distributed is maintained for reconciliation, audit, and tax reporting purposes.
• Using only approved payment methods.

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:

• This generally includes parking, gas, and travel reimbursements, and may include per diem (meals).
• Mileage reimbursement may not exceed the current published IRS rate for business miles which can be found at http://www.irs.gov/tax-professionals/standard-mileage-rates

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.

IRS Reporting

• All payments must be supported by source documentation.  Documentation must be retained in accordance with Dartmouth's record retention policy.  In the event of an IRS or sponsor audit/request, it is the responsibility of the PI and their unit to provide appropriate source documentation applicable to the payment method to support each payment. 
• Payments should not be charged to the research project until disbursement.  Any payments that are not distributed (i.e. unused gift cards) cannot be charged to the research project.
• In compliance with Internal Revenue Service (IRS) requirements, Dartmouth reports payments made to human subjects that total $600 or more in a calendar year. This amount is the total from all participant payments regardless of payment type.  Reimbursements for travel and similar expenses are not included in this total.
• Research subjects will be asked to provide basic information including name, mailing address and, in some cases, Social Security Number. The subjects should be informed that the information allows Dartmouth to meet government reporting obligations and precautions are in place to keep this information secure. Subjects may be given the opportunity to waive receipt of payment/s should they wish to not provide identifying information.

 Resources

• Office of the Committee for the Protection of Human Subjects
• Controller's Office
• Office of Sponsored Projects