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Office of General Counsel Policies & Guidelines

Cash and Gift Card Payments to Research Participants : B-015

Policy/Guideline Area

Business and Finance Guidelines

Applicable Divisions

TCATs, Community Colleges, Universities

Purpose

The purpose of this guideline is to establish the process for low dollar payments to research participants through cash or gift card at the institutions governed by the Tennessee Board of Regents.

Policy/Guideline

  1. General
    1. Payments to research participants, regardless of delivery method (check, direct deposit, cash, traditional gift card or electronic gift cards) are considered compensation by the Internal Revenue Service. Research participants receiving more than $100 in any calendar year for one study must provide name, SSN and home address at the time of the receipt of payments.
      1. Personally identifiable information should be gathered in a manner which prevents disclosure of personal information to other research participants.
      2. Signatures must be obtained from research participants indicating receipt of the cash or traditional gift card payment.
    2. Payments of greater than $100 to research participants for participation in studies should be made through the institution's accounts payable system via check or direct deposit.  
    3. Some research studies use low dollar payments to compensate participants for time, inconvenience, or as an incentive to increase participation. When such payments are no more than $100 per payment per participant, and individual participant payments aggregate to less than $600 per study, it may be appropriate to make payments utilizing cash, traditional gift cards or electronic gift cards as long as the following procedures are followed.
  2. Prohibition from use of cash or gift cards in research studies
    1. No payment from cash or gift cards may be made to an institution employee or non-resident alien.
    2. Cash may not be used to purchase gift cards.
  3. Procedures for safeguarding and accounting for cash and gift cards in research studies
    1. Cash or gift cards for research studies must be assigned to a custodian, e.g. a member of the research study staff, responsible for safeguarding the cash or gift cards.
    2. Cash or gift cards for research studies must be maintained under lock and key by the custodian of the funds.
    3. Access to the cash or gift cards for research studies must be controlled by the custodian of the funds.
    4. The balance of cash gift cards on hand plus participant receipts must equal the cash and gift cards authorized and obtained. If a shortage of cash or gift cards on hand is determined, the shortage must be reported to the institution’s Bursar’s Office immediately.
    5. Cash or gift cards must be used for research participant payment only and may not be used for departmental or other research expenses.
    6. Cash and gift cards for research participants are subject to audit at any time by the institution, State Audit, or funding agency. 
    7. Cash and gift cards for research participants are required to be closed out at the end of the research study and any excess cash or cards must be returned to the Bursar’s Office.
  4. Distribution of cash or gift cards to research participants
    1. Cash or traditional gift cards must be hand delivered to research participants. These funds cannot be sent to participants through the mail. If participant payments must be mailed, cash or gift cards cannot be used and the payments need to be in the form or a check or direct deposit processed through the Institution’s Accounts Payable department.
    2. The method of tracking gift cards should record the following information:
      1. Recipient name or, in the case of anonymous or confidential human subject participants, the participant ID number;
      2. Date of distribution;
      3. Signature of PI authorizing disbursement to recipients;
      4. Purpose of payment;
      5. Serial number of the gift card;
      6. Amount of gift card;
      7. Signature or initials of study participant or recipient, if available.
    3. Alternate method of record keeping for anonymous and confidential surveys - for anonymous surveys and confidential research participants, the PI must maintain a reconciliation of the number of cards given equaling the number of surveys or participants.
      1. This reconciliation must be approved by the supervisor of the person disbursing the cards.
    4. Alternate method of record keeping for mailed and electronic gift cards - for electronic gift cards, the department must maintain a reconciliation of the number of cards given equaling the number of surveys or participants.
      1. This reconciliation must be approved by the supervisor of the person disbursing the cards.
    5. Payments aggregate to $600 or more per participant are required to be reported as income to the Internal Revenue Service.

Sources

NEW Guideline approved at Presidents Meeting, Feb. 4, 2014. Revised at Presidents Meeting, August 18, 2015.

Contact

Mickey Sheen
615-366-4437
mickey.sheen@tbr.edu