Human subjects are people who participate in research studies. Specific guidelines dictate how human subjects can be compensated.
Control of Funds
Study administrators assume fiduciary responsibility to ensure proper accounting for funds spent on studies conducted at Stanford. Adequate controls must be in place for the distribution of the funds, and costs must be allocated to the correct charge account (Project-Task-Award).
Protecting Participants’ Privacy
Human subjects are protected under California state laws and federal Health Insurance Portability and Accountability Act (HIPAA) regulations. As a result of these requirements, study administrators must follow certain business processes to protect the privacy of the participants.
Only the following authorized individuals can view Human Subject Expense Request transactions:
- The preparer
- Transaction approvers
- Individuals with authority over accounts charged
- Authorized staff in central administrative units
Note: The subject's name must not appear within the first 30 characters of the business purpose of the Expense Request Non-PO Payment transaction, because those characters will also appear in expenditure reports for the designated project, task and award. Therefore, use a generic statement of business purpose, such as “Human Subject Payment.” For more examples, refer to Resource: Guidelines for Writing a Clear Business Purpose.
Many studies are sensitive in nature, and information concerning human subjects is confidential. Therefore, do not include the name of the study in the transaction. Instead, refer to the protocol number of the study or another number that identifies the study.
Tax Treatment for Incentives
All payments and gifts to human subjects are considered income, which may be subject to tax treatment. For tax treatments related to specific scenarios, refer to the table in the Payment Methods by Incentive and Payee Type section below.
Note: For required tax reporting, the payee or an authorized agent must submit all confidential data, including Social Security Number or other tax identification and residency information, via the secure Supplier/Payee Request Portal. Do not upload confidential information as backup documentation with Expense Request transactions.
Payment Methods by Incentive and Payee Type
Payments to human subjects or administrators to fund payments or purchase gifts are initiated within the Expense Requests system. As an alternative, a Stanford Purchasing Card may be used to purchase gift incentives valued under $200. See the following table for various scenarios.
Note: When direct payments to human subjects are requested, the payee or an authorized agent must submit all confidential data, including Social Security Number or other tax identification, residency information, and banking information, directly via the secure Supplier/Payee Request Portal. Do not upload confidential information as backup documentation to Expense Requests system transactions.
|Payee Type: Incentive||Payment Method||Required Documentation||Tax Treatment|
|Stanford and SLAC employees participating in a study for their department or related to their employment: monetary, any amount||Stanford payroll||Contact the department HR manager||As income|
|Non-resident alien: monetary, any amount||
Direct Non-PO Payment requested by an administrator in Expense Requests, paid directly to the human subject
|Payee or authorized agent provides banking, residency and tax information via the secure Supplier/Payee Request Portal||30% Federal withholding at the time of payment (refer to these examples)|
|Legal U.S. residents (except SU and SLAC employees participating for their work or department): monetary, ≥$200||Direct Non-PO Payment requested by an administrator in Expense Requests, paid directly to the human subject
Advance requested by and paid to an administrator for cash disbursement to human subjects, followed by the Expense Report to clear the advance. Total advances requested by one person may not exceed the maximum advance amount.
Payee or authorized agent provides banking, residency and tax information via the secure Supplier/Payee Request Portal
If payment is by Advance, the administrator must submit a Request Cash Advance for Human Subject Incentives Form.
Reported by Stanford via 1099 for every U.S. resident who is paid ≥$600 in a calendar year
Administrators should indicate in the expense report when an individual payee receives multiple incentives totaling ≥$600 in a calendar year, and Stanford will prepare a 1099
|Any human subjects: gifts* valued <$200||Advance requested by and paid to an administrator to purchase gifts, followed by an Expense Report to clear the advance. Total advances requested by one person may not exceed the maximum advance amount.||
Administrators complete and retain a Human Subject Incentive Certification Form as well as a record of:
The administrator must submit a Request Cash Advance for Human Subject Incentives Form.
|No tax reported|
|Expense report for reimbursement of gift purchase||Upload receipt for gift purchase with Expense Requests transaction|
|Stanford Purchasing Card||Fax receipt when verifying PCard purchase in PCard Module|
* Non-cash gifts are especially useful for individuals who may not have Social Security Numbers, for non-resident aliens or for studies where a small incentive is appropriate. Non-resident aliens and Stanford or SLAC employees may receive non-cash gifts. Gifts valued at $200 or more are subject to tax reporting and are highly discouraged.
Some human subject incentive payee types can be paid with an advance. In order to reduce risk and promote responsible stewardship of Stanford’s resources, there is a maximum limit on the total of uncleared advances that an individual may have pending at any given time. The total amount of advances requested by and paid to an administrator to pay human subjects may not exceed $7,000. To request another advance, the administrator must clear earlier advances so that the balance does not exceed $7,000.
The following table provides links to specific instructions on initiating the various payment methods in the Expense Requests system.
|Payment Method||Refer to|
|Direct monetary payment to human subjects||How to: Create New Non-PO Payment Request – Single Payee|
|Direct monetary payment for up to
50 human subjects in one transaction
|How to: Create New Non-PO Payment Request – Multiple Payees|
Request cash advance for human subject incentives, or to purchase non-cash incentives for distribution to human subjects
|How-to: Request and Clear an Advance|
Request reimbursement and/or clear an advance for domestic human subject incentives
|How to: Create Domestic Expense Report for an SU Payee|
Request reimbursement and/or clear an advance for foreign (non-U.S.) human subject incentives
|Request reimbursement for domestic (U.S.) travel expenses for human subjects||How to: Create Domestic Expense Report for a Non-SU Payee (Visitor Reimbursement)|
|Request reimbursement for foreign travel expenses for human subjects||How to: Create Foreign Expense Report for a Non-SU Payee (Visitor Reimbursement)|