Payments to Research Subjects
Research studies often involve human participants, known as subjects. Human research subjects may be remunerated for their study participation. Sometimes remuneration is merely reimbursement of expenses, such as mileage or parking. Other times it includes a reward. Although payments usually are monetary, both patient/subjects and normal healthy volunteers may be given other rewards, such as free medications. When reviewing a proposed study, the Institutional Review Board (IRB) considers whether the remuneration offered for participation is appropriate.
At UT Southwestern Medical Center, there are four IRBs that review research performed at University facilities, Parkland Health & Hospital System, Children's Medical Center, Texas Scottish Rite Hospital for Children, and other affiliated institutions. When the IRB approves a study, the approval may include authorization to provide payment to research subjects.
Payment of research subjects with money or goods should be done in such a way so as to achieve the following institutional goals:
- Reimburse subjects' expenses and/or reward the subjects' participation in the study
- Document that payment was for participation in the research study
- Record financial compensation in the accounting system for both financial and tax reporting purposes
- Ensure appropriate internal controls and safeguards for funds used to pay participants (whether cash, checks or other) and for protection of participants' Federal Tax Identification Number
Payments to research subjects may be in the form of checks (preferred), cash, gift cards, gift certificates, or reimbursement of expenses. Employees participating as research subjects will be paid through the payroll process to ensure correct Federal tax withholding. This involves completing a “Request for Payment to Research Study Participants” form found in IRB Forms and submiitting an email to Payroll-UTSW@utsouthwestern.edu. With the exception of documented transportation expense reimbursements (i.e., mileage, parking, taxis), payment to research subjects represents taxable income to the recipient, regardless of the payment amount or method used.
UT Southwestern is required to report to the Internal Revenue Service total payments of $600 or more made to non-employees in a calendar year. Since research subjects could be involved in multiple studies during the year that together may exceed the reporting threshold, it is necessary to collect the Federal Tax Identification Number (generally a Social Security number) of subjects prior to payment.
Informed Consent Documents, a.k.a. consent forms, should contain standard IRB-approved language regarding the need for provision by the research participant of a Federal Tax Identification Number prior to payment. Should the University fail to obtain the Federal Tax Identification Number from the research participant, or if the subject does not provide it, payments will be reduced by the required Federal Income Tax non-employee withholding rate, currently 28 percent (subject to change).
Reimbursed transportation expenses are not taxable, provided documentation is submitted to substantiate the expenses, as required under the University's travel expense rules. Generally, receipts or other documentation is required. Please consult with your Department Administrator for assistance with the processing of reimbursements.