Policy: 103-Payments to Human Subjects

Policy: 103-Payments to Human Subjects
Date: 10/07/03 (Last updated: May 14, 2009 )

Statement of Policy:

Under the Internal Revenue Code, payments to human subjects are subject to reporting to the recipient on a form 1099-MISC annually, if the total of all payments for services, received by the same individual, in a calendar year exceeds $600.

Since the implementation of the Health Insurance Portability and Accountability Act (HIPAA) on April 14, 2003, UW-Madison staff who are in a position to see this kind of information have been trained to handle protected health information in a confidential manner as required under HIPAA. In addition, subjects who sign the HIPAA authorization for the study are agreeing that their health information can be used for processing payments. As a result, the need to mask names and social security numbers is no longer required when preparing necessary paperwork for reimbursement or payment of human subjects.

Names, social security numbers, mailing addresses, and dates of payment must be obtained from each human subject who receives payment for their services. However, Departments have the discretion to determine, with respect to non-recurring payments to human subjects up to $99, that the particular circumstances of the research study are such that it would be unreasonably burdensome to collect the social security number in light of the very low potential for the total payments to the recipient to exceed $600 in a calendar year.

Research subject payments can be processed through Accounting Services for both employees and non-employees. UW employees can be treated the same as non employees when participating as a research subject. Research subject payments are not considered income or wages and therefore UW employees will not need to be payrolled for their services. All other policy and procedural guidelines regarding research subject payments remain the same. Please refer to the e-mail that was sent to DBR’s on 11/14/08.

Payments to a Nonresident Alien (NRA): All payments to NRA’s must be processed through a Payment to Individual Report (PIR) and must include documentation as outlined in http://www.bussvc.wisc.edu/howto/acct/requiredtx.html. All other policy and procedural guidelines regarding research subject payments remain the same except for the de minimus amount section of Policy: 103-Payments to Human Subjects (http://www.bussvc.wisc.edu/acct/policy/human_subjects/humanpol.html). The de minimus amount section does not apply to payments to NRA’s because of the documentation required by the IRS for all payments to NRA’s, as noted above.