Policy: 103-Payments to Human Subjects
Date: 10/07/03
Statement of Policy:
Under the Internal Revenue Code, payments to human subjects are considered payments for services and subject to reporting to the recipient on a form 1099 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.
Related Procedure(s):
103-Payments to Human Subjects
Who should know this policy?
Deans, Directors, and Staff dealing with payments to human subjects
Related Documents:
PIR Payment to Individual Report Form
Payment to Individual Report Tutorial
Cash Advance Accounting Form
UW-Madison Human Research Protection Program
Health Insurance Portability & Accountability Act
Contacts:
Sharon Hughes or e-mail uwtravel@bussvc.wisc.edu.