Payments To Human Subjects
(Last updated 11/23/2009)
If Custodian Funds ares obtained, the Custodian (principal investigator) can make payments directly by cash or check to human subjects and is personally responsible for the amount of the custodian funds. A log must be kept of all disbursements, including name, address, social security number, signature of recipient, amount paid to each individual, and date of payment. The original log should be attached to the Custodian Fund Accounting Form when accounting for the custodian funds. Any portion of the custodian funds not accounted for must be returned to Cash Management in the form of a check payable to "University of Wisconsin-Madison" along with the accounting for the portion of the custodian funds used.
All payments $250 and over to an individual must be submitted to Accounting Services on a Payment to Individual Report (PIR). This is to insure that a UW-Madison check is issued directly to the individual. Employees should not pay these costs from personal funds and seek reimbursement.
Taxation and identification of Payments to Human Subjects
Just as medical information must be furnished to insurance companies for claims processing, information on participants in research studies must be obtained for tax reporting.
Under Internal Revenue Service regulations, we must collect the name, mailing address, date of payment, signature, amount, and social security number of individuals who receive these payments. The only exception to this policy is a de minimis payment described below. Dean/Director’s or their designees are responsible for monitoring the dollar amounts and frequency of human subject payments to ensure tax compliance. If an exception exists, these should be noted on the custodian fund request.
De Minimis Payment
For de minimis research subject payments, which are considered to be less than $100 per transaction and less than $250 in total for an individual subject, you are not required to obtain a social security number from the subject, however the Custodian Fund Accounting Form does require the name, signature, mailing address, and date of payment.