Policy: 103-Payments to Human Subjects
Date: May 16, 2013
- Payment to Individual Report Form (PIR)
- Payment to Individual Report Instructions
- UW-Madison Human Research Protection Program
- Health Insurance Portability & Accountability Act (HIPAA)
- Step by Step Instructions for Obtaining IRB Approval for Human Subjects Research
Statement of Policy
The University often conducts research projects that involve the use of Human Subjects. Payments to Human Subjects may be paid in the form of checks, gift cars or cash depending on the circumstances and the dollar amounts paid.
Since the implementation of the Health Insurance Portability and Accountability Act (HIPAA) in 2003, UW-Madison staff members have been trained to handle protected health information in a confidential manner as required by HIPAA regulations. Subjects who sign the HIPAA authorization form prior to participating in the study are agreeing to the release of their personal information for payment processing purposes. As a result, the department need not mask the names and social security numbers when preparing the paperwork necessary for payment or reimbursement to the human subjects.
Taxation on Human Subject Payments:
Under the Internal Revenue Code, payments to human subjects must be reported to the individual on a 1099-MISC form annually. The information required for these payments include the human subject’s name, address and social security number. Accounting Services will report this information to the IRS, and a form 1099-MISC, Miscellaneous Income, will be sent to the payee at the end of the calendar year in which the payment is made.
Payment amounts of less than $100 are considered to be de miminus payments. Departments are encouraged, but not required, to obtain a Social Security Number from the subjects when de minimis payments are made.
Payments to a Nonresident Alien (NRA): All payments to NRA’s must be processed through a Payment to Individual Report (PIR) regardless of the dollar amount. Follow the Payment to Individual Report (PIR) procedures, attaching all required documentation as outlined in the Non-Payroll Payments Flowchart.
Note: The discretionary de minimis payments do not pertain to nonresident aliens. If payment is made to a nonresident alien for services performed outside of the United States, then taxation and immigration information is not required.
Employees and Nonemployees: UW employees are treated the same as non-UW employees when participating as a research subject. Research subject payments are not considered income or wages and therefore, payments to UW employees are not processed through payroll. All payments are to be processed as indicated in the Payment to Human Subjects Procedures.
For tax questions contact Jose Carus.