8.4 Payments to Human Subjects

Policy Statement

The University of Illinois System often conducts research projects that involve the use of human subjects. When human subjects are offered financial incentives to participate in research, they are paid in the form of cash/cash equivalents to participate. All human subject payments must be made in compliance with an approved IRB Protocol.

Human subject payments may be paid in the form of cash, cash equivalent (such as gift cards/certificates/electronic-codes), or check depending on the circumstances of the study and the dollar amounts involved. If a good or service is provided in exchange for or as a requirement to participate in a research study, the taxability of the good or service will depend on IRS tax reporting requirements.

Personal funds cannot be used for payments to human subjects. The risks of allowing use of personal funds include non-compliance with tax reporting rules, and payments before official approval of Institutional Review Board (IRB) protocols.

All human subject payments must be processed using account code 141200 unless the payment is to a nonresident alien. Human subject payments to a nonresident aliens (as defined in 18.2 Foreign Nationals) must be processed using account code 215985.

The Internal Revenue Service (IRS) requires tax reporting for human subject payments.

Reason for the Policy

Federal tax and immigration laws require compliance with the rules and regulations pertaining to processing compensation for participants in human subject studies. Failure to comply with these procedures may result in a violation of Federal Law.

Applicability of the Policy

This policy is applicable when providing payments to human subjects for participation in research, regardless of the funding source.

Procedure

Refer to 8.3 Cash Advances for guidance that is universally applicable to all types of cash advances.

Refer to 8.4.1 Cash Advances for Human Subject Payments for guidance that is unique to human subject payments.

Refer to 18.10 Human Subjects Payments for IRS Reporting Requirements.

Last Updated: February 14, 2022 | Approved: Senior Associate Vice President for Business and Finance | Effective: September 2012