Effective Date: May 4, 2016
The University of Colorado pays individuals to participate in various types of studies. Some of these studies involve confidential health-related or human subject research , and those payments must be processed in accordance with federal law (the Health Insurance Portability and Accountability Act of 1996, or HIPAA, which requires protecting the privacy of personal health information) and with the rules and regulations established by the federal Office of Human Research (OHRP) for the conduct of studies involving human subjects.
This PSC Procedural Statement (PPS) sets forth university requirements for processing study subject payments. These requirements include, when relevant, procedures to protect the privacy rights of individuals while still providing sufficient information to the University for Internal Revenue Service reporting. This PPS must be considered in conjunction with any campus-specific policies on studies involving human subjects.
Terms Used in This Procedural Statement
Italicized terms are defined in the Policy Glossary. Underlined terms are defined in the Finance and Procurement Procedure Glossary.
Study subject payments are accomplished in one of the following ways:
A. Study Subject Payment Form
Study subjects can be paid using the Study Subject Payment form, which is available on the PSC Forms web site. All payments processed on the Study Subject Payment form are treated as if they are for confidential studies. This means that access to study subject personal information in the Finance System and in the Central Information Warehouse (CIW) is limited. The payee name will appear in the Finance System and on reports simply as “Study Subjects.” The individual’s actual name will not appear in Finance Inquiry or on financial reports.
If the department has not previously paid an individual for a study, then the department must attach a completed paper W-9 (IRS form) for that individual to the Study Subject Payment form. (Note: If paying a University of Colorado employee/student, a W-9 form is not needed as long as the Employee/Student ID # is provided on the Study Subject Payment form.)
The department must maintain documentation–including study subject name (or code/number,for confidential studies)–to support the disbursement.
B. Petty Cash Fund
Study subjects can be paid using a petty cash fund, established by the department to accommodate these payments. For all payments processed this way, only the reimbursement/replenishment of the petty cash fund appears in the Finance System, and not the names of the individual study subjects.
The department must maintain documentation–including study subject name (or code/number, for confidential studies)–to support the petty cash fund disbursement. Additional information on the establishment and replenishment of petty cash funds is available in the PSC Procedural Statement Petty Cash and Change Funds.
C. Gift Cards
Study subjects can be paid using cash-like methods such as gift cards. The preferred method of procurement for gift cards is the Procurement Card.
The department must maintain documentation–including study subject name (or code/number, for confidential studies)–to support the disbursement. Additional information is available in the Procurement Card Handbook.
D. Cash Advance
Subject study payments that are associated exclusively with a specific trip can be considered part of the expenses for that trip and therefore can be accomplished through issuance of a cash advance, requested through the Concur Travel & Expense System.
Documentation submitted by the traveler upon conclusion of the trip will include identification of study subjects by name (or code/number, for confidential studies). Procedures for requesting cash advances to support expenses associated with official university travel are outlined in the PSC Procedural Statement Cash Advances.
Study subjects can be paid through the use of an online coordinator, such as Amazon’s Mechanical Turk. Such services coordinate entities that want to advertise tasks – e.g. surveys – with people who can sign up to perform the tasks and receive a payment. A CU Procurement Card is used to pay the participants and the coordinator’s fees.
If this method is used, the coordinator must be able to provide a report that shows who was paid and how much they were paid as support for the transaction. The coordinator must be also be able to ensure that only US residents are being paid to perform the advertised tasks.
Payments to individuals through such online coordinators may not exceed $100.
Special Note on Travel Reimbursements to Study Subjects
Travel and/or per diem-related patient reimbursements should be reasonable given the nature of the expense(s) requested for reimbursement. It is recommended that travel reimbursement policies applicable to employees of the University be applied to study subjects. Thus, for example, reimbursement for alcohol would not be appropriate, and reimbursement for airfare would be expected to be at economy or coach fare rather than first class. Departments should exercise particular attention with reimbursements when federal funds are used for study subject payments. Reimbursement policies should be made known in advance to potential study subjects.
Unless approved by the Associate Vice President/Chief Procurement Officer, there are no exceptions to this procedural statement.
For additional campus-specific policies and procedures, contact the appropriate campus controller office.