Study Subject Payment Methods

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. The study subject payment form may be used to process payment to employees and non-employees, including nonresident aliens (See references), for any amount. 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 (study subject) 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.

Study subject payments to nonresident aliens, in any amount, can only be made by physical check which requires a completed Study Subject Payment form for each payment, in addition to a completed W-8 BEN tax form. THIS IS THE ONLY METHOD OF PAYMENT ALLOWED TO NONRESIDENT ALIENS.  

Pease contact an international tax specialist at intltax@cu.edu in advance of the study to resolve any questions or concerns you may have related to payments to nonresident aliens.

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.  

The rules and requirements for establishing and maintaining a petty cash fund are available in the Finance Procedural Statement: Petty Cash and Change Funds. To establish a petty cash fund at UCCS the following is required:

• Organization must identify a petty cash custodian. The custodian is fiscally responsible for safeguarding the petty cash fund.
• Custodian Skillsoft training must be taken and passed by the custodian prior to approval of a petty cash fund.
• Organization must submit the Petty Cash/Change Fund Request form to acctfund@uccs.edu for review and approval.

Study Subject payments made to employees, in any amount, are generally tax reportable on Employees’ W-2 and are required to be reported to Employee Services at payroll@cu.edu.

Study subject payments made to non-employees greater than $100, per payment or in aggregate, require a W-9 and are reportable to the Procurement Services Center at psc@cu.edu.

Study subject payments to nonresident aliens (See references) are not allowed via a petty cash fund.

Contact acctfund@uccs.edu with questions and concerns related to establishing a petty cash fund at UCCS.  

C. Gift Cards

Study subjects can be paid using cash-like methods such as gift cards, both tangible gift cards and intangible digital gift cards. Study subject payments made using gift cards cannot exceed $100 per payment to an induvial study subject. The preferred method of procurement for gift cards is the Procurement Card. Additional information related to procurement cards is available in the Procurement Card Handbook.  

The department must maintain documentation–including study subject name (or code/number, for confidential studies)–to support the disbursement.

The rules and requirements for gift card use is available in Finance Procedural Statement: Gift Cards. To establish a gift card program at UCCS the following is required:

• Custodian Skillsoft training must be taken and passed by the custodian prior to approval of a gift card program.
• Organization must complete the Gift Card Authorization Form
• Organization must attach written procedures for the safeguarding of gift cards addressing the following per the Finance Procedural Statement: Gift Cards:
  • Custody
  • Security
  • Receipts (Issuance)
  • Audit Log
• Submit form and procedures to acctfund@uccs.edu for review and approval.

Study Subject payments greater than $100 per payment to an individual study subject (employee or non-employee) are not allowed via gift cards.  

Study Subject payments made to employees, in any amount, are generally tax reportable on Employees’ W-2 and are required to be reported to Employee Services at payroll@cu.edu.  

Study subject payments made to non-employees greater than $100, in aggregate, require a W-9 and are reportable to the Procurement Services Center at psc@cu.edu.

Study subject payments to nonresident aliens (See references) are not allowed via gift cards.

Contact acctfund@uccs.edu with questions and concerns related to establishing a gift card program at UCCS. See the UCCS Controller’s Office website for more information on  gift cards.

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 Subject payments made to employees, in any amount, are generally tax reportable on Employees’ W-2 and are required to be reported to Employee Services at payroll@cu.edu.  

Study subject payments made to non-employees greater than $100, per payment or in aggregate, require a W-9 and are reportable to the Procurement Services Center at psc@cu.edu.

Study subject payments to nonresident aliens (See references) are not allowed via Cash Advance without review and approval by the Employee Services’ International Tax team prior to the cash advance request. Contact an international tax specialist at intltax@cu.edu in advance of the study to resolve any questions or concerns you may have related to payments to nonresident aliens.

E. Online Coordinators

Study subjects can be paid for through the use/services 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. Additional information related to procurement cards is available in the Procurement Card Handbook.

If this method is used, the online coordinator must be able to provide a report showing who was paid and the amount they were paid as support for the transaction.  In addition, the reports must be available upon request in the event of an audit or review. The coordinator must be able to ensure that nonresident aliens are not being paid to perform the advertised tasks.  

To use an online coordinator for study subject payments at UCCS the following is required:

• Complete the Online Coordinator Form or
• Submit the following information to the Controller’s Office:
  • Name of online coordinator.
  • Funding source (Speedtype)
  • Program start and end dates.
  • Total cost to use online coordinator.
  • Amount of service charge or fee, if applicable.
  • Amount received by each study subject calendar year.
  • Amount of each study subject payment.
  • The purpose of the study subject payment.
  • An attestation that the following is true of the program:
    • No payments will be made to non-resident aliens (See refences),
    • No individual will receive greater than $100 in a calendar year, and
    • Supporting reports will be made available.
• Submit the form or information to acctfund@uccs.edu for review and approval.

Study Subject payments greater than $100 per payment or in aggregate to an individual study subject are not allowed via online coordinators. In addition, payment to nonresident aliens (See references) is not allowed via online coordinators.

Study Subject payments made to employees, in any amount, are generally tax reportable on Employees’ W-2 and are required to be reported to Employee Services at payroll@cu.edu.  

Contact the Controller’s Office acctfund@uccs.edu with questions and concerns related to using an online coordinator at UCCS.

Special Note on Travel Reimbursements to Study Subjects, Human Research Participant Costs

Human Research Participant costs such as travel and/or per diem-related 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 expenses and payments. Reimbursement policies should be made known in advance for potential human research participant costs.

Participant Support Cost vs Human Research Participant

The following are important terms and definitions that require consideration when discussing costs associated with participants and human research participants (aka, human subjects and study subjects).

Participant Support Costs:  

• Include direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects (2 CFR 200.1). This does not include NIH Kirschstein-NRSA programs.
• A participant is the recipient of a service or training opportunity as part of a workshop, conference, seminar, or other short-term instructional or information sharing activity funded by a sponsored award.  
• Participants may be, but are not limited to, students, scholars, scientists from other institutions, or teachers.
• Participant support costs do not include expenses incurred to incentivize or enable human research participants (study subjects) to participate in studies, such as gift cards, stipends, dependent care costs, parking fees and transportation.
• Participant support costs are not considered compensation.  As a result, the $100 reporting limit does not apply.

Human Research Participant (Human or Study Subject):

• A living individual from whom an investigator (whether professional or student) conducting research obtains data through the following methods:
  • An intervention, interacting with the individual and using, studying, or analyzing the information or biospecimens, or
  • Obtaining, using, studying, analyzing, or generating identifiable private information or identifiable biospecimens (adapted from 45 CFR 46.102).

References:

Nonresident alien (NRA): Any individual who is not a citizen or resident alien of the United States is a nonresident alien individual. An alien individual meeting either the "green card test" or the "substantial presence test" for the calendar year is a resident alien. Any person not meeting either test is a nonresident alien individual.

(2024, April 14). Instructions for Form W-8Ben (10/2021). https://www.irs.gov/instructions/iw8ben#en_US_202109_publink1000311804

See Publication 519, US Tax Guide for Aliens, for more information.

Resources:

PSC Procedural Statement: Study Subject Payments  

Study Subject Payment form

Finance Procedural Statement: Petty Cash and Change Funds

Finance Procedural Statement: Gift Cards

PSC Procedural Statement: Cash Advances

Procurement Card Handbook

OSPRI: Research Involving Human Subjects IRB

OSPRI: Guidance for Human Subjects Compensation

Employee Services: Imputed Income 

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