2319.1 Payment of Human Subject Fees

A human subject stipend is a payment that represents remuneration to individuals participating as subjects in a research project and is tax-reportable. Reimbursements can also be issued to human subjects for travel-related purposes (travel costs, parking, uber/lyft costs, meals, etc.), and they are not tax-reportable.

The University is obligated to report to the Internal Revenue Service (IRS) on Form 1099 all U.S. Citizens and Resident Aliens receiving cumulative remuneration in one calendar year of $600 or greater.

The University will report to the Internal Revenue Service (IRS) on Form 1042S all Non-Resident Aliens receiving remuneration and/or out-of-pocket reimbursement greater than $100 in any one calendar year.

NOTE:

IF YOU HAVE ANY REASON TO BELIEVE THAT YOU ARE MAKING A PAYMENT TO A FOREIGN PERSON AND DO NOT KNOW IF HE/ SHE IS CONSIDERED A RESIDENT ALIEN OR NONRESIDENT ALIEN, PLEASE CONTACT THE TAX OFFICE. OR PAY THE INDIVIDUAL IN THE PENN MARKETPLACE (PME) SO THE TAX OFFICE CAN EVALUATE.

Do not collect any paperwork from a Non-Resident Alien. When you enter them as a supplier/payee in the Penn Marketplace, the Tax Office will send them a link for the forms they need to fill out.

1. The Greenphire ClinCard (virtual or physical) is the University’s preferred method for paying human subjects. If the total payment to each human subject is over $100, you MUST process payment via a Greenphire ClinCard (U.S. Citizen or Resident Alien only) or through the Penn Marketplace using a Non-PO Payment Request.

2. U.S. Citizen or Resident Alien 

   A W-9 is required if the human subject is receiving payment for the first time and not collected in Penn’s W-9 repository or not listed as a “supplier” in the Penn Marketplace, or the subject has a name or address change.

   Gift cards, gift certificates, money order etc., over $100 per occurrence are not permitted as remuneration for participation in a research study. Payments over $100 must be paid via Greenphire ClinCard.

   Human subject payments of $100 or less per occurrence can be processed via a Greenphire ClinCard (virtual or card) or Cash Card, money orders, or gift cards.

   The Human Subject Voucher C-2 Form is not required  when paying human subjects. If your department wants to use it, and you are using the ClinCard, then we suggest using the C-2 form as a one-time requirement when distributing/paying via the Greenphire ClinCard. If you are paying a human subject in the Penn Marketplace, it is not required.

   For employees who participate as human subjects, human subject stipends are not considered additional wages. These payments will not be reflected on the employee’s W2. An employee who receives more than $600 in a calendar year will receive a 1099 form in addition to their W2.

3. Privacy of Medical and Protected Health Information (PHI)

   It is the responsibility of the PI to ensure that information collected for purposes of remuneration of a human subject does not include medical information, diagnostic information, medical/personal information, or other PHI protected by law and does not link the subject to the research study by title.

   No sensitive information should be included when issuing payments in the ClinCard system or when paid in the Penn Marketplace (PME). Just the name of the human subject, permanent/home address, social security number, and amount of remuneration. Date of birth (DOB) is also required in the ClinCard system. No further information is required for IRS purposes.

   It is the responsibility of the Principal Investigator (PI) to ensure a completed W-9  is collected from each U.S. Citizen or Resident Alien IF it is recognized that the human subject will receive a total of $600 or more in a calendar year,  either at the beginning of each research study/clinical trial or during the course of the research study.  Once the payments phase of the study is completed:

   • The PI must submit a summary worksheetof cash and/or gift card payments and the relevant W-9s for individuals receiving $600 or more to the Accounts Payable group via SecureShare at the completion of the study or at the end of the calendar year.
     • Human Subject Advances, gift cards, or cash payments must be reconciled with their Business Office.
   • Greenphire ClinCard coordinators can send their Greenphire W-9s via SecureShare to be stored in the Penn Greenphire W-9 repository. Please see Ben Helps Support Portal for details.
     • Coordinators can search the Penn Greenphire W-9 repository by a participant’s name and the last 4 of their SSN to see if a W-9 is already on file, and if it is, there is no need to collect another.
   • It is the responsibility of the PI to contact the Tax Office if it is recognized that the human subject who is a Non-Resident Alien will receive a total of more than $100, either at the beginning of the research study/clinical trial or at any time throughout.

   Note: This process does not apply if the IRB has approved a waiver of informed consent, and no identifiers of the human subject are collected.

   It is the responsibility of the PI to ensure that potentially sensitive data is protected. The following steps must be taken to help ensure privacy:

   • The W-9 forms (for non-BEN/non-Greenphire ClinCard disbursements accumulating $600 or more) should be kept in a secure location and at the end of the study or at the end of the calendar year sent to the Accounts Payable group, accompanied by the summary worksheet (http://www.finance.upenn.edu/comptroller/Forms/#Accounts_Payable).
   • Participants’ Social Security numbers should not be kept on a local desktop, laptop, or other computing device.

4. Additional Responsibilities

   The Accounts Payable Department is responsible for ensuring that human subject payment requests are authorized. In the event that the proper documentation is not complete, the approver should return the Non-PO Payment Request to its preparer. Each PI has the primary responsibility for:

   • Monitoring the process of compensating human subjects and ensuring that such activity is properly accounted for and reported to applicable departments.
   • Ensuring that all human subjects are informed during the consent process (verbal or written) of the human subject’s responsibility of reporting human subject remuneration to the IRS.
   • Documenting the number of human subjects and payments to those human subjects in studies where the human subject remains anonymous (where the IRB has approved a waiver of consent) or no identifiable information is collected.
   • Documenting the names of human subjects and payments to those human subjects in studies involving surveys when de minimis incentive payments ($25 or less) are used as enticement to complete the survey and the returned survey contains no identifiers and is considered anonymous.