2319 Payment to Individuals for Human Subject Fees, Honoraria, Limited Engagements and Independent Contractor Services

Document purpose

To describe the proper handling of payments to, and procurement from, non-affiliates* performing services in support of the University's operations and to establish responsibility for the approval of these payments.

effective

January 1989

revised

March 31, 2025

Reviewed

March 31, 2025

Responsible Office

Procurement Services

Approval

Procurement Services

Definitions

Hiring Manager 

The individual responsible for the hiring of a temporary employee or for procuring services of an independent contractor.

School or Center Representative

For the purposes of this policy, the school or center representative is the individual responsible for procuring services of a service provider. The school or center representative must be either a Business Administrator or Human Resources representative within the school or center.

 

Human Subject Fee* 

A Human Subject Fee is a payment that represents remuneration and/or reimbursement to individuals participating as subjects in a research project

 *The Human Subject Fee is the only category within this policy in which employees may be paid.

Honoraria 

An honorarium is a gratuitous payment of money or anything of value to a person for their  participation in a usual academic activity for which no fee is legally required. Honorarium payments are provided as a token of appreciation for participation in an activity or event, and not as a contractual obligation to pay for services rendered.

Payments of honoraria to University staff, faculty, or students are prohibited.

Independent Contractor 

An independent contractor is a worker who provides services to the University and the University does not have the right to control the details of how the worker’s services are performed. An independent contractor is a non-employee, as determined by the University according to applicable laws and the procedures set forth below.

Limited Engagement 

A Limited Engagement is a subset of Independent Contractors meeting the following two criteria:

  1. The individual is a guest speaker, guest lecturer, artist, performer, writer/editor, board member, critic, preceptor, or mentor of an academic nature.  The individual is not University faculty, staff or student.
  2. A service payment to the individual has a maximum dollar amount of $5,000 per transaction; $5,000 per calendar-year.  This is not to pay individuals on an hourly basis.

 

Penn LE Service Types  Definition/Examples 
Guest Speaker  Expert, professional, or influential individual who charges a fee to deliver a talk or presentation at an event
Guest Lecturer  An academic or professional expert who charges a fee to deliver a lecture, a limited series of lectures, visiting professors guest lecturing at a course on a limited basis
Artist  Artist doing an art exhibit, stage set and light designer, costume designer, choreographer
Performer  DJ, singer, comedian, dancer, musician / instrumentalist, actor, magician/clowns, juggler/circus performer, performance painter (i.e. sand painter)
Writer/Editor  Writer/editor for grants, articles, manuscript reviewer / editor
Board Member  Payment to advisory/directory board members for duties
Critic Someone paid to critique/write a review of a piece of work (literary, artistic, etc.) or paid to judge a competition
Preceptor  An experienced professional who mentors, supervises, and trains students or trainees in a practical, hands-on learning environment
Mentor of an Academic Nature   An experienced faculty member, researcher, or professional who provides guidance, support, and advice to students, scholars, or junior faculty in their academic and professional development

Policy

  1. It is the responsibility of the person initiating the payment request to follow the guidance of the policies listed below for each category of payment being made to an individual.

  2. The payment of Human Subject Fees to employees and non-employees must be made pursuant to Policy #2319.1 – Payment of Human Subject Fees.

  3. The payment of Honoraria to non-employees must be made pursuant to Policy #2319.2 – Payments Made for Honoraria.

  4. Payments to non-employees for Limited Engagements must be made pursuant to Policy #2319.3 – Payments Made for Limited Engagements. 

  5. Payments to Independent Contractors must be made pursuant to Policy #2319.4- Procurement – Procurement, Payment, and Reporting of Independent Contractors.