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

Hiring Manager
The individual responsible for hiring a temporary employee or procuring the 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 from a service provider. This representative must be either a Business Administrator or Human Resources representative within the respective 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.

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.
Honoraria are tokens of appreciation, not contractual payments for services rendered.
Honoraria may not be paid to University staff, faculty, or students.

Independent Contractor
An independent contractor is an individual providing services to the University, over whom the University does not control the means and methods of service delivery. Classification as an independent contractor is made by the University in accordance with applicable laws and internal procedures.

It is the responsibility of the individual initiating the payment request to follow applicable University policies based on the nature of the service and payee classification:

• Human Subject Fees: Must comply with Policy #2319.1 – Payment of Human Subject Fees.
• Honoraria: Must comply with Policy #2319.2 – Payments Made for Honoraria.
• Limited Engagements: Must comply with Policy #2319.3 – Payments Made for Limited Engagements.
• Independent Contractors: Must comply with Policy #2319.4 – Procurement, Payment, and Reporting of Independent Contractors.

Procurement Services serves as the final authority on the classification of individual service providers and the determination of payment eligibility. Classification decisions and exceptions are made using a risk-based approach that balances the operational needs of the University with applicable legal requirements, institutional policies, and risk mitigation standards.

To ensure informed and responsible decision-making, Procurement Services may consult with:

• The Tax Office
• The Office of General Counsel
• Global Support Services
• Human Resources

All exceptions to classification criteria must be reviewed and approved by Procurement Services prior to payment.