To ensure an effective and efficient means to make payments to human subjects in research studies and properly account and report these payments in accordance with generally accepted accounting principles and compliance with the Internal Revenue Code.
January, 2007
revisedJuly, 2020
April, 2024
Responsible OfficeProcurement Services
Procurement Services
A human subject fee is a payment that represents remuneration and/or reimbursement to individuals participating as subjects in a research project.
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 greater than the annual threshold amount of $600.
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 COLLECT THE FORMS BELOW FOR NON RESIDENT ALIEN AND SEND TO CORPORATE TAX, COMPLIANCE, & PAYROLL OFFICE FOR A DETERMINATION.
The Greenphire ClinCard (virtual or card) is the University’s preferred method of paying human subjects. Payments to human subjects of over $100 per occurrence MUST either be processed via a Greenphire ClinCard (U.S. Citizen or Resident Alien only) or through the Penn Marketplace using a Non-PO Payment Request.
Note:
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 Penn’s Accounts Payable system, or the subject has a name or address change.
Nonresident Alien
The following forms are required –
Note:
Gift cards, gift certificates, money order etc., over $100 per occurrence are not permitted as remuneration for participation in a research study.
Human subject payments of $100 and under per occurrence can be processed via a Greenphire ClinCard (virtual or card) or Cash Card, money orders, or gift cards.
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.
For employees who participate as a human subject:
Privacy of Medical and Protected Health Information (PHI), personal data, and social security numbers
Additional Responsibilities