New IRB Guidance on Compensation for Human Subjects
ORCS and the Office of Finance are currently developing a dedicated policy on how to pay human subject participants in IRB-approved research at Emerson College. In the interim, we have added new guidance on this topic to the Institutional Review Board’s home page, entitled Compensation for Human Subjects. The contents of this section is reproduced below.
As always, please feel free to contact ORCS should you have any questions.
Compensation for Human Subjects
A research protocol may offer compensation to human subjects for their participation. Researchers who are conducting sponsor funded research or internally funded research are responsible for ensuring that subjects are eligible to receive payments (in accordance with US Tax and Immigration laws) and for ensuring that the payment process is appropriate. The following section outlines how human subjects can be compensated.
Compensation and Consent Considerations
Payments or non-monetary rewards may be given to subjects as remuneration for time and inconvenience of participation in research studies, as well as an incentive to participate. Compensation can include monetary (gift cards, vouchers, etc.) and/or non-monetary (gifts/promotional items, etc.) remuneration.
There are two ways in which compensation can be problematic:
- Undue influence: An offer of excessive or inappropriate compensation is made in order to obtain compliance.
- Coercion: An overt or implicit threat of harm/negative consequences is intentionally presented by one person to another in order to obtain compliance.
Protocol and Consent Considerations: The protocol application should fully describe the plan for compensation of subjects as well as the reasoning behind the amount, method of payment, proration and scheduling of payment, and any other terms of compensation — for example, what happens if a subject withdraws his or her participation. All of this information should be included in the informed consent process. It is also appropriate to disclose possible compensation in recruiting and advertising materials.
Amount of Payments
Compensation should be appropriate for the time and effort subjects devote to participation. The level of payment should not be high enough to cause subjects to accept risks that they would not otherwise accept or participate in activities to which they would otherwise strongly object based on personal values or beliefs.
Some researchers may base the payment amount on the acceptable average wage in the location where the research is conducted or for the specific study population. This is often an acceptable level of payment that does not exert undue influence. When hourly payments are not suitable or feasible, compensation may be task- or procedure-specific (for example, some studies pay subjects per sample collection or survey).
Methods of Compensation
Emerson College facilities the payment of human subjects by researchers through the following methods (in order of institutional preference):
- Payments to Participants via Online Survey Platforms. For protocols that solicit participant responses via a College-approved online survey platform –such as Qualtrics– a researcher may elect to have the platform pay Human Subjects directly for their participation. For more information on using Qualtrics through Emerson’s site license, click here.
- Tangible Items/Gifts are non-cash items given to human subjects in recognition of their participation in a protocol. Examples include Examples include: books, trophies, plaques, event tickets, food, Emerson logo items, memento items, pens, pennants, or similar items. Gift items may be purchased via the Workday Marketplace, or submitted for reimbursement via an Expense Report (subject to the College’s purchasing and reimbursement policies).
- Gift Cards are “cash equivalents” that can be used to purchase merchandise or which can be easily converted to cash.
Gift card payments are reportable as miscellaneous income to the IRS. It is strongly recommended that a researcher contact the Office of Research and Creative Scholarship for assistance with acquiring gift cards for human subject payments. Gift cards being held in reserve may be stored securely in a fireproof safe by the Office of Finance, upon request.
Prohibition on the Use of Personal Funds. Under no circumstances should researchers use their personal funds to compensate human subjects. These cannot be reimbursed under Emerson’s accounting rules.
Tracking Human Subject Payments
Researchers on an IRB-approved protocol must maintain a payment log for all payments made to human subject participants. Researchers must record the following information for each Payment to an individual:
- Full legal name
- Active phone number or email
- Date, amount, and method of payment
For protocols that pledge confidentiality to participants, the researcher should use a coded identifier in place of an individual’s name, using the same identifier consistently for each participant. However, the researcher must also record sufficient information so that an individual can be contacted by Emerson for IRS-required information when the $600 threshold is reached.
Tax-Reporting Requirements and IRS Obligations of the College
The IRS treats monetary human subject payments (gift cards or gift certificates) as taxable income to the recipient. This means the recipient is supposed to report the payment when they file a personal tax return at the end of the year.
As the payer, Emerson must adhere to IRS regulations. The tax treatment of human subject payments depends on the amount paid, the recipient’s tax status, and whether the study takes place inside or outside the U.S.
If Emerson issues $600 or more in Human Subject Payments to an individual in a calendar year, the College is required to report the payments to the IRS and issue the recipient a Form 1099.
Pursuant to the above, Emerson must collect a completed and signed Form W 9 from an individual when they receive $600 or more in Human Subjects Payments in a calendar year. Participants should be notified of this requirement in the Informed Consent Form.
Payments to human subjects facilitated by a third-party data-collection platform, such as Qualtrics, are typically exempt from the above rule, but must still be logged by the researchers.
Further Guidance on Paying Human Subjects
For further information, policies and procedures on compensating human subjects, please contact the Executive Director for the Office of Research and Creative Scholarship. A dedicated policy to this topic, Payment of Human Subjects Participants in Research, is forthcoming from the College.