How Do I... Pay Confidential Research Participants?

Administration and Finance

This Steinhardt guideline covers confidential direct payments to confidential and to anonymous research study participants to enable human subject research.

Background

These guidelines are addressed to you

...If you are a research investigator, project administrator, or have been designated to process payments to participants for someone doing research involving human subjects.

...And takes as a basis, that in working with human subjects, confidentiality is presumed and must be maintained unless the investigator obtains the express permission of the subject to do otherwise. Risks from breach of confidentiality include invasion of privacy, as well as the social, economic and legal risks.

...Recognizing at the same time that the common principles of fiscal accountability required by the University and the many types of audits to which it is subject need to be balanced with the issue of confidentiality for human subjects.

...And presumes you are working with human subjects within the New York City metropolitan area.

When research covered by this policy takes place in a foreign country, procedures normally followed in that country to protect human subjects may differ from those set forth in this policy, as may NYU's fiscal procedures.

When research is conducted domestically, but outside the New York City metropolitan area, a cash advance may be used in place of a research petty cash fund. However, the method outlined below for keeping a participant log to maintain confidentiality, should be followed.

Fiscal Responsibilities

The research investigator along with a project administrator or appointed designee is responsible for:
• Safeguarding the research participant cash/gifts prior to distribution
• Issuing individual payments to study participants
• Maintaining appropriate documentation for each participant payment made
• Reconciling advanced or replenished funds within 60 days unless otherwise mandated

Procedures

The research investigator or project administrator directly or via a designee may provide a payment to a human subject via cash, money order, pre-paid cash card, merchandise card, MetroCard^TM or goods (e.g., an NYU hat).

The security of undisbursed cash or cash-equivalents is of utmost concern. Keep funds in a safe bolted within a cabinet or closet, in an office securely locked at night. For your own protection, upon removing anything from the safe, even if in preparation for distribution, promptly note in a log.

A Research Participant Payment Log simultaneously links and yet separates the seemingly contradictory needs of research subject confidentiality and fiscal accountability. It should be kept for any payment made to a human subject. (See the Research Participant Payment Log section.)
Payments totaling $600 or more to an individual in a calendar year must be reported by the University to the IRS on Form 1099-Misc. To do so the human subject's name, address, and social security number are collected via a W-9. This may jeopardize anonymity of the participant. If you become aware that payments to an individual will exceed the annual $600 limit, notify Administration and Finance.

Cash Payments

To access the cash to make payments to participants, the PI directly or through a designated project administrator establishes a Research Petty Cash Fund to be used solely for research participant payments. Use How do I ... Establish and Use a Petty Cash Fund? to guide you in working with a petty cash fund.

When planning how much cash to keep on hand at a given moment, for security reasons just hold two weeks worth of disbursements.
When replenishing and accounting for the Research Petty Cash Fund, having the Participant Payment Log enables you to omit recipient details and simply add a statement to the effect, "...for participants with code #s ...... to ...... Confidential participant details are on file in department."

Non-cash and Cash-equivalent Payments

Non-cash and cash-equivalent items are not purchased via a petty cash fund. They are purchased using normal New York University procurement processes or from an NYU store via an internal charge. Negotiable items, such as money orders, pre-paid cash cards, merchandise gift cards or MetroCards^TM require very strict accountability. They must be handled like cash.

MetroCards^TM can be ordered in bulk through Ticket Central. Allow approximately five business days for order fulfillment.
Pre-loaded debit cards in denominations of $25 - $500 may be obtained through NYU’s Accounts Payable. See How Do I… Obtain and Use Debit Cards for Payments to Human Subjects?
If pre-paying for items via an NYU payment directly to a vendor, remember to plan ahead.

Inquire in advance, whether the vendor will accept a check and how it should be made out.

Allow three weeks for the check to be generated.

When accounting for the purchase of items for non-cash or cash-equivalent payments, the Participant Payment Log enables you to omit recipient details and simply add a statement to the effect, "...for participants with code #s ...... to ...... confidential participant details are on file in department."

Research Participant Payment Log

Each payment to a human subject -- whether a cash, cash-equivalent or non-cash disbursement -- is entered into a Research Participant Payment Log. This sets up the blind that both maintains research participant confidentiality and enables fiscal accountability.

Upon making the payment, it is entered into a Research Participant Payment Log. The log will contain:

Study name

Payment date

Subject's name

ID code assigned by the PI to the research subject - the key element in the blind. The ID code is what will be recorded later in the Petty Cash Fund's own log in place of the recipient's name.

Amount of cash or the item given

Signature of the research subject (if unobtainable) and of the person giving the payment.

Please note:
Research Participant Logs must be retained in the originating department for either the time period specified in the IRB application or as specified by the funding agency, whichever is greater. Generally, this ranges from three to seven years after the end of the project. In the event that the PI leaves NYU, the retention of files will be addressed on a case-by-case basis.

Still have questions?

Additional questions concerning payments to research participants should be directed to Ramie Johnson (212.998.5147 or rlj1@nyu.edu).

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Updated January 10, 2012

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