How Do I... Pay Confidential Research Participants?
This Steinhardt guideline covers direct payments to confidential study participants to enable human subject research.
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.
- ...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.
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
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 debit card, merchandise card, MetroCardTM or goods (e.g., an NYU hat).
- The security of undisbursed cash or cash-equivalents is of utmost concern.Cash equivalents include retailers’ gift cards, pre-loaded debit cards, MetroCardsTM, and money orders. 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 it 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.
To access the currency to make cash payments to participants, a Research Petty Cash Fund can be established to be used solely for research participant payments. Use the 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 items are not purchased via a petty cash fund. They are purchased using normal New York University procurement processes. Negotiable items, such as money orders, pre-paid debit cards, retailers' gift cards or MetroCardsTM require very strict accountability. They must be handled like cash.
- Pre-loaded debit cards in denominations from $10 - $1,000 may be obtained through NYU’s Accounts Payable. Allow 2-3 weeks for the first order and 7-10 days for subsequent orders. See How Do I… Obtain and Use Debit Cards for Payments to Human Subjects?
- MetroCardsTM can be ordered online from the NYU Computer Store via i-Buy. The maximum order is $3,000. The order turnaround time 1-4 business days.
- If pre-paying a vendor for items via an NYU payment, plan ahead. Consult with your department or unit administrator on the preferred method of payment. If a paper check must be generated, you may need to allow for as much as three weeks.
- 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."
Each payment to a confidential research participant -- 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 obtainable) and of the person giving the payment.
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 3-7 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.
Updated October 15, 2015