Payment of Research Subjects
The 91次元 (UM) often conducts research studies that involve the use of human participants. The suitability of any payment to a research participant in a human subject research protocol will be determined by UM’s Institutional Review Board (IRB) and the related protocol must be approved or determined to be exempt by the IRB before the study is conducted.
Human subject payments include all forms of payment (including in-kind incentives) given to participants in research that are consistent with the approved IRB protocol. These are incentive payments to encourage individuals to participate in a research study and provide private data/information through intervention or interaction. This includes participation in surveys, interviews, and other forms of data and/or biospecimen collection. These payments/incentives must be directly related to research activities and the budget justifications should include a correlation between the payment and the research activity. Incentive payments in any amount are generally considered to be taxable income and should be reported by the recipient on his/her individual income tax return. Individuals receiving incentive payments are advised to consult their personal tax advisor regarding the tax treatment of these payments.
UM policy requires that human subjects be paid either through the Virtual Incentives (VI) platform or via check. Researchers that cannot use either of those methods for participant payments must consult with the IRB prior to protocol submission.
Sponsored research refers to research that is funded by an external sponsor, is governed by a formal written agreement such as a grant, cooperative agreement, or contract, and is overseen and administered by the UM Office of Sponsored Programs. These include but are not limited to agreements from federal agencies, such as the National Institutes of Health, the National Science Foundation, and the Department of Defense.
Non-sponsored research refers to research that is not funded by an external sponsor and is overseen and administered by the PI and possibly their Departmental Research Administrator and/or Budget Analyst. Examples include a PI who may be using UM-provided start-up funds for a human research project or a graduate student who receives a departmental award that is administered through the university (and not paid to the student directly).
Important forms and guides referenced throughout this page are linked below.
Responsibilities
1. Principal Investigators (PIs):
PIs and their research teams are responsible for following human subjects payment procedures as outlined below and submitting the appropriate project and account setup paperwork to Virtual Incentives and the IRB. PIs are responsible for submitting the Human Subjects Payment Form to either the Office for Sponsored Projects (OSP) (for sponsored projects) or to the appropriate department Budget Analyst or Departmental Research Administrator (DRA) (for non-sponsored projects). PIs are also responsible for submitting reconciliation reports as per OSP and/or department requirements.
PIs are responsible for communicating payment expectations to participants. Participants should not receive their compensation until they have completed the research, or portions of the research, as applicable, and/or as approved by the IRB. The distribution of e-gift cards must follow the timing, process, or payment scheme as approved, including bonus payments, research milestones, or compilation of research payments over time. If a subject voluntarily withdraws or is removed from the study based on PI review as it relates to, for example, risk to or eligibility of the subject, the PI must decide what is appropriate for payment based on the approved research study or consultation with the IRB.
PIs are responsible for maintaining human subjects payment records in accordance with Business Services, IRB, and OSP record retention policies.
2. IRB Office
The UM IRB office will assist PIs with getting Virtual Incentives projects and VI accounts set up. The IRB will also assist with any questions related to participant protections and incentives, including appropriate incentive amounts for the project and informed consent language.
3. Office of Sponsored Projects (OSP)
For sponsored research, OSP Grant and Contract Officers (GCOs) are responsible for reviewing and approving UM Human Subjects Payment Form requests, and confirming budget categories and fund availability. GCOs are also responsible for reviewing/approving VI invoices before entering the appropriate information into GrizMart to process payments made to Virtual Incentives accounts. GCOs are available to assist with account balance refunds when needed and ensure that PIs submit the correct paperwork for account reconciliation at the end of a project
4. Departmental Research Administrators (DRAs) / Department Budget Analysts
If a project is not sponsored, DRAs and department Budget Analysts are responsible for assisting PIs with entering correct funding information into GrizMart. PIs are responsible for reaching out to their DRA and/or department Budget Analyst for assistance with getting human subjects research incentive funds to their Virtual Incentives account. It is highly recommended that DRAs and Budget Analysts require PIs to submit the Human Subjects Payment Form, like OSP, in order to be consistent in procedures across campus.
DRAs and Budget Analysts should follow the GrizMart procedures as outlined below to process payments to Virtual Incentives.
5. Business Services
Business Services is responsible for monitoring and reporting incentive payments to the IRS that total more than $2,000 to an individual in one calendar year. At the end of each calendar year, Business Services will subtotal payments over $2,000 by participant. Any individual receiving total annual payment exceeding $2,000 will be issued a 1099-MISC form.
PAYMENT PROCEDURES
Payments to research participants can be processed either by virtual gift cards through the Virtual Incentives (VI) platform or via check.
Checks
Checks issued to human subjects will follow normal Business Services procedures. PIs should complete the Check section of the Human Subjects Payment Form and submit it to the appropriate offices for approval and payment.
Virtual Incentives (VI)
VI is a digital rewards platform for administering research participant incentives for IRB-approved research projects. PIs are able to manage their own VI account, allowing for swift payment processing and a customizable compensation experience. Each IRB-approved protocol will be set up with its own VI project. UM is signed up for VI’s GiftCard PASS, which allows participants to choose from a pre-determined selection of brands and payment options, including:
- Amazon
- Bank transfer (cash payout) (requires additional identity verification)
- DoorDash
- Lowe’s
- Starbucks
- Target
- Venmo (3% processing fee administered to participant)
- VISA (Physical; $3 processing fee administered to the participant)
- VISA (Virtual)
- Wal-Mart
Projects that are self-funded with funds that are NOT administered through UM will not be able to utilize VI. Undergraduate students are not permitted to have a VI account or to place Orders. There may be exceptions for graduate students under specific circumstances. Please contact the IRB office for more information.
Project Setup and Account Funding Instructions
- Please start the VI project set-up and accounting funding process at least 30 days before your anticipated first payment date. Fill out the Project Setup Form and email it to the VI contacts listed in the form’s instructions; make sure to copy the IRB on this email. This is the start of the project set-up process. This will take approximately 2 business days. VI will send the PI an email confirmation once the project is set up. VI will also send the PI the project invoice.
- Once the PI receives notification from VI that their project has been set up, then the PI must take the following actions:
- Email the IRB office to get a VI account created. The IRB office will create the PI a VI NOW User account and give them access permissions to their VI project. Please allow at least 5 business days for account creation. PIs will receive an account activation email from VI once their account has been created. All study team members handling human subjects payments will need their own account. The PI should identify all study team members who will be handling payment on the Project Setup Form and these team members should be noted in the PI’s email to the IRB office.
- Fill out and submit the Human Subjects Payment Form. The PI will send the Human Subjects Payment Form to the appropriate people for sign off (Chair, Dean, etc.). After the form is signed, the PI or their designee (DRA, Budget Analyst, etc.) will then send the Human Subjects Payment Form and the invoice for their project to the appropriate OSP GCO.
For project funds that are administered through UM but are not sponsored or that will not go through OSP for funds (e.g., departmental awards), the PI will need to work directly with their department’s DRA or Budget Analyst to have the project set up in GrizMart so that Business Services can fund it. In cases where the PI is a graduate student, the Faculty Supervisor will need to assist with this process.
- Email the IRB office to get a VI account created. The IRB office will create the PI a VI NOW User account and give them access permissions to their VI project. Please allow at least 5 business days for account creation. PIs will receive an account activation email from VI once their account has been created. All study team members handling human subjects payments will need their own account. The PI should identify all study team members who will be handling payment on the Project Setup Form and these team members should be noted in the PI’s email to the IRB office.
- OSP will receive the signed and completed Human Subjects request form, along with the Virtual Incentives invoice from the PI. The GCO will review these forms to confirm the budget category and the availability of funds in the awarded grant. If everything is approved, the GCO will sign the forms.
Next, the GCO will enter a Non-PO requisition in GrizMart to process the payment for the Virtual Incentives. The payment will be made to Medmatics, LLC. The payment type for the Non-PO requisition is categorized under Human Subjects, and the accounting will reference the grant index and account number 1904. DRAs and Budget Analysts should follow this same process for non-sponsored projects, when applicable.
Please note: due to federal reporting and account reconciliation requirements, human subjects payments for sponsored projects may not be made via Virtual Incentives within the last 90 days of an award period. - The PI will receive an email from VI once their account has been funded. Once an account has been funded, the research team can proceed with paying human subjects.
How to Place Virtual Incentives Orders
Once a VI account has been funded, the research team can start placing orders to pay human subjects. Please download the VI Order Guide for step-by-step instructions. At minimum, an order must contain denomination/dollar amount and a participant email.
After an order is placed, participants will receive a customized email from VI with their reward information (based on the Project Setup Form information that you submit). Participants will have 90 days to redeem their reward link. If a participant has not clicked on their reward link within 90 days, then the money reverts back to the project account and the PI retains the money for that reward.
Merchant gift cards (e.g., Amazon, Walmart, Target, Starbucks, etc.) do not expire once the reward has been redeemed. Virtual VISA accounts expire within six months, however, so it is vital that participants know they must spend their VISA reward within six months of redemption. Any unclaimed rewards or VISA funds left on an account after six months revert to Virtual Incentives and the PI/project does not get that money back.
Virtual Incentives has for placing Orders and accessing other functions such as the Customer Service tab and the Reports features.
How to Use Virtual Incentives Customer Service and Reports Features
The Customer Service tab allows VI users to locate specific rewards, view a reward’s detailed activity information, as well as initiate available reward functions such as canceling a reward, canceling & re-issuing to an updated email address or physical address, re-issuing an expired reward, etc. The Reports tab allows a VI User to run reports to review their activity. Please download the VI Customer Service and Reports Guide for step-by-step instructions.
Account Balance Refund Procedures
If there is money left on a VI account after a project ends, then Virtual Incentives will issue a refund to UM. Please note that due to federal reporting and account reconciliation requirements, payments to human subjects may not be made via Virtual Incentives within the last 90 days of an award period.
- The PI must contact Virtual Incentives and indicate that they need a refund for the amount remaining on their project. The PI must include their OSP GCO and/or appropriate DRA or Budget Analyst on this correspondence with VI.
- Virtual Incentives will wire remaining funds back to UM. GCOs, DRAs/Budget Analysts, and Business Services are responsible for ensuring funds are then transferred to the correct account.
- After the refund is issued, PIs should confirm that their VI project account is balanced out to zero.
Account Reconciliation
PIs are responsible for submitting appropriate VI reconciliation paperwork to their OSP GCO or other units if required. Make sure to plan ahead and have this deadline on the calendar.
To reconcile an account, please provide your OSP GCO with the VI Sent Rewards Report (found in the Reports tab) and the signed Reconciliation Certification form. Please make sure to remove any identifying participant information (name and email) before sending the report to OSP.
91次元 Employees
91次元 (UM) employees are permitted to participate in UM-sponsored human subjects research and may receive incentives through the Virtual Incentives platform. However, pursuant to new UM policy, all research incentives provided to UM employees are considered taxable compensation. Accordingly, any UM employee who receives a research incentive through UM-sponsored research will be taxed on the value of the incentive through Payroll. Employer tax costs are estimated to be approximately 8-22% of the incentive amount.
To ensure compliance with this policy, the following requirements apply:
- Participant Screening
Principal Investigators (PIs) must screen all research participants for UM employee status prior to providing payment.- A UM employee is defined as any individual who receives a paycheck from UM, including but not limited to faculty, staff, graduate assistants, and student employees.
- Employee Self-Reporting at Consent
At the time of informed consent, participants must self-identify whether they are a UM employee. Employees must provide the PI with all information necessary to associate the incentive payment with their W-2, including but not limited to their name and 790.
- Reporting to Payroll
After incentive payments have been issued, the PI is required to submit a list of all UM employee participants to Payroll. This list can be emailed to askpayrollacct@mso.umt.edu; please copy your OSP GCO on this email. This list must include the following information for each employee participant:- Employee name and 790#
- Incentive amount
- Date the incentive was redeemed
- Index to be charged for the associated tax expense