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XIII. Human Subject Payments

XIII. Human Subject Payments

This policy details the process for the payment of compensation to human subjects participating in research projects at UTA. UTA faculty and staff have the legal obligation to maintain confidentiality of human subjects as well as fulfill financial accountability. This guidance is to help UTA staff and investigators work together in order to achieve the following goals: (1) Ensure the confidentiality of research subjects; (2) Provide timely, convenient compensation to participants to facilitate, not hinder, the study; (3) Provide sufficient financial documentation for the University’s records and for IRS purposes; (4) Provide sufficient documentation that compensation was provided to research subjects for participation in a study; and, (5) Ensure that appropriate internal controls and adequate safeguards exist for items of value used to compensate, whether cash, checks, or other.

The process for paying research participants depends on the source of the payment and on the method in which you are distributing the funds. For payments made to human subjects from UTA funds or federal, state, or local grants, the payments human subjects receive for time and effort involved in participating in a study are considered taxable income, regardless of the amount. Payments may take many forms, including check, cash, money order, gift card, or any gift with a monetary value.

1) UTA Business Affairs department - This policy requires that UTA funds (i.e., working fund, procard, grant account) a W-9 and tax information should be collected from each subject. If an investigator plans to collect this information, the investigator is asked to describe in the protocol the confidential and safely transfer of the information to the accounting office. Please note: if personal funds are used to compensate subjects, this policy does not apply

2) IRS Considerations - The IRS treats human subject payments, no matter the form, as taxable income to the recipient. All forms of payment are subject to IRS guidelines:

A) The IRS W-9 form (UTA Form 1-18, Office of Business Affairs), must be collected from human subjects receiving payments from UTA or a gift or gift card with monetary value.

B) UTA is obligated to report to the IRS all non-university employees (U.S. citizens or resident aliens) who receive income greater than $600 in an annual year. If UTA pays $600 or more to a U.S. tax resident during the calendar year, then UTA is required to report the payments to the IRS and issue the recipient a Form 1099. Where reporting is required, UTA must collect the recipient's full legal name, SSN/ITIN (or HUID), permanent address, mailing address (if different) and Foreign National Information Form (FNIF, for foreign nationals).

C) UTA is obligated to add research payment income to UTA employee research participants (including student employees) on the UTA employee's W-2 annual earnings. These payments are subject to income tax and other withholdings as applicable.

D) Payments made to human subjects who are nonresident aliens must be paid by an Accounts Payable check or through UTA Payroll if a foreign National is a UTA employee and must be reported on Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding, regardless of the dollar amount or W-2. All payments to nonresident aliens are subject to 30% federal income tax. Researchers anticipating payments to Non-Resident Foreign Nationals should contact the UTA Payroll and Tax Compliance Office for guidance prior to making such payments.

3) Informed Consent Information - The information below is suggested information to include in the informed consent document:

“The Internal Revenue Service (IRS) considers all payments made to research subjects to be taxable income. Your personal information, including your name, address, and social security number, may be acquired from you and provided to UT Arlington’s accounting office for the purpose of payment. If your total payments for the year exceed $600.00, UT Arlington will report this information to the IRS as income and you will receive a Form 1099 at the end of the year. If you receive less than $600.00 total for payments in a year, you are personally responsible for reporting the payments to the IRS.”

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