Office of Sponsored Programs
The Ohio State University

Payments to Human Subjects

University research projects may require the participation of human subjects. Often, these individuals receive payments – in the form of cash, checks or non-cash items – for their participation. Principal Investigators (PIs) and other faculty/staff members 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. For additional information, download the Policy on Payments to Research Subjects.

Managing Research Subject Payments

Human Subject Cash Accounts and Human Subject Checking Accounts
To establish either a petty cash account or a checking account for the purpose of paying study participants, a Human Subject Petty Cash Fund Information Sheet (PR-HS1) is submitted to the Grants Accounting department. The form requires the approval signature of the Principal Investigator (PI) and the Chair/Dean. Once the account has been established by Grants Accounting, charging the project and replenishing the account will use standard eRequest workflow.  If you have questions please call 8-5456.

OSP Gift Cards
This payment method may be used for single payments, or payments in aggregate, of up to $100, per subject, per protocol, per year, for all research subjects.  Although gift cards are somewhat similar to cash or checks in their use, the mechanism for their procurement and accounting for their use are unique. Be sure you understand the required reconciliation procedures before you request gift cards for your project.

Purchase of Gift Cards: Gift cards can be obtained by purchase order through the Office of Sponsored Programs Purchasing Department. Be sure you order only an amount of cards that you are sure you will use. Unlike cash or checking accounts, OSP has no mechanism to accept the return of gift cards that have been purchased but not distributed to human subjects. Charges for gift cards purchased but not distributed will be transferred from the project to the department associated with the project.

How to make payment to a subject:  When a subject has completed his participation in a study, the account custodian should issue a gift card, fill out a Human Subject Payment Receipt, and have the subject sign the receipt. A separate receipt is required for each disbursement. It is the responsibility of the custodian to maintain all receipts in a secure and confidential manner in the project records.

Reconciliation of Gift Cards on a Sponsored Project: While a project is active, the value of undistributed gift cards (gift cards on hand), plus the value of all Human Subject Payment Receipt retained by the project should equal the amount of expense charged to the project for gift cards. When a project is finished, any undistributed gift cards should be turned in to the appropriate department and the charges for these gift cards should be transferred from the project to the department. A final reconciliation of gift cards on a project should confirm that the value of all Human Subject Payment Receipt retained in the project files is equal to the total expense for gift cards charged to the project.

Mailing Gift Cards
If gift cards are to be mailed to the human subject in exchange for completing a survey or other purpose that makes collecting their signature impractical, the reconciliation is still required. There should be two employees in the room at all times while the gift cards are prepared for mailing. A list of recipients should be maintained. The list should record the same demographic information that is captured on the Human Subject Payment Receipt (date mailed, paid to, dollar amount, subject number, gift card number from back of gift card, human subject protocol #, project #), as well as the address that the gift card is mailed two. Both employees are required to sign the list. The SFO is also required to sign the list.

OSP Accounts Payable (PREP) Disbursements
This payment method may be used for all research subject payments to U.S. citizens and residents. Its use is required for payments to U.S. citizens or residents, singular or in aggregate, greater than $500 per subject, per protocol, per year. NOTE: See section below for additional details on payments to nonresident aliens.

How to make payment to a subject:  The PREP system can be accessed by a trained and authorized department administrator. When making payments to human subjects via PREP it is critical to use account number 64615.The use of this account ensures the confidentiality of subject information. Additionally, “payments to research subjects” should be chosen from the drop down selection for the “Short Description” box. If the research subject is not a university employee, he/she must complete a Vendor Maintenance Online Request Form, which must be provided to Office of Sponsored Programs Accounts Payable in order to release the payment. The Vendor Maintenance Online Request Form needs to be submitted only once for an individual. It remains in effect indefinitely, however, if the subjects’ personal information changes, a new form should be submitted. University employees do not need to submit a Vendor Maintenance Online Request Form. The required information for employees is already available through the human resources system.

Records maintenance:  All records generated through PREP will be maintained centrally at the Office of Sponsored Programs.

OSP Accounts Payable Disbursements to Nonresident Aliens
Special processing requirements apply to payments to nonresident aliens.  The university must comply with regulations of both the IRS and the Department of Homeland Security. The rules regarding payments to nonresident aliens are complex and the penalties for violations are harsh and can include deportation from the United States. For payments greater than $100, OSP needs to obtain critical information on the nonresident alien’s visa status before the individual participates in a project as a research subject. Contact the Office of Sponsored Programs (OSP) Accounts Payable Office for additional details. As a starting point, OSP will need a copy of the subjects’ visa or immigration stamp, a copy of their passport photo page, and a completed Vendor Maintenance Online Request Form. Using these documents, OSP personnel will determine is an individual is allowed to be paid as a research subject. In some cases, additional information may be required to make a final determination.