Effective Date: June 20, 2023
Last Reviewed: June 20, 2023
POLICY STATEMENT
The purpose of this policy is to describe the process by which Stonehill College will compensate Human Subjects of research studies. This policy aims to ensure compliance with federal tax law and reduce fraud risk while also recognizing the importance of human subject confidentiality in the design of certain studies.
Applicability
This policy applies to human subject payments made by Stonehill College. If a researcher is compensating study participants with external funding for which the College is not the responsible fiscal agent, then the College is not the payor and therefore not the party responsible for tax reporting.
Policy Context
The Internal Revenue Service (IRS) considers any compensation to individuals participating in research studies to be taxable income for U.S. federal income tax purposes, regardless of whether the compensation is cash, cash equivalent (e.g., gift card/check), or in-kind (e.g., books, electronic devices, etc.). This means that the recipient of the payment has an obligation to include the amount received on his/her personal income tax return for the year and that Stonehill College must comply with the IRS reporting obligations for payors. Payments to U.S. citizens and resident aliens of $600 or more during a calendar year are required to be reported to the IRS on Form 1099-NEC and payments to nonresident aliens are required to be reported to the IRS on Form 1042-S.
Payments to Human Subjects
Payments to Employees
All payments to college employees are subject to federal and state tax withholdings and reportable on the employee’s Form W-2, regardless of amount. Employees of the College can only be paid through the Payroll Stipend process, regardless of the amount.
Payments to Non-Employees and to Students
Stonehill College allows two payment methods to compensate non-employee and student human subjects for participation in research studies.
- Gift Card (Only for Payments of $100 or less): Gift cards may be used to compensate human subjects of research studies if the amount does not exceed $100.
- Note: If a Researcher has reason to believe that an individual may receive $600 or more in compensation from Stonehill College during a calendar year, the researcher must compensate this individual through the AP Check process, even if his/her study compensation is $100 or less and would otherwise be able to utilize the gift card payment method. This scenario might occur if the human subject has participated in other College-sponsored research studies or has performed other services for Stonehill College as a contractor.
- Accounts Payable Check (Required for Payments of more than $100): The preferred payment method, and the method required for payments exceeding $100, is to pay the individual through Accounts Payable.
- In-Kind (Non-Cash/Cash Equivalent) Compensation: The fair market value of any in-kind compensation (e.g., books, electronic devices, etc.) is considered income to the recipient. If a human subject is to receive in-kind compensation (or a combination of in-kind and cash compensation) more than $600 in a calendar year, please contact Accounts Payable as a Form 1099-NEC must be issued to that individual.
Student employees do not need to be paid by stipend and can be paid according to either the AP Check or Gift Card methods noted above.
Raffles / Drawings:
This policy applies to the awarding of prizes related to raffles or other drawings held for human subjects participating in each study.
Definitions:
Human Subject: A volunteer participant in a research study. Any person participating in a research study is known as a human subject (participant). Under federal regulations, human subjects are defined as: living individual(s) about whom an investigator conducting research obtains: 1) data through intervention or interaction with the individual or 2) identifiable private information.
Stonehill College Employee: Any individual who is on the Stonehill College payroll and for whom Stonehill College is required to withhold income/employment taxes during the calendar year in question (i.e., faculty and staff). For purposes of this policy, student employees are exempt from this definition.