University at Albany, State University of New York
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Financial Management
MSC Room 216
1400 Washington Avenue
Albany, New York 12222
Phone: (518) 442-3196
Fax: (518) 442-5208

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Sponsored Funds Financial Management
Sponsored Funds | Subject Costs

Subject Costs

Human Subject Payments are payment to a living individual about whom an investigator (whether professional or student) conducting research obtains (1) data through intervention or interaction with the individual or (2) identifiable private information.

Federal and state regulations require that all sponsored program activities that involve human subjects be reviewed and approved by an Institutional Review Board (IRB).  Therefore, requests to pay human subjects should be accompanied with a copy of the projects' IRB Approval.

Human subject payments should be limited to less than $75 per interaction.  Payments exceeding that amount must be approved by the Operations manager, or a designee. 

Payments to human subjects are considered nonemployee compensation and, as such, are subject to Internal Revenue Service (IRS) requirements for miscellaneous income reporting (1099 reporting).  Non-cash compensation is still reportable under IRS guidelines.  Therefore, it is the responsibility of the Principle Investigator to track such compensation and report to the campus should amounts reach reportable levels.  Please note that IRS requirements are not limited to compensation from one particular award, but for a given year.  Therefore, we encourage the use of cash payments when ever appropriate.

Non-cash compensation should be appropriate for the intended recipient. 

Cash Payments
Requests for Human Subject Payments should be submitted utilizing the human subject form.  In addition to the form, requests should also include either a copy of the questionnaire or a brief description of the research they are participating in.  A copy of the University IRB approval of the protocol should also be attached. 

Non-Cash Payment
Should the nature of the research require, gift cards or gift certificates may be issued as Human Subject Payments.   Please note that tax reporting requirements preclude issuing cash or gift card payments to nonresident aliens. 

Request for such instances should be submitted on a purchase requisition requesting payment to the applicable vendor.  As with all Human Subject payment requests, documentation included should briefly describe the research and include a copy of the University IRB approval.  Additionally, the request should itemize the number and amount of non-cash payments and include a list of individuals expected to receive them. 

The department conducting the study will be responsible for maintaining records concerning the issuance of each gift card.  Records should contain the names, addresses, and social security number of the individual as well as a certification statement signed by the subject indicating that they have received such compensation for the described services.  Copies of these records should be submitted to Sponsored Funds Financial Management upon completion of the activity.  No subsequent requests for related non-cash payments will be honored until prior requests are reconciled.

Payments to Confidential Human Subjects
Research activity which dictates that the identity of the subject be kept confidential can issue non-cash payments, such as gift cards.  The same procedures as outlined above would be applicable in this situation with the exception of the records upon issuance of the gift cards.  The department will still be responsible for maintaining records concerning the issuance and receipt of the compensation.  However, information released can utilize a non-identifying indicator, such as subject number.  Please note that the department should be maintaining records with identifying information in the event that compensation reaches reportable levels.


Human Subject Form

Human Subject Payment Certification Form

Confidential Human Subject Payment Certification Form