Human Research Participant Payments
Emory University is guided by applicable laws, regulations, and principles in its review and conduct of Human Subjects Research. Emory Policy 7.28, Payments to Human Research Study Participants, describes the management of payments to human research study participants, including direct payments, advances, debit cards (ClinCard) and gift cards. The policy states that the PI is responsible for maintaining Institutional Review Board (IRB) approval for the duration of the study and that the payment method must occur as outlined in the consent document signed by the research subject, and payments to research participants must be monitored for appropriate IRS reporting and compliance.
Payments vs. Reimbursements
- A Payment or Stipend is money given to a participant to offset time and inconvenience and/or to provide incentive to participate. This means that the participant is gaining money from participation. Payments are taxable.
- Reimbursement is money given to a participant to pay them back for out-of-pocket expenses related to study participation (e.g., parking and transportation). Reimbursements are are not taxable.
Payment Methods
ClinCard
ClinCard is a reloadable debit card system provided by Greenphire, and it is Emory University’s preferred method of payment to participants of both Sponsor-Funded and Non-Sponsor Funded research studies.
In the recently updated system, entering a participant for ClinCard payment will trigger the system to perform a validation of the entered SSN or TIN against an IRS database. If the SSN/TIN or SSN/TIN and name combination comes back invalid and the study team proceeds, the system will automatically withhold taxes at a 30% tax rate to ensure compliance and payment to the participant will be net of taxes withheld. This is backup withholding of participant taxes.
- There is a $1 fee to register a participant into the ClinCard system for the first time.
- Emory is required to issue Form 1099-misc to individuals who receive $600 or more from all sources at Emory.
- Emory is required to withhold tax and report on payments to non-U.S. residents (in U.S. on visa) regardless of amount.
For more information, view our ClinCard FAQs.
Other Payment Methods
Prior approval is required to use a method of payment other than ClinCard. These methods include check, direct deposit, and gift card. Cash is no longer allowed for payments more than $25.
Research participant payments are considered taxable income to the participant. Procurement will manually validate the SSN of each participant not receiving payment via ClinCard. If any of the participants do not provide a SSN, the value of the payment, regardless of the amount, will need to be grossed up and the study will have to pay the associated withholding taxes.
The PI and another delegate is responsible for tracking these payments and providing the information to Procurement for tax reporting via this form, as well as keeping detailed records for potential audits.
*Please note that under IRS rules cash is not de minimis and all payments, including check or gift card, are considered the same as cash and are taxable income.
Submit a New Supplier Request via Emory Express
- Login to Emory Express
- Go to Shop > Shopping > Popular Forms > Supplier Request
- Complete and submit supplier request form (for instructions, click here)
- The form will be routed to procurement services for approval and setup
Follow your procurement request in Express= 48-72 hours to setup vendor in system. Once the payee has been set up in Emory Express, submit a Payment Request via Compass
- Login to Compass
- Go to Navigator ˃ Employee Self-Service ˃ Payment Request Center
- Complete and Submit form to enter the payment request for approval (for instructions, click here)
Once approved, check will be mailed to the address provided by participant (Please ensure that you submitted the participant’s proper mailing address as well as their business name)
Payment requests are typically approved within 3-5 business days
For additional help, please contact the Finance Support Center:
- Online: https://eufinancesupportcenter.force.com/login
- Phone: 404-727-7000
- Have the subject complete the Supplier Information Form (SIF) before you begin your request (if participant doesn’t have means to complete the form, the coordinator may do so on their behalf).
- Ensure that participants are clear on their routing and account numbers. Once the completed SIF is received, submit a New Supplier Request via Emory Express
- Login to Emory Express; go to shop ˃ popular forms ˃ supplier request.
- Complete and submit supplier request Form (for instructions, click here)
- The form will be routed to procurement services for approval and setup
Follow your procurement request in Express- 48-72 hours to setup vendor in system. Once the payee has been set up in Emory Express, submit a Payment Request via Compass
- Login to Compass
- Go to Navigator ˃ Employee Self-Service ˃ Payment Request Center
- Complete and Submit form to enter the payment request for approval (for instructions, click here)
- Once approved, funds will be deposited into subject’s bank account (ACH processes daily)
- Payments are typically approved within 3-5 business days
For additional help, please contact the Finance Support Center:
- Online: https://eufinancesupportcenter.force.com/login
- Phone: 404-727-7000
Submit e-gift card request through the punch-out supplier via Emory Express
- Login to Emory Express
- Go to Shopping ˃ Shopping Home ˃ Gift Card Purchasing Guide
- Review the Gift Card Purchasing Guide, click next, and submit.
- Go back to Shopping ˃ Shopping Home and select Blackhawk
- Submit Request (When completing the requisition, you must include the IRB protocol number in the internal notes section on the requisition in order to prevent delays when ordering)
- Once order is processed and ready, you will receive email with info to access link/eCode to distribute to the participant
Please note that all gift cards expire 12 months after purchase.
For additional help, please contact: DL-PunchoutSupport@bhnetwork.com
Training
Updated Human Research Participant Payment training coming soon.
Additional Resources
Contact
- General ClinCard inquiries: emoryclincards@emory.edu
- Tax-related questions: Susan Clark at sclar38@emory.edu.
- Budget adjustment requests or other subject payment options:
- Industry-contracted studies, contact WISC at wisctrials@emory.edu
- Federally funded studies, contact your School and Unit RAS.
- For all others, contact OCR at ocr_preaward@emory.edu