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When subjects will be compensated for their participation in a study, compensation exceeding specific amounts may be subject to record keeping requirements of the State of Iowa, grantor agencies, and the Internal Revenue Service. These record keeping requirements may necessitate collection of a Social Security Number (SSN) or Taxpayer Identification Number (TIN). In order to protect subject privacy, the Institutional Review Board expects that researchers will collect only the minimum information necessary to answer the research question.
The following policy does not apply to studies conducted at the Veterans Administration Healthcare System or subject to VHA policies. For more information on the VAHCS policy for research subject compensation, please see VHA HANDBOOK 1200.05 paragraph 59.
Any single payment to non-VA subjects exceeding $100.00, or cumulative payments of more than $600 in one calendar year to the same subject will fall under the SSN and TIN collection and usage guidelines outlined in this policy. In the event a Social Security Number or Taxpayer Identification Number must be collected for compensation purposes, the Principal Investigator must have plans to protect the SSN or TIN from disclosure. If a study will provide multiple payments over a period of time, the Social Security Number or Taxpayer Identification Number must not be kept in the research files for future payments. The identification number must be discarded in a confidential manner once the Research Participant/Substitute W-9 form has been sent to Accounts Payable and a Vendor ID has been assigned to an individual.
As of January 21, 2014, all research projects will require updating at the point a modification or continuing review is submitted, to bring existing projects in line with the new policy.
UI Faculty, staff, and students should be aware of the University of Iowa policies regarding the collection, use, and storage of Social Security Number (SSN) when used for research subject reimbursement. SSN’s and TIN’s must be protected from disclosure. A copy of this policy can be found here.
Subjects must be given the option to waive compensation if they do not want to disclose their Social Security Number for the purposes of compensation for research participation.
Per the guidelines outlined in this policy;
- Any single payment to subjects exceeding $100.00, or cumulative payments of more than $600 in one calendar year to the same subject will fall under the SSN/TIN collection and usage guidelines.
- Payments to non-resident aliens are subject to further usage guidelines. In addition, recipients must complete a Research Participant/Substitute W-8BEN form.
- Reimbursements for travel or per diem are not subject to the requirement to collect SSN/TIN regardless of the amount of reimbursement.
- Reimbursements of this nature are expected to be supported with receipt or mileage documentation.
- This type of reimbursement without supporting documentation could be construed as tax avoidance.
- Flat rate reimbursements are considered to be compensation if it is not reimbursement at cost or at the designated mileage reimbursement rate.
- Any questions related to this requirement should be referred to Grant Accounting.