664  Research Participant Payments

Approved by President
Effective Date: June 5, 2017
Responsible Division: Business and Finance
Responsible Office:  Business and Finance
Responsible Officer:  Associate Vice President, Business and Finance

I. Purpose

This policy establishes the process used by Middle Tennessee State University (MTSU or University) for payments to research participants through cash or gift card payments.

II. General

A.  Payments to research participants, regardless of delivery method (check, direct deposit, cash, traditional gift card, or electronic gift card) are considered compensation by the Internal Revenue Service (IRS). Research participants receiving a payment, or series of payments, for participating in a research study(ies) must complete a Form W-9 at the time they receive payment.

1.  Personally identifiable information should be gathered in a manner which prevents disclosure of personal information to other research participants.

2.  Signatures must be obtained from research participants, indicating receipt of the cash or traditional gift card payment.

3.  Research participants should be informed that information collected allows the University to meet government reporting obligations and precautions are in place to keep their information secure. Participants may be given the opportunity to participate without receiving payment, if they do not wish to provide identifying information.

B.  Payment amounts and Form W-9’s collected in Section A. above must be forwarded to Accounting Services, which has the reporting responsibility to the IRS.

C.  Payments of greater than one hundred dollars ($100.00) to research participants for participation in studies should be made through the accounts payable system via check or direct deposit.  

D.  Some research studies use low dollar payments to compensate participants for time, inconvenience, or as an incentive to increase participation. When such payments are not more than one hundred dollars ($100.00) per payment, per participant, and individual participant payments by the University aggregate to less than six hundred dollars ($600.00, it may be appropriate to make payments utilizing cash, traditional gift cards, or electronic gift cards, as long as the following procedures are followed. Payments totaling six hundred dollars ($600.00) or more to an individual, in a calendar year, must be reported by the University to the IRS on Form 1099-MISC.

III. Prohibition from Use of Cash or Gift Cards in Research Studies

A.  No payment may be made to a MTSU employee or non-resident alien; an individual who is not a U.S. citizen, or U.S. National, and has not passed the green card test or the substantial presence test. This information should be ascertained prior to an individual’s participation in the study. Contact Accounting Services for assistance.

B.  Written pre-approval should be obtained from Athletic Compliance for participation of student-athletes in the research study, to ensure the student’s athletic eligibility is not jeopardized.

C.  Cash and/or P-Cards may not be used to purchase gift cards.