Occidental College Human Subject Research Payment Policy
I. POLICY STATEMENT.
Occidental College is committed to compliance in all areas of its operation and adheres to all regulations concerning human subject participants (HSP). It is not uncommon for HSPs to be paid for their participation in research studies. Occidental College does not generally allow the purchase of gift cards as rewards. However, in some instances, financial payouts are necessary to the conduct of approved research with specific conditions. Payment for participation in research studies is not considered a benefit, it is compensation for time, effort and for study-related expenses. Compensation to HSPs should not be confused with Participant Support Costs.
II. APPLICABILITY.
This policy applies to all OXY personnel who are involved in Human Subjects Research and wish to provide gift cards or cash payouts as compensation to research participants using OXY funds (including external grants awarded to the institution).
III. Definitions.
CO- PI - Co Principal investigator
HSP – Human Subject Participant - According to 45 CFR 46, a human participant is a living individual about whom an investigator conducting research obtains (1) data or samples through intervention or interaction with individuals(s) or (2) identifiable private information.
HSRRC-IRB - the Human Subjects Research Review Committee - Institutional Review Board.
PI - Principal investigator
PSC – Participant Support Costs - Participant Support Costs, as defined by 2 CFR §200.75, 200.456, are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects.
Researcher - an individual who is interacting and/or intervening with HSPs or handles personally identifiable data of a HSPs.
SRO - the Sponsored Research Office.
IV. POLICY
A. Responsibilities of Researchers
Researchers must:
- Ensure the compensation is for voluntary participation in the study. Compensation can be in the form of cash, gift cards, products, or physical checks. In some cases, payments are made to the legal guardians of participants of vulnerable populations. The researcher must not deviate from the amount, type, or timing of compensation without amending their protocol and securing the HSRRC-IRB’s approval.
- Document how much is paid to each HSP, regardless of dollar amount. The document should provide the following information:
- Date of the transaction
- Receipt of purchase if utilizing gift cards
- Signature of HSP acknowledging receipt of payment
- Protocol name or number (IRB assigned)
- Amount of payment; and
- Name of the IRB-authorized Researcher making the payment.
- NOTE: The compensation paid to HSPs should not exceed $500 in a calendar year. It is recommended that the Researcher keep compensation below $600 to comply with OHRP regulatory requirements of maintaining anonymity, privacy, and confidentiality. If the amount paid to a HSP during a calendar year is $600 or more, HSP anonymity cannot be maintained because the College must report such payments to the Internal Revenue Service. Completing the Informed Consent Form ensures HSPs are notified of this. Before December 31st, please submit your log of HSPs who received $600.00 and or more, along with their Informed Consent Forms, to Accounts Payable for 1099 processing.
- Store consent forms for a minimum of seven (7) years after completion of the research. If OXY is audited by the IRS or other agencies (e.g., OHRP, granting agency, etc.), these forms must be presented.
- Physically safeguard cash and gift cards from loss at all times:
- Place them in a safe or a locked receptacle, and keep the receptacle in a properly secured area.
- HSP payments should be reconciled regularly (not less frequently than quarterly and upon termination of any award) by the Researcher to ensure every HSP was paid accordingly.
- In the event of a theft, the loss must be reported to Campus Safety and the Business Office
- If a gift card or cash payout is provided outside of these parameters, the value of the payout(s) may be added to the Researcher’s gross income in payroll and will be subject to tax
B. Responsibilities of the SRO and HSRRC-IRB
The HSRRC-IRB, in collaboration with the SRO, reviews both the amount of payment and the proposed method and timing of disbursement to ensure that they are neither coercive nor present undue influence [45 CFR 46.116, 21 CFR 50.20].
C. Procedures
Access to funds will depend on the preferred purchasing method, participant payment type, and whether the HSP is anonymous or not:
|
Purchasing Method |
Payment Type |
|
Oxy credit Card |
Gift Card only |
|
Cash Advance |
Gift Card / Cash |
|
Personal Funds Reimbursement |
Gift Card / Cash |
1. OXY Credit Card
Procedure for purchasing gift cards, from a retailer of your choice, using your OXY-issued credit card:
- Purchase a small number of gift cards at one time:
- So your credit card limit is not exceeded;
- Because it is easier to track and safeguard smaller numbers of gift cards, and
- Most gift cards are not refundable and all purchased gift cards will be charged to the study, used or not.
- Retain receipts so they can be included with your monthly credit card expense report.
- Gift cards should be distributed to HSPs within thirty (30) days of purchase.
Note: Fees for gift cards may not be charged to federally-sponsored projects.
2. Cash Advance
Cash advances may be used to pay participants with cash or gift cards.
- Prepare a Cash Advance Request Form, payable to the Researcher employed by the College, with the following information in the "Business Purpose" area:
- Length of time the cash advance will be needed, to a maximum of thirty (30) days.
- Amount to be paid to each HSP.
- Number of HSPs to be paid.
- Name and protocol number of the research project.
- Expected date Accounting will receive documentation supporting the payments to HSPs.
- Dollar amount of the advance.
- Include approval from the PI (and Chair or Dean, if Researcher is the PI); and the IRB Committee.
- Each cash advance must be cleared upon completion of the research or by the date specified on the cash advance, whichever comes first. When warranted, due dates may be extended by the Controller.
- To reconcile and clear a cash advance, submit an Employee Expense Reimbursement Form (obtained through the Accounts Payable office) along with appropriate original expense receipts attached and a Banner Cashiering receipt from the Business Office for any amount left unspent to Accounts Payable. Do not return unspent cash to Accounts Payable.
3. Personal Funds Reimbursement
Submit an Employee Expense Reimbursement Form for the total amount to be reimbursed including the following information;
- Approved by the PI (and the Chair or Dean, if Researcher is the PI);
- Include the approval by the HSRRC-IRB.
- Ensure the"Business Purpose" section provides the following information:
- Amount paid to each HSP.
- Number of HSPss paid.
- Name and protocol number of the research project.
- If gift cards were given, include the purchase receipt of the gift cards.
V. POLICY HISTORY.
Responsible Officer(s): Controller
Effective Date: August 12, 2024
VI. RELATED POLICIES AND RESOURCES.