Hi All,

We are in the process of also creating a standard addressing Participant Support Costs. We are looking at the 2020 PAPPG and have some questions about how to define “employees”.

FT of the university?

FT of the department?

FT of the grant?

For student also employed would arms-length be enough, i.e. they work in the library and participate in program in the biology dept?

Best,

Tracey

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Michael Spires
Sent: Thursday, August 27, 2020 10:29 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Wages vs. Participant support vs. Participation incentives

Let’s start by correcting a common terminological misunderstanding. Payments to human subjects are not in any way stipends – they’re just what the name implies – payments. “Incentives” is more commonly used when the remuneration of research subjects takes other forms than money – a souvenir or a gift of some kind – but that term can be used when actual money is involved, too. Either kind must be budgeted under other direct costs and not as participant support.

Participant stipends are (roughly) defined in the Uniform Guidance at 2 CFR 200.75. The key distinction is that stipends are paid to participants (not employees) and in connection with conferences or training projects. Usually, a stipend will not be paid through the normal payroll mechanism, and the recipient will get a 1099 (if the stipend is more than $600 in a given tax year) rather than a W-2 – but that’s not an ironclad rule. Sometimes stipends are paid through the payroll process – it varies from institution to institution and depends on circumstances. Participants are not engaged in specific work or expected to provide deliverables – they’re supposed to be learning something. Sometimes that learning comes in the form of a research project where they will, in fact, be doing specific tasks or undertaking assigned projects – but it’s primarily in the context of a learning process. Think of a graduate research assistant, or a trainee on an NIH award – the amount of time they can put in on the work is limited because they have to make time for their classes. The fringe benefits they’re provided are different from those that regular faculty or full-time staff get (usually it’s limited to FICA/Medicare and unemployment insurance). They’re connected to the institution as a student and not as an employee.

Paying someone as an employee is covered pretty well by the differentiations between employees and contractors. The employer sets the working hours and conditions, provides the employee with necessary resources to carry out their assigned duties and responsibilities, and sets either an hourly wage or a monthly/annual salary amount. The employer usually provides fringe benefits, at least for full-time or qualified part-time employees. Employees can be disciplined for poor performance, and so on.

Michael Spires, M.A., M.S., CRA
(He/him/his)

Research Development Officer

The Research Office

Oakland University

256 Hannah Hall

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(248) 370-2207

xxxxxx@oakland.edu

Past President, National Organization of Research Development Professionals

Oakland University has taken steps to slow the spread of COVID-19. Nevertheless, the Research Office is available to faculty and staff for all the research development, proposal submission, and award management services that we routinely provide; please reach out to us through email (first preference) or phone.

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Amy Velasco
Sent: Thursday, August 27, 2020 13:00
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Wages vs. Participant support vs. Participation incentives

Hello all-

I’d like to develop an internal resource to help our pre-award staff talk with PIs about how to determine when someone should be paid as an employee vs. when they can receive a stipend as a participant, and the difference between participant stipends provided to those who are receiving a service and participation incentives paid to those who are just completing surveys (and not receiving services). Has anyone developed this kind of guidance document or checklist that they would be willing to share? I understand that I’ll need to tailor it for any state-specific employment considerations (we’re in CA; that’s always true), but I’m selfishly hoping that I won’t need to start from scratch. 😊

Thanks for your help,

-Amy

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Amy Velasco

pronouns she/her/hers

Associate Vice President for Research Administration

Research and Economic Development

Cal Poly, San Luis Obispo, CA

^_______

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