We are working on implementing a new participant remuneration system at my institution and are running into some challenges. If there is anyone out there who has a robust practice, including supporting documentation/policies in place, that would be willing to share? It would be MUCH appreciated!

 

Our organization treats primarily pediatric patients and therefore a large portion of our research subjects/participants are under the age of 18.

 

In our current system, we were able to provide remuneration directly to the participant if they were over 13; with the new system, we aren’t allowed to issue a card to an individual unless they are over 18.

1.       This may have tax implications for the parent/caregiver/guardian

2.      Our Finance department is insisting that we obtain a W-9 from all participants up front (which seems rather onerous…) for multiple purposes:

a.       Tax compliance with IRS 1099 issued for >$600 payments, BUT

                                                                                                  i.      The receiver isn’t really the recipient of the funds – more of a “pass-through” entity

                                                                                                ii.      The receiver may get multiple payments for different children’s participation in various/multiple studies, thus elevating the risk of exceeding the taxable threshold

b.      Completing an OIG compliant “vendor exclusion search” on all remuneration recipients

                                                                                                  i.      Does anyone else do – or not do – this with policy/documentation to support this decision?

                                                                                                ii.      Are research participants really vendors?

 

Thank you in advance for any advice you can offer! Feel free to reach out directly to me rather than replying to the list serv thread! 😊

Tammy L. Jobes, DBA, CRA
Sponsored Projects Administrator | Research
Internal Zip: 183205
200 University Ave East | Saint Paul, MN 55101
Phone: 651-229-3992 | Fax: 651-229-1767
Email: xxxxxx@gillettechildrens.com
Research Correspondence: xxxxxx@gillettechildrens.com

Normal Business Hours: 7:00 a.m. to 4 p.m. Central time; Upcoming PTO 6/19-6/26

 

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