If you allow employees to be subjects (I know of no reason not to!), work
with your payroll and accounting on this.  They are the ones who have to
meet the IRS regulations.  Generally, W-2 covers all payments to employees,
but there can be special situations where some extra payments are by
1099.  In any case, take special care that the individual cannot easily be
identified as a subject in this specific study based on the data in the
payment documents -- for example, run the payment through a pool of all
payments for all subjects, where the output does not identify the specific
study.  Doing this might pretty much drive how the payment generates data
for the IRS (my guess is that it would result in a 1099).

This problem of paying subjects but meeting the no-personal-identification
requirement is a bothersome one in many ways.

Chuck

At 04:37 PM 6/4/2004, you wrote:
>I'm curious as to how reimbursements/payments to research subjects, who
>happen to also be your employees, are handled at your Institutions?
>Do you issue both a 1099 and a w-2?
>Withhold taxes and list it as something other than salary on the w-2?  If
>you withhold, do you address this in the consent?
>Not allow employees to be subjects at all?
>Something entirely different?
>
>Thanks,
>Jennifer
>
>Jennifer Sharp, JD
>University of Arkansas for Medical Sciences
>Associate Director
>Office of Research and Sponsored Programs -
>Institutional Review Board
>Office of Clinical Trials
>4301 W. Markham Street, MS  812
>Courier Address:  4th & Jack Stephens,
>Biomedical Research Building, Room 102
>Little Rock, AR  72205
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