I guess I should have given a more detailed explanation for everyone. The certification the participants sign was developed by my state division of legislative audit, who completes our 133 audit on campus. The program I am referring to is for subjects where confidentiality is important, such as a research study involving aids victims, etc. where the participants name and personal information is to be kept in the strictest of confidence. Please note, I come from a small institution in a rural state where "everybody knows everybody" so running payments directly through the university's system for these types of studies can be almost like placing the names on a Marquette as you drive into town :( Prior to utilizing this process, the PI is required to meet with my office for training on the process. The PI also signs their own certification stating they will comply with all university, state and federal regulations involving the disbursement of the funds to the research subjects. In cases where a 1099 is required, the PI works directly with our accounts payable manager to process the payment, in order to keep everything as confidential as possible. In case of audit, the PI's records are reviewed separately from the financial documents. In my particular situation, we have a limited population base for obtaining research subjects, therefore, we try to do our utmost to make their experience with my institution as positive as possible under the circumstance. Renita -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Steinert, Bruce Sent: Wednesday, November 02, 2005 10:24 AM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] Providing Participant Fees to Research Subjects Hi Renita, You may be setting yourself up for compliance issues. The institution is responsible for making the required IRS reports, but you seem to have put the data and compliance certification in the hands of others (subject and PI). I'm sure we all implicitly trust our PIs and know that each will unfailingly inform the appropriate institution office if/when the IRS threshold is breached. But a few points to consider: Will a given PI know whether the subject participates in future studies? The subject may not realize the implications of erroneous or failed reporting. Also, relying on PIs to use or disclose subject financial information to determine compliance requirements could raise confidentiality issues if not handled appropriately. There is no confidentiality issue (HIPAA or otherwise) if all subjects are informed at the time of consent that specific financial information (e.g., name, address, SSN) will be collected by the institution to process study payments and make necessary reports. There should be a central point of contact to process and monitor that data. It's easiest if the POC also processes the payments (check, voucher, cash, etc.) IMHO, Bruce Bruce Steinert, PhD, CCRA Administrative Director, Clinical Trials Center ENH Research Institute Evanston Northwestern Healthcare -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Renita Gray Sent: Wednesday, November 02, 2005 9:24 AM To: xxxxxx@HRINET.ORG Subject: Re: [RESADM-L] Providing Participant Fees to Research Subjects Our PI is required to keep a log which includes Name, Address, SSN, Date and Amount Received. In addition, the participant is required to verify that they have not received payments of over $600, which would require IRS 1099 reporting. Otherwise all information is kept completely confidential and is only available in the PI's records. Renita L. Gray, CRA Director of Sponsored Programs Arkansas State University P.O. Box 1260 State University, AR 72467 Telephone: (870) 972-2400 Facsimile: (870) 910-8209 "If my life is fruitless, it doesn't matter who praises me, and if my life is fruitful, it doesn't matter who criticizes me" - Bunyan -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Julie Wyse Sent: Wednesday, November 02, 2005 8:47 AM To: xxxxxx@HRINET.ORG Subject: [RESADM-L] Providing Participant Fees to Research Subjects I would like to know the process in which other institutions are using in order to pay a participant fee to research subjects. Do you require name, address and social security number? If a participant will not give his/her SSN can they participate. Do you provide payment at the time of the session or is it mailed to the participant? If payment is given at the time of the session do you require the individual to sign a statement noting that they received the funds? Thank you, Julie Wyse IUP Research Institute Project Development Officer xxxxxx@iup.edu (724) 357-4504 Stright Hall 107B ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
