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

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 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")
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 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")
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