Chuck,

 Does you're IRB know that you are processing subject payments in this
manner.  By disclosing to a third party (accounting) you are breaching the
confidentiality of the research process.  Especially if you identify the
research project they are in.  While you are satisfying all of the post
award audit requirements, I really believe that you are in an ethical/breach
of confidentiality arena.

Barbara LoDico

Chuck Willis wrote:

> Gretchen,
>
> We use a standard form for expenses/reimbursements to cover these
> situations.  This issue can be complex, especially for Federal & State
> income tax, FICA reporting, etc.  Each form cites the project, Principal
> Investigator approving the expense/payment, then full mailing address,
> name and social security number of the subject receiving the payment.
> Our form has a disclaimer that states we will issue a 1099 IRS form for
> all payments and the person understands we will forward the information
> to the IRS.  Each person has to have a valid social security number to
> receive a payment.  The payments are mailed directly to each person.
>
> This way is extremely time consuming and rather expensive for cutting
> small checks ($5 to $50, etc.) but it covers all the legal issues.  The
> IRS is satisfied, we have an adequate paper trail to satisfy
> reporting/audit requirements.  We have had some problems in the past
> with younger people and foreign students not having valid social
> security numbers..but that answer is simple..if no social security
> number, no check..  Since the IRS now requires social security numbers
> for all dependents on Tax Returns this issue has ceased to be a problem.
>  Of course this seems to be a hassle to P.I.'s, but rules are rules.
>
> Sincerely,
>
> Chuck Willis
> Grant & Contract Administrator
> ODU Research Foundation
> Phone: (757) 683-4293 Ext. 613
> Fax: (757) 683-5290
> E-mail: xxxxxx@pobox.hprf.odu.edu

--
Barbara J. LoDico, IRB Administrator   xxxxxx@umdnj.edu
New Jersey Medical School, MSB C-690   (973) 982-3608
185 So. Orange Ave., Newark, NJ 07103  fax (973) 982-3585