Sandy,

This would be a problem.  It would seem to be difficult to have
confidentiality with any use of public funds due to the Freedom of
Information Act (FOI) and the public's availability to Government
information.  Additionally, I am unaware of any Federal Law that waives
reporting requirements when an organization is paying for services
rendered.  Sounds like you need additional legal and tax advice.

What is the reason for the confidentiality?  Is it that the person's
name will not be published the research reports?  That would be an easy
omission, since the only place the name will appear is in the financial
documents of the project file.  Generally, the only people (other than
the Principal Investigator) who have access to that detail of the
project information is the Grant Manager & auditor.  Since these
individuals do not normally read/study the research results, it would
not seem to violate any subject confidentiality.  The FOI protects the
release of sensitive personal information and the controlling documents
for subject payment should only have a statement "payment for services"
with identifying project number.  I don't see how this level of
information would violate any confidentiality.

My interpretation would be no social security number no payment unless
there is sufficient legal case precedence to waive the IRS reporting
requirements and normal accounting practices.

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