Monetary Participant Incentive Guidance

• This guidance offers best practices for disbursing payments to participants in research studies and provides information about when research participant tax reporting information must be collected by the Principal Investigator (PI) on behalf of the university.
• This guidance is designed to provide documentation and reporting guidance to WWU faculty/staff involved in processing payments to research participants while still maintaining appropriate levels of confidentiality and minimizing administrative burden when possible.
• The most common form of research participant incentive at WWU is through a gift card. The gift card incentive method helps assist researchers establish appropriate financial controls for oversight and the prevention/detection of fraud and theft.

Scope

1. WWU research projects may pay individuals for their participation in research projects in accordance with a Human Research Protections Program (HRPP)-approved protocol that explains the amount and process for compensating the participants.
2. This guidance does not apply to situations involving direct reimbursement for costs associated with participating in the research (i.e. travel, lodging) or non-financial incentives.
3. WWU is responsible for properly accounting for all payments made to individuals to ensure fiscal accountability and meet Federal reporting obligations.
4. Incentives improve recruitment by encouraging individuals to enroll in a study and to complete some or all research activities. Incentives are not considered prizes or awards. See also Standards for Purchasing Awards, Prizes, Incentives, and Gifts . 

Principle Investigator (PI) Responsibilities

• The PI must attach a copy of the appropriate HRPP determination letter detailing the approved monetary incentive to the Request to Purchase a Research or Survey Participant Incentive eSign form.
• In the event of an audit, the PI holds responsibility for supplying all required supporting documentation for human participant incentive payments made from the PI’s research accounts. PIs must securely maintain records needed to support incentive payments to recipients.

Incentive Payment Process and Procedures 

1. Informed Consent Documents: Include participant incentive information in study consent forms. See HRPP Consent and Other Templates page for guidance.
   • Allowable Mechanisms for Payments to Research Participants
   • Gift Cards: This is the preferred method for providing payment to research participants
   • Online crowdsourcing platforms
   • Other: Alternatives may be used on rare occasion in extenuated circumstances and must be pre-approved
2. Unallowable Mechanisms for Payments to Research Participants: Gifts made to third party organizations in lieu of a direct payment to participants
3. Payments to participants will vary based on the type of research performed. Therefore, the University has divided these payments into three categories

Note: Specific post-award guidance from external funders supersedes the following guidance.

$0 to 200.00 USD: De minimus 

Requiring even minimal information from a participant is highly likely to reduce participation and exclude the very voices the PI is attempting to collect, and, due to the small amount, it is unlikely that these payments would trigger tax withholding and reporting for the recipients. Therefore, PIs are not required to obtain paperwork from participants for these payments; however, PIs are still responsible for proper accounting of the funds spent according to University policies. Participants must be informed that the incentive received for their participation may be considered taxable income by the IRS, and it is the research participant’s responsibility to report this income.

$200.01 to $600.00 USD

PIs must track the disbursement of research incentives greater than $200.01 USD while protecting identifiable information from disclosure. If participant names will not be linked to research data, then PIs should track incentive payments via a separate log. See Best Practices section for an example of this type of documentation.

For $600.01 USD or more

If the participant is a US tax resident and can be paid by gift card or cash a completed W-9 form from the participant is required to receive payment. The PI should contact Purchasing.Department@wwu.edu to arrange secure processing. Purchasing will confirm receipt of W-9 with an email to the researcher after which payment can be disbursed to participant. (If a one-time research participant incentive payment is less than $600.01 USD, researchers should NOT obtain a social security number (SSN) from participants as a condition of payment.)

• If the participant is a foreign national: Research participant payments to foreign nationals are automatically subject to 30 percent tax withholding. Participants must document and report such payments on IRS form 1042-S.
• Special Situation: Payments to any non-WWU employee US tax resident totaling $600 USD or more in a calendar year (January-December)
  • To maintain compliance with WWU's 1099 reporting obligations, if a PI reasonably expects that aggregate payments to a non-employee U. S. tax resident will equal or exceed $600 in a calendar year (for example, when the participant is expected to receive twelve separate $50 gift cards over the course of a year-long study) the researcher must obtain a completed W-9 form from the participant and submit it to Purchasing.Department@wwu.edu before December 31 to receive payment.
• Payment to non-US citizens: If a research subject is a non-US citizen, and the anticipated payment to this person will exceed $100, the PI should coordinate with rsp@wwu.edu regarding additional paperwork and withholding processes during study development.
• For international projects: Researchers should consult rsp@wwu.edu about foreign tax implications when beginning to plan participant incentives. 

Best Practices: Protecting Research Participant Data

We strongly recommend the following practices to prevent privacy violations and unnecessary risk to participants.

Sample Tracking for $200.01-600.00 USD Incentives

We recommend the following example tables and practices for tracking participant incentive disbursements from $200.01 to $600.00 USD.

Table A: Participant Name & ID (For PI use only, do NOT disclose)

Table B: Incentive Disbursement Tracker (For audit purposes if requested)

Save information as separate documents on secure WWU server.

Recommended Format: Excel files. Remember, Microsoft 365 is free to all faculty, staff, and students.

For payments to non-WWU employees totaling over $600 per calendar year: Investigators should not attempt to provide tax or visa advice but rather inform participants about any applicable tax rules. This includes telling research participants that WWU will issue a 1099-MISC Form to the participant and the IRS if they receive payments equal to or greater than $600 in a given year.

Use Non-Identifying Titles for Your Project 

If you include a “short title” for research projects or grants on the Request a Research or Survey Participant Incentive eSign form in the "PI comments" section, avoid using titles that that include a study acronym that is searchable on the web or has the condition under study (e.g., GR12346 HIV Study). This prevents the research participant's name from being associated with any information that would reveal something personal about them (e.g., they have HIV because they are in a HIV study).