Business Office - Research Participant Payments

https://policy.wisc.edu/library/UW-3012This information is intended to provide a basic overview of research participant payment methods and policies. A more complete guide to the Payments to Research Participants policies related to Custodian Funds/Cash Advance, Gift Cards & PIR research payments may be found at the following links:

Policy UW-3005: Payments to Research Participants
Policy UW-3012: Custodian Funds Policy
200.2 Temporary Fund Procedure
Policy UW-3027: Gift Card Policy

See the Business Office - School of Human Ecology Contacts for assistance and questions regarding the Research Participant Payments process.

Allowable Methods of Payment to Research or Study Participants WITHOUT Using Custodian funds (Non-IRB Related Research)

• Check
  1. Made via Payment to Individual Report (PIR)
  2. Supported with a completed and signed W-9 form for US Persons
  3. Supported with a completed and signed W8BEN for Nonresident Aliens (NRAs)
     • This is something that should be noted as part of your screening process for participants, as to whether they are a US citizen/Permanent Resident, or not a US citizen (Nonresident Alien), to ensure that they are paid using the appropriate method. 
  4. Contact the Business Office for assistance
• Gift Cards/E-Gift Cards 
  1. Paid with UW P-card
  2. Up to $50
  3. US Persons only
  4. See Business Office -Purchasing Information

Allowable Methods of Payment to Research Participants with REQUIRED IRB Approval Related Research:

All plans to compensate research participants in research studies must receive prior approval or an exemption formally documented from the Institutional Review Board (IRB). Contact Michael Kukula for assistance with Custodian Funds.

The Principal Investigator/Researcher (Custodian) can make payments to research participants via:

• Cash via Custodian fund
  
  1. Paid by the Custodian using a Temporary Fund
  2. Custodian is UW employee
  3. $249 or less
  4. US Persons only

• Gift Cards/E-Gift Cards 
  • Purchasing Card: Gift cards may be purchased as payments to research participants using a UW–Madison purchasing card provided the following requirements are met:
    • Gift cards are purchased in amounts of $50 or less OR up to the amounts provided in related grant agreements. A copy of this documentation supporting the amount of the gift cards purchased must be included with the Gift Card Approval Form when obtaining pre-approval and with the supporting documentation for the purchase.
      • Paid with UW P-card
      • Up to $50
      • US Persons only
      • See Business Office -Purchasing Information

• • Or Custodian Funds: All research participant studies are to be approved or an exemption formally documented and provided by the IRB. Refer to the UW-3012 Custodian Funds Policy and 3012.2 Temporary Fund Procedures for information on using gift cards to pay research participants.
    
    • Paid by the Custodian using a Temporary Fund
    • Custodian is UW employee
    • $249 or less
    • Refer to the Policy UW-3012 Custodian Funds Policy and 200.2 Temporary Fund Procedure for information on using gift cards to pay research participants.

• Check via Custodian Fund
  
  1. Paid by the Custodian using a Replenishable Bank Account
  2. Custodian, Signers, and Reconciler are UW-Madison employees
  3. $249 or less
  4. US Persons only
  5. At least 10 checks will be written per month.
  6. Minimum of two and a maximum of four signers authorized to sign checks
  7. Replenishments are based on checks written
  8. Cash will not be advanced out of the checking account

For check payments of $250 or more to US Persons OR for any dollar amount if participant is a Nonresident Alien (NRA)

1. Made via Payment to Individual Report (PIR)
2. Supported with a completed and signed W-9 form for US Persons
3. Supported with a completed and signed W8BEN for Nonresident Aliens (NRAs)
   • Should be noted as part of screening process for participants, as to whether they are a US citizen/Permanent Resident, or not a US citizen (Nonresident Alien), to ensure that they are paid using the appropriate method. 
4. Not paid with Custodian Funds
5. Contact the Business Office for assistance

Types of Custodian Funds: Temporary Funds

Payments to research participants at SoHE are generally processed using a Temporary Fund, which is used to pay research participants when a research study will be for less than 1 year. Options for payment include cash or gift cards.

• Temporary Funds are open for 3 months or less, and then closed after 3 months or when all payments have been made, whichever comes first. If funds are needed to pay research participants beyond three months but less than one year, then additional Temporary Funds would need to be opened every three months upon the expiration of the previous Temporary Fund, depending on the needs of the research study.
• Each payment must be $249 or less.
• The Custodian must be a UW-Madison employee, and is responsible for monitoring the Custodian Fund and distributing the participant payments.
• Important Policy Notes on Temporary Funds:

  - A UW p-card cannot be used to purchase gift cards for IRB-related research participant payments under a Custodian Fund. The Custodian must use the funds provided to them as part of the Custodian Fund request in order to purchase any gift cards related to these payments.

  - All payments of $250 or more to any participant must be processed through the Payment to Individual Report (PIR) process with Accounts Payable and supported with a completed and signed W-9 form, rather than using the Temporary Fund for payment. If PIRs are needed for payments to any participants, please contact the Business Office

• If any participants are Nonresident Aliens (NRAs), then regardless of the dollar amount, their payments must be processed on a Payment to Individual Report (PIR) rather than through the Custodian Funds process. This is due to the immigration and taxation documentation associated with payments to NRA’s as imposed by Homeland Security and the Internal Revenue Service (IRS). This is something that should be noted as part of the screening process, to ensure that they are paid using the appropriate method.  For NRA (non US citizen) participant payments, contact the Business Office
• The participant(s) will receive a check. For more on this: Policy UW-3005: Payments to Research Participants
• The following steps represent the overall process and life cycle of a Temporary Fund:
  1. The Custodian/Researcher contacts the SoHE Business Office (Michael Kukula) to request a Custodian Fund. 
  2. The Business Office helps prepare the forms needed to request the funds from the campus Cash Management office for the study on behalf of the Custodian/Researcher. (These include Custodian Fund Request, Agreement, and Budget forms.) The forms will include justification on the purpose of the study and how it is linked to the project, as well as start/end dates and budget information.
  3. If 133 or 144 funds will be used to purchase gift cards, the Custodian or Business Office needs to obtain written approval from Research and Sponsored Programs (RSP).
  4. The Business Office verifies information and sends the original forms to the campus Cash Management Office (cstdnfnd@bussvc.wisc.edu).
  5. The Custodian receives the requested funds from the campus Cash Management office in the form of a check, uses the funds to make the payments, while maintaining the security of cash and/or gift cards.
  6. The Custodian maintains a research participant log as the payments are distributed.
  7. The Custodian turns in the HIPAA compliant participant log to the Business Office (Michael Kukula), who helps prepare the Custodian Fund Accounting form to account for the payments that were made. The accounting is due to the campus Cash Management office within a month of the end date of the 3 month period listed on the Request form.
     1. If not all funds were used, the Custodian will write a personal check payable to “UW-Madison” to pay back the unused amount. 
     2. If the payments exceeded the requested amount, then the UW will reimburse the Custodian for the difference via check.

Types of Custodian Funds: Replenishable Checking Accounts

For studies lasting 1 year or longer, a Replenishable Checking Account is used. Payment is made by check.

1. To open and maintain this type of account, a minimum of ten checks per month are to be written. 
2. The following roles must be assigned for Replenishable Checking Accounts: 
   1. Custodian - A UW-Madison employee who is responsible for monitoring the custodian fund.
   2. Signer(s) - UW-Madison employee(s) responsible for writing and signing checks to the appropriate recipient, and ensuring all checks are logged and accounted for. A minimum of two and a maximum of four Signers are required.
   3. Reconciler - A UW-Madison employee who is responsible for performing reconciliations and if necessary, replenishments.
3. Accounts must be fully reconciled on a monthly basis as of month end. The purpose of the reconciliation is to agree the US Bank statement to the account’s check log/check register. Only checking account activity in the current month being reconciled should be included in the reconciliation. 
4. Any discrepancies between the two must be researched and reconciled. Please notify Cash Management via cstdnfnd@bussvc.wisc.edu if any transactions are found on your bank statement that appear to be incorrect, so that the issue may be researched and resolved with US Bank. Also, all stop-payments issued in SinglePoint for stale-dated checks (older than 90 days) must be set for 24 months. Use the drop down to select 24 months, since the system defaults to six months.
5. Replenishable Checking Accounts require Memorandums of Understanding (MOUs) that outline the responsibilities and duties for each role associated with the Custodian Fund type, and are updated annually or when there is a change in any role. 
6. A US Bank Signature Card must be submitted when the account is opened and each time there is a change in the signer(s). In addition to the US Bank Signature Card, an updated MOU must also be submitted for a change in the Signer(s). Replenishable Checking