Payments to Participants

 Guidance for investigators on paying research participants

The IRB must ensure that recruitment methods and materials, including payment amount and timing of disbursement to subjects, are not coercive, misleading, or unduly influential. In addition, the IRB expects the informed consent process to provide information that a reasonable person would want to know regarding compensation in the form of payments. Investigators are expected to follow all applicable university policies and other requirements when paying subjects. While the IRB review primarily focuses on the ethical considerations of paying subjects, this webpage provides additional guidance for complying with financial procedures for paying subjects and assuring the informed consent process includes appropriate details when participants receive payments for research participation.

PI Responsibilities:

  • Choose the appropriate payment method. If your study processes payments to participants through ETSU, see FP-8 Sponsored Program Management Policy for the different methods that are allowed.
  • Ensure that your proposed payment plan will not be coercive or present an undue influence on potential participants. The payment must not be contingent upon the participant completing the entire study. The credit for payment must accrue as the study progresses.
  • Clearly explain the following in your submission to the IRB: 1.) the amount of payment; 2.) the proposed method (check, cash, traditional gift card, electronic gift card); 3.) the timing of payments to participants; and 4.) why you think the amount, method, and timing are appropriate.
  • Ensure that your Informed Consent Document (ICD) has the appropriate language before you submit it for IRB review. All information concerning payment, including the amount, method, and schedule, must be included in the informed consent. Place this information in the section entitled "Compensation in the Form of Payments to Participants."
  • If your study is subject to HIPAA, be sure that your HIPAA Authorization lists who the information will be disclosed to for processing and, if applicable, for reporting the payment.
  • Ensure the confidentiality of research participants. Personally identifiable information for receipt of payments for research participation should be gathered in a manner which prevents disclosure of personal information to other research participants, and should be stored securely in accordance with relevant policies.

For studies where payment is processed through ETSU:

Researchers must follow FP-8 Sponsored Program Management Policy and ORSPA Payments to Research Subjects Policy.

Questions about how to comply with ETSU and/or IRS requirements for paying research subjects should be directed to ETSU Financial Services.

  • For studies that anticipate an aggregate payment to a single individual of $600 or more, add this to your ICD:
    "Personal information about me, including my name, address, and social security number, will be released to the University for the purpose of payment and for tax reporting to the Internal Revenue Service (IRS). I understand that ETSU will issue me an IRS Form 1099, listing my payment as reportable income."
  • For studies that anticipate payment via University check, with aggregate payment to a single individual of $100 or more (but less than $600), add this to your ICD:
    "Personal information about me, including my name, address, and social security number, will be released to the University for the purpose of payment and for tax reporting to the Internal Revenue Service (IRS), if necessary."
  • For studies that anticipate payment via University check, with aggregate payment to a single individual of less than $100, add this to your ICD:
    "Personal information about me, including my name and address, will be released to the University for the purpose of payment and for tax reporting the the Internal Revenue Service (IRS), if necessary."
  • For studies that anticipate payment by a method other than check, such as gift cards*, cash, or merchandise, with aggregate payment to a single individual of $100 or more (but less than $600), add this to your ICD:
    "Personal information about me, including my name, address, and social security number will be released to the University for the purpose of payment and for tax reporting to the Internal Revenue Service (IRS), if necessary."
  • For studies that anticipate payment by a method other than check, such as gift cards*, cash, or merchandise, with aggregate payment to a single individual of less than $100, add this to your ICD:
    "You will be asked to sign or initial a form confirming that you received the (insert gift card or cash or merchandise as appropriate). This form will be released to the University for the purpose of payment record-keeping."
  • Per the ETSU payment policies noted above, payments to ETSU employees must be processed through ETSU Payroll to be added to their pay check. Investigators are responsible for consulting with ETSU Financial Services about the process and following it accordingly.

*See exception in the ETSU FP-08 Payments to Research Subjects policy for electronic gift cards when the study is anonymous/confidential.

  • For studies that are subject to HIPAA, add this to Section C of the HIPAA Authorization, "How your protected health information will be used:" 
    "Individuals at East Tennessee State University that are responsible for financial oversight of research including billing and payments."
  • For studies that are subject to HIPAA and payment is through the ETSU Research Corporation, add this to Section C of the HIPAA Authorization, "How your protected health information will be used:"
    "The ETSU Research Corporation"
  • For studies that are subject to HIPAA if aggregate payment for participation is $600 or above, add this to Section C of the HIPAA Authorization, "How your protected health information will be used:"
    "Internal Revenue Service"

For questions about HIPAA compliance and authorization language, please contact the HIPAA Privacy Office.

Please note that the VA has their own requirements; see IRB Policy 16 for information and consult with the VA R&D Office.