Human subject payments are defined as payments of cash (including cash equivalents/gift cards) or tangible personal property to individuals (subjects) for their participation and time commitment in a clinical trial, survey, or research study.
49er Mart or P-cards: Can be used to purchase any items of tangible personal property, such as pens, books, candy. P-cards can also be used to purchase gift cards.
- Gift cards are considered cash equivalents. If the research administrators will not be checking recipient status (employee v. non-employee), to mitigate risk, gift cards should be limited to $25 or less per individual, per occurrence unless specific recipient tracking requirements are met (see “Classification of recipients” below).
- For gift cards, also refer to the Gift Cards/Gift Certificates, How to Pay guide.
- Separately submit UP 602.11 Appendix B, Reportable Gifts, Awards, & Prizes Documentation Form, to the Tax Office if:
- The recipient is an employee, or
- The recipient is a non-employee and the amount is $600 or greater.
Request a Check/Direct Deposit via an Employee/Student Direct Pay Request (ESDPR) for cash payments to recipients or when a check/direct deposit or other tax reportable item is desired. (Refer to Policy 602.11, Gifts, Awards, and Prizes.) Download an ESDPR form and complete according to the form instructions (link provided below).
- Cash payments must be requested by submitting an ESDPR. This facilitates appropriate review and approval by Financial Services and helps ensure amounts paid are properly tracked for tax reporting purposes. Note that cash payments must be issued directly to the recipient; cash cannot be issued to administrative personnel for further distribution.
- Attach UP 602.11 Appendix B, Reportable Gifts, Awards, & Prizes Documentation Form, to the ESDPR if:
- The recipient is an employee, or
- The recipient is a student and the amount is $600 or greater.
Regardless of the payment method chosen, each college/department is responsible for tracking the total amount of human subject payments that each payee has received during a calendar year unless it is unreasonable or impractical to do so. Use of Appendix C, Gifts, Awards, & Prizes Log Sheet, or a similar tracking sheet, is recommended.
Applicable University Policies:
- Refer to University Policy 602.11, Gifts, Awards, and Prizes, for the full definition of tangible personal property and required tracking for tax reporting purposes. All cash gifts, including gift cards, to employees, regardless of amount, are taxable to the employee and must be reported to the Tax Office. See Appendix A of Policy 602.11.
- Refer to University Policy 601.8, Appropriate Use of University Funds, and related standards to determine permissible fund types for these purchases.
Classification of recipients:
- Employees: If a payment of any amount is made to an employee, the Tax Office must be notified for reporting on the employee’s Form W-2. In addition, the payment will be subject to federal and state income taxes.
- Non-employees: If combined payments to a non-employee total $600 or greater in a calendar year, the Tax Office must be notified for Form 1099 reporting.
- Foreign nationals: Prior to making a payment of any amount to a foreign national/non-U.S. resident, contact the Tax Office, as tax reporting and withholding are required.
- Determining classification of research subjects:
- If the target study population is UNC Charlotte employees, then any cash incentives (including gift cards) are taxable/tax reportable to the recipients as employees, regardless of amount.
- If the target study population is NOT specifically UNC Charlotte employees, nor is it advertised directly to UNC Charlotte employees by themselves, then incentives paid can be considered as unrelated to the recipient's employment at UNC Charlotte. If the research administrators will not be checking recipient status (employee v. non-employee), to mitigate risk, these incentives should be limited to $25 or less. Payments are subject to the non-employee reporting requirements listed above and in Policy 602.11.
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UP 601.8, Appropriate Use of University Funds
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Last updated: 5/02/2018, 7/30/19, 8/5/19