Payments to Research Participants

Purpose

To provide guidance to Hamilton College researchers (e.g. employees, faculty, and students) on the appropriate methods for handling payments, via cash or gift card, to individuals (whether Hamilton students or not) for their participation in a college-sponsored research study.

Reason for Policy

Research programs involving human subjects often provide an appropriate level of incentive or compensation for the individual’s participation in the study. This policy will aid researchers in understanding how to manage these financial payments, while preserving the College’s responsibilities under Internal Revenue Service reporting rules and regulations.

Policy

Individual payments to research participants in amounts of $100 or less are considered by Hamilton College to be de minimis in nature and do not require a completed form W-9 from the participants. Cumulative de minimis payments exceeding $600, to the same participant, in a calendar year require that the participant complete a form W-9.

De minimis payments are available for citizens and permanent residents but not Nonresident Aliens under any circumstances. For payments other than de minimis payments to research participants, a form W-9 must be obtained from the individual.

Procedures

Research payments of $100 or less:

Payments to research participants of $100 or less may be provided as cash or gift cards from an endowment or operating budget account. Researchers are not required to obtain a form W-9 from the research participant. However, the researcher shall obtain a signed receipt (i.e. email confirmation or signed document) from the individual that indicates the participant’s name and the amount received to reconcile the payments. A research participant who receives a payment over $100 must complete a form W-9.   

Cases of anonymity for payments of $100 or less:

In studies where participant anonymity is important, the researcher is not required to obtain identifiable information, or obtain the participants' signature of consent. The researcher may use College funds and collect receipts without participants’ names or other identifiers. The receipts will serve to document payment of the funds.

Cash and gift card payments

If participants are paid in cash or gift card, the researcher must ask if the participant has already participated in other research studies at Hamilton College for which they received compensation.

If the participant has already participated in other Hamilton College research studies, the researcher should verify that the participant’s total compensation per calendar year from Hamilton College will not exceed $600. If the researcher is aware that the participant will be receiving multiple de minimis payments that may exceed the IRS limit of $600, then it is the researcher’s responsibility to obtain a form W-9 from the participant.

Eligible and non-Eligible Research Participants

U.S. Persons (Citizens, Permanent Residents - Both Employees and Non-Employees)

This policy and payment procedure applies to all U.S. citizens and resident aliens.

Nonresident Alien – The de minimis payment policy does not apply to Nonresident Aliens (NRA).  Payment methods for NRAs are restricted to payment by a check request due to immigration and taxation documentation required by Homeland Security and the Internal Revenue Service. All payments to NRAs must be processed by check request, regardless of the dollar amount.

Research studies conducted outside of the United States

Payments for activities and services that are performed outside of the U.S. are classified as “foreign source” and are not subject to U.S. tax. In this case, participants will be required to complete an Individual Foreign Source Statement prior to receiving payment.