Paying Human Subjects Clinical Neuroscience Administrative Center (CNC) https://hub.med.umn.edu/administrative-services/administrative-centers/cnc

Paying Human Subjects Four common options: Gift Card Cash via Cash Advance mechanism Check issued by U of MN (Single Payment Voucher) Goods (t-shirt , mug, Xbox) UMN Policy: https://policy.umn.edu/finance/humansubjects UMN Procedure: http://policy.umn.edu/finance/humansubjects-proc01 Items with this symbol have a corresponding handout

Paying Human Subjects Key best practices Standard justification is “Details are on file in the department and available for audit” – Confidentiality of subjects is paramount Maintain payment records within the appropriate unit A log book or other systematic recording keeping process must be utilized and available for audit by someone unfamiliar with project particulars. Recipient must sign for every payment except non-cash payments (e.g. coffee mug) under $10 Individuals receiving more than $600 per calendar year from all University sources must be reported to the tax desk

Check issued by U of MN Key best practices Standard justification is “Details are on file in the department and available for audit” – Confidentiality of subjects is paramount Maintain payment records within the appropriate unit A log book or other systematic recording keeping process must be utilized and available for audit by someone unfamiliar with project particulars. Recipient must sign for every payment except non-cash payments (e.g. coffee mug) under $10 Individuals receiving more than $600 per calendar year from all University sources must be reported to the tax desk

Types of Gift Cards Type Order via Fees Expiration Notes VISA UM Office of Investments & Banking oib@umn.edu No setup fee After 12 months: $2.50 per month maintenance fee until used. Date on card OR balance is zero. Best Practice Should not purchase more than what can be distributed within 2 months Use form UM1798 Store-issued e.g. Target.com or giftcards@ walmart.com n/a Often preferred by subjects. Best to purchase with Pcard. Should not purchase more than what can be used in 6 months.

Gift Card Summary Research Subjects Employees Students Non-Employees Maximum $$ IRB Approval < $100 recommended n/a Considerations IRB approval required Return unused cards Do not commingle purchases Pass public scrutiny All employees considered Taxable Yes 1099 if annual over $600 to employee if > $100 Reconcile after cards issues Reportable to Finance & Central Payroll Financial Aid if > $100 Retain Records No

Gift Card Security Gift Cards are a relatively easy and desirable target for theft! Best Practices: Secure their physical location A lockbox inside a locked cabinet inside a locked office Monitor key access  many thefts are inside jobs Keep track of all card numbers/identifiers Having records that contain the serial number and date of purchase for each card makes it easier to cancel and replace the specific cards that have been stolen Review stock regularly. It’s easy to notice when ALL the cards go missing but it’s much harder to notice when only a few disappear

Cash Advances for Human Subjects Policy: https://policy.umn.edu/finance/cashadvances Procedures: https://policy.umn.edu/finance/cashadvances-proc01 Key Policy / Practice Elements Requests must be over $100 and made no more than 30 days before needed Deposited into requestor’s bank account Requestor is responsible for custody of funds Requests always end within 6 months Must be reconciled within 60 days after scheduled end date

Life Cycle of Human Subject Payments Make a request for resources Obtain the resources Pay subjects Maintain payment log/records Reconciling subject payments

Requesting Resources Step Role Duty 1 Study Coordinator   Duty 1 Study Coordinator Confirm that IRB approval for human subjects has been obtained. Determine the type of gift card appropriate for the subjects. Determine total amount of gift cards that are needed to pay subjects over the maximum time frame noted above. --or-- Determine total amount of cash needed to pay subjects over the maximum time frame of six months. Prepare the Gift Card Request Form and submit it to a preparer. Prepare the Cash Advance Request Form and submit it to a preparer. 2 Preparer If Visa Gift Cards have been requested, fill out the Visa Gift Card Request Form. Obtain required signatures and submit it to CNC. If store gift cards have been requested, arrange purchase with a PCard holder. Complete a Travel Authorization (TA) and Cash Advance (CA) in EFS. If applicable, the description should include the project number. 3 CNC Approver Confirm that the expense is appropriate for the funding source and that there is an active IRB approved protocol.

Maintaining Payment Records Step Role   Duty 1 Study Coordinator Use either the CNC Gift Card Reconciliation Log or CNC Cash Advance Reconciliation Log to track subject payments given. Recipients must sign acknowledging receipt of payment. (Payments less than $10 do not require the signature of the recipient). Gift cards to be completely disbursed within the appropriate time frame: * 6 months for store cards * 2 months for UMN issued VISA cards An extension may be granted if only a small amount of cards remain. Work with CNC staff to process a request for extension. --or-- CAs must be reconciled within 60 days after the end date of the advance. In circumstances where only a small amount remains you can request an extension. To do so, contact your preparer. 2 Preparer Email Disbursement Services disbsvcs@umn.edu for Cash Advance extensions

Reconciling Subject Payments Step Role   Duty 1 Study Coordinator Reconciliation is expected to occur immediately upon the last gift card being disbursed, all cash being spent, or at the end of the 2/6 month timeframe, whichever is first. If there is unused cash, the requestor must submit a check payable to the “Regents of the UofM” for the amount remaining. Note the CA# on the check and hand delivered it to CNC. --or-- Unused gift cards may be 1) charged to another project or 2) the coordinator/PI may submit a personal check payable to the “Regents of the University of Minnesota” for the remaining value and use them for personal purchases. Work with CNC staff to determine the best solution. Black out the signature portion of the CNC Gift Card or Cash Advance Reconciliation Log, ensure the total payments (to include check, if applicable) match the total purchase amount, and submit it to the Approver.

Reconciling Subject Payments – con’t Step Role   Duty 2 CNC Student If applicable, submit a deposit for the check and email the approver the deposit number. 3 Preparer For Cash Advances only - Create an Expense Report with short description of “CA # Close.” Note the TA, CA and Deposit numbers (if applicable) in the justification. Also include the de-identified log in the attachments. 4 CNC Approver Update the centralized CNC Gift Card & Cash Advance Tracking Sheets with the reconciliation completion date. Attach the reconciliation sheets to the original EFS purchase record.