Participant Support Costs vs Human Subject Payments
Participant Support Costs (PSC)
as defined in 2 CFR 200.75, means direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participants perform no work or services for the project or program other than for their own benefit. A participant is not involved in providing any deliverable to the University or a third party.
Human Subject Payments
are also known as Research Incentives. These payments include cash, checks, gift cards, gift giveaways, food, drawings, etc. given to participants in research that are consistent with the approved IRB protocol. These are incentive payments to encourage individuals to participate in research study and provide private data/information through intervention or interaction. This includes participation in surveys and interviews. These payments/incentives must be directly related to research activities and the budget justifications should include a correlation between the payment and the research activity.
Participant Support Costs
- The Uniform Guidance (2 CRF 200) requires prior approval of the Federal Agency in order to incur PSC under federally sponsored awards.
- The PSC must be specifically allowed by the sponsoring agency.
- F&A costs are not allowed on PSC expenditures
- Rebudgeting from the PSC category into other categories must have prior sponsor approval.
- Any unexpended PSC are returned at award close-out – they cannot be used to offset overexpenditures in other categories.
The PI and his/her project staff should be familiar with the specific requirements set forth by the sponsor, and is expected to insure compliance with those requirements. In addition to the financial restrictions noted above, the PI/department is also required to retain records detailing:
- Criteria by which participants in the program are selected
- Copies of applications of selected participants, with documentation as to how they meet the selection criteria
- List of program participants and documentation of their participation in the program
how to initiate payments
Payment may include stipends, allowances, or reimbursement of expenses. Please reach out to Rochelle Sykes prior to needing the funds disbursed to determine the best method of payment.
Human Subject Payments
- Human Subject Payments shall be treated as Other Direct Costs in the budget
- The full F&A rate is applicable.
how to initiate payments
Incentives for research participants may be in the form of checks, cash, gift cards, gift giveaways, food, drawings, etc. and paid on a grant or other local funds.
Please read the official IRB SOP for Compensation to Research Participants.
For gift cards, departments must process an ePro requisition to the vendor from whom the cards are to be purchased and assign a Custodian. The Custodian must be a full-time benefits eligible employee who will be designated as the responsible party for custody of the cash/cards at all times and are required to maintain a Research Participant Disbursement Log as the cash/cards are distributed. This is usually the PI or another senior personnel member working on the project. All employees involved in distribution of cards must complete cash handling training annually.
At all times the total value of the cash or gift cards being held and the value of the payments on the disbursement log must equal the amount of the Purchase Order.
The Principal Investigator must retain the confidential log at the department level per the record retention requirements of the grant or contract and must make it available for all approved audit purposes. For information about retention requirements for a specific project, please reach out to Rochelle Sykes.
Researchers are advised to work with the university grants office to help facilitate the best method for their award.
Information on gift card processing can be found in the UNT System Procurement Guide (p 66).
Payments to UNT Students
All non-work related payments to university students must be coordinated through Financial Aid (SFAS). An award authorization form must be sent to SFAS for them to capture the payment as an award rather than as payment through gift cards. Please work with Rochelle Sykes to set up the award process.
Payments to UNT Faculty and Staff
Payment to university faculty and staff participating as research subjects represents taxable income to the recipient, regardless of the payment amount or method used and payments are taxable on employee paychecks and subject to taxes.
The Custodian must submit a research participant disbursement log containing the Employee ID, Employee Name, and amount paid to UNT System Tax by emailing at BSC-GA@Untsystem.edu after each event or disbursement date to serve as supporting payment documentation.
Payments to Non-University Employees
Per IRS guidelines, annual payments of $600 or more to non-employees require UNT System to issue a Form 1099 at the end of the calendar year. The Custodian must submit a log with the following information about the participants by sending an encrypted email to UNT System Tax at email@example.com after each event or disbursement date to serve as supporting payment documentation.
- List of participants including:
- SSN (if gift cards amount is $100 or more)
- Mailing Address
- Email or phone number
- Amount of gift card
- Last 4 digits of gift card number
- Signature or initials of recipient acknowledging receipt
- Disburser's name
- Date card was disbursed
The above requirements for Custodians to maintain and submit payment information also apply to the research participants payments administered through third party service providers. Custodians must submit the payment information as instructed above.