Information Related to Payments to Study Subjects
The communication addresses three discrete topics related to payments to study subjects. Additional information on the University policies and procedures for study subject payments is available at the links contained herein.
Payments to Current Research Participants
On September 10, 2018, Accounts Payable issued a memo regarding requirements for all new and updated campus vendors. In the UNC system, study subjects that receive payments for participation and reimbursement are considered an “Outside Party – Individual” and the following supporting documentation is required in order to issue payment:
- Form W-9 (for U.S. persons) or W-8BEN (for non-resident aliens).
- Foreign Vendor Withholding Assessment with supporting documents (for non-resident aliens only)
- Outside Party-Individual Certification form
- Optional: Banking information (ACH Form) – required only if the study subject prefers direct deposit as opposed to being issued a check. This form is NOT MANDATORY for study subjects.
Please note, while the memo noted above does allow for emailing this information with external sources, it has recently been determined that emailing this sensitive information is not permitted. Please do not email to or ask a study subject to email to you any of these completed forms.
How does this affect your current IRB approved studies?
Use of a W-9 or W-8BEN will replace use of the current Social Security Authorization Form studies have been using. The Office of Human Research Ethics (OHRE) is not requiring study teams to submit a modification for active studies if the study has been using the Social Security Authorization Form, but instead, such studies may continue to use the SSN form at this time. In addition, OHRE does not need to review the W-9/W-8BEN or Banking Information (ACH) forms as these are standard forms utilized for business purposes.
OHRE will be adding a checkbox in the IRBIS application that says W-9/W-8BEN, and by selecting this box it would incorporate the appropriate language into the informed consent.
Proposed ICF language for future use:
“Your name, address, and U.S. tax payer identification number (SSN or ITIN) are required to process payments and/or to report taxable income to the IRS. You must complete a W-9 (for U.S. persons) or W-8BEN and the Foreign Vendor Withholding Assessment with supporting documents (for non-resident aliens) in order to receive payment for participation.
U.S. person participants must complete Form W-9 in order to receive payment for participation. If payment by UNC equals or exceeds $600 per calendar year for U.S. persons, UNC will report the amount to the Internal Revenue Service on Form 1099. Nonresident alien participants must complete Form W-8BEN and the Foreign Vendor Withholding Assessment with supporting documents in order to receive payment for participation. Payments to nonresident alien participants may be subject to tax withholding and are generally reported to the Internal Revenue Service on Form 1042-S. This information will not be linked to any of the study data and will only be used for payment purposes.
The W-9 and W-8BEN should be retained by the study team and relevant information contained therein reported to Accounts Payable as provided in the section below titled “Accounts Payable Tax Reporting Obligations for Study Subjects”. The W-9 and W-8BEN must be stored separate from other study related documents and secured in a manner that meets the University’s requirements for storage of “sensitive information.” Please see relevant policies at:
- UNC at Chapel Hill Policy on Information Security
- UNC Security Control Standards
- Information Technology Access Control
- UNC Standard on Information Technology Access Control
- Protected Health Information Policy
- Transmission of PHI and Sensitive Information over External Networks or an Unsecured Medium
- UNC Standard for Transmission of Protected Health Information and Sensitive Information over an External Network or Unsecure Medium
Study subjects who are not U.S. citizens or green card holders are generally nonresident aliens. Nonresident alien study subjects are required to provide the University with different tax forms than U.S. persons and may be subject to tax withholding. For questions regarding nonresident aliens enrolled in studies where payment are anticipated please email email@example.com for additional guidance. Information is also available in Procedure 709.1, Completing Tax Withholding Forms as a Non-Resident Alien Performing Services in the United States. The requisite information must be provided to Accounts Payable in advance of any study payments being made to Non-resident Alien study subjects.
The University is committed to providing an inclusive and welcoming environment. Consistent with these principles and applicable laws, it is the University’s policy not to discriminate on the basis of age, color, disability, gender, gender expression, gender identity, genetic information, national origin, race, religion, sex, sexual orientation or veteran status as consistent with the University’s Policy on Prohibited Discrimination, Harassment and Related Misconduct. No person, on the basis of protected status, shall be excluded from participation in, be denied the benefits of, or be subjected to unlawful discrimination, harassment, or retaliation under any University program or activity.
Accounts Payable Tax Reporting Obligations for Study Subjects
Pursuant to U.S. tax laws, the University is required to issue an IRS Form 1099 to U.S. persons who receive $600 or more from the University during a calendar year. This applies to payments in the aggregate. Accounts Payable is the unit on campus that handles this reporting requirement.
In order for the University to meet its obligations, study teams are required to report to UNC-CH Accounts Payable all U.S. person study subject payments in calendar year 2018 that equal $200 or more. The only exception to this reporting requirement is if your study subjects receive payment via a check or ACH payments from the University. Check payments are already recorded within the University’s system.
For all non-resident alien study subject participants, all payments must be made thru Accounts Payable. This process will require that all documentation be submitted to Accounts Payable in order to set up a unique vendor ID for the non-resident study subject participant. Send documentation and questions to firstname.lastname@example.org.
The deadline for reporting this information to Accounts Payable is 5:00 December 21, 2018.
PLEASE NOTE: The information on the spreadsheet is sensitive and MUST be PASSWORD PROTECTED prior to sending to Accounts Payable. Do not store this spreadsheet or data on your laptop, desktop, or personal device.
Please send the PASSWORD PROTECTED spreadsheet via your UNC device and email account from on campus (UNC-CH’s network) or through a University approved VPN connection only to the following secure mailbox: Research1099@unc.edu. Once you have provided this email to this mailbox, please move the email and attachment from your sent items to archive.
Once the spreadsheet has been emailed, please call Judy LeDoux, Accounts Payable Accountant, Accounts Payable, at (919) 843- 5096 and provide Judy with your name, telephone number in case there are any questions, and the password.