HSP Study Fund Management

Directive Statement

Human Subject Payment study funds must be safeguarded against theft or misuse.  In addition:

• HSP study funds must be spent appropriately and in accordance with UF policy
• Records must be maintained for study funds
• Payment activity must be reconciled

Reason for Directive

Treasury Management is responsible for the stewardship of the University’s cash and investments, including HSP study funds.  This directive provides assurance that payments will be well-safeguarded, appropriately managed, and properly used.

Who Must Comply?

All University departments.

Procedures

Securing the HSP Study Fund

The Custodian is responsible for safeguarding the payments provided (cash, prepaid VISA cards both loaded/unloaded, and/or gift cards) against theft or misuse.  HSP Study Fund Requests (SFR) must be modified and approved by the Department Approver for changes to the location or Custodian of the HSP Study Fund.  Until the custodianship has been transferred and approved by the Department Approver, the Custodian will continue to be held responsible for the HSP Study Fund.

The Custodian must safeguard the HSP Study Fund:

1. Keep the study funds physically safe, such as using a lockbox kept in a locked drawer or cabinet
2. Limit the number of people with direct access to the payments
3. Keep any key or code combination for the lockbox in a secure place that is not accessible to anyone who does not have authorized access to the HSP Study Fund
4. The key or combination code must change when there are any staff changes involving those with authorized use of the key or access code
5. HSP Study Funds should never be left unattended or unsecured

Commingling of HSP Study Funds

Payments for multiple studies should never be commingled

1. HSP Study Funds must be kept physically separate from any other funds, including payment types for any other HSP Study Fund Request, and separate from any other department or personal money
2. Funds may never be deposited into a personal bank account – even temporarily – for any reason
3. If a Custodian has more than one HSP Study Fund, there should be separate lockboxes or other storage for each HSP Study Fund
4. Custodians are not allowed to “supplement” one HSP Study Fund with payments from another – that is considered commingling of funds

Reconciling the HSP Study Fund

The HSP Study Fund should be reconciled by comparing the amount of payments on hand with logged payments.

1. The HSP Study Fund should be reconciled at least once a month
2. Someone independent of the Custodian should perform the reconciliation
3. The principal investigator (PI) should compare research stipend cash receipts with the HSP payment log and confirm the appropriate persons were paid and paid the correct amount
4. Management will review and approve all HSP Study Fund reconciliations for accuracy
5. Management review and approval will be based on verification that all payments are accurately recorded and are reflected in myUFL (UF’s official accounting record) and HSP
6. Retain the monthly reconciliations and payment records for the current and previous fiscal year – this is required for auditing purposes

Theft or Loss

Any discrepancies in the HSP Study Fund payments must be investigated and resolved.

1. Notify Treasury Management in the case of any discrepancy or loss
2. If there is any suspicion of theft, immediately notify both the University Police Department (392-1111) and Treasury Management (392-9057)

Definitions

Human Subject

According to Federal Regulation 45 CFR 46 102.f, a human subject means a living individual about whom an investigator conducting research obtains:

• Data through intervention or interaction with the individual
• Identifiable private information

Examples of human subjects are a person who becomes a participant in research, data obtained through medical records, data obtained through surveys and data obtained from observation. [Back to Top]

Last Reviewed

01/31/2020: reviewed content

Resources

Cash Fund Management

Institutional Review Boards (IRB)

Division of Sponsored Programs (DSP)

Contracts & Grants (C&G)

Training

TRM200 – Explaining UF Cash/Check Controls

PRO303 – Internal Controls at UF

PRV800 – HIPAA General Awareness

PRV804 – Protecting Social Security Numbers

RSH320 – Human Subject Payment

Contacts

Treasury Management: (352) 392-9057

treasury-HSP@admin.ufl.edu

Contracts & Grants: (352) 392-1235

Disbursements: (352) 392-1241

University Police Department: (352) 392-1111

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