Making and Recording RPP Payments

Directive Statement

Research Participant Payments must be spent appropriately in accordance with University of Florida policy, the terms of a grant (if applicable) and Institutional Review Board (IRB) study protocol terms and conditions.  Funds are to be used exclusively to pay research participants and may not be used to pay for other goods or services provided to the University of Florida.  All Research Participant Payments must be coordinated through the Research Participant Payment (RPP) program administered by Cost Analysis.

Nonresident aliens must be paid through Payroll Services, and not through the RPP module.

Reason for Directive

Enables reliable IRS reporting and improves tracking of participant payments. Reduces the need to maintain sensitive data at the department level since the data is encrypted in the RPP module. Non-compliance with the payment policies of the University of Florida, grant terms, and IRB study protocol terms and conditions can have serious consequences.  The University of Florida is subject to IRS penalties and fines for failure to file correct 1099 MISC tax information.

Who Must Comply?

All University departments.

Procedures

Payments to Research Participants

Prior to making any payment, the Custodian must ensure that the payment is made in accordance with the grant terms (if applicable) and the Institutional Review Boards (IRB) study protocol terms and conditions.

Research Participant Payments to participants of research or survey projects (including University of Florida employee participants) may be made with a prepaid bank debit card or gift card.  These cash equivalent payments are considered taxable income and will result in the issuance of an IRS Form 1099-MISC if the participant receives $600.00 or more in a calendar year.

Payments to NonResident Aliens

Payments to Foreign Nationals/Nonresident Aliens for participation in research studies must be processed through Payroll Services, as many factors are involved when determining work eligibility of NRA individuals and we rely on the analysis of qualified persons that have the expertise within the tax arena.  There can be very serious consequences for non-compliance not only at an institutional level but also for the individual, i.e. IRS penalties and fines, the 20-hour rule (for those participating here in the U.S.) should be considered and the fact that some visa types (work-dependent visas, usually) will not permit the individual to receive income outside of their employment, including as a study participant.

Recording RPP Study Fund Payments

The Custodian must ensure the following:

1. All research stipends paid in person must be substantiated with a recipient signature
2. Mailed payments should be substantiated by a log signed by two people
3. A “check-out” log should be used for payments provided to someone other than the Custodian, for later distribution to participants, or that are taken off-site (including to a lab in another building or off campus)
4. Collect and record the Social Security Number (SSN), name, and address of participants in the payment log if required

The SSN is required unless the study will pay participants $200 or less in a calendar year.

Last Reviewed

07/31/2021: reviewed content

Resources

Contracts & Grants (C&G)

Division of Sponsored Programs (DSP)

Institutional Review Boards (IRB)

Requirements for Payments to Foreign Nationals or Nonresident Aliens

Training

PRV800 – HIPAA General Awareness

PRV804 – Protecting Social Security Numbers

RSH320 – Human Subject Payment

Contacts

Cost Analysis: (352) 392-5778

hsp@admin.ufl.edu

Disbursements: (352) 392-1241

Contracts & Grants: (352) 392-1235

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