Making and Recording RPP Payments

Directive Statement

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 (if applicable). Funds are to be used exclusively to pay participants and may not be used to pay for other goods or services provided to the University of Florida.  All 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 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 (if applicable).

Payments made to participants of research, incentive, or survey projects (including University of Florida employee participants) may be made with a Zelle electronic transaction, prepaid bank debit card, or gift card.

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

Receipt Requirements for Payment Types

1. Loaded gift card or cash type payments, must be substantiated with a receipt signature.
2. For electronic gift cards –
   • If delivered via email, the receipt is the sent email file.
   • If delivered in person, must be substantiated with a receipt signature.
3. All Visa Debit or Zell Payment types, the receipt is the banking file that is sent to load these card types.  No signature is required from the participant for these payment methods.

Other Custodian Requirements for Payment

1. Check-Out Logs
   1. If the any plastic payment types are taken off-site, meaning away from the address that is on file in the RPP system as the location of the payment types,
   2. If the payments are being delivered by someone other than the Custodian
   3. It is always recommended that if you are in charge of a study that has multiple locations, that each location has their own RPP study Fund number in order to track those locations in the RPP system with an updated address.
2. Collect and record the Social Security Number (SN), name and address of participants if the payment log if the payment for a participant is more than $199 in a calendar year.
3. Zelle – For ZELLE payments, collect required phone numbers or email address and record manually in the payment log – do not copy and paste.  This is to assist with preventing any errors because once the payment has been transmitted to the bank, it is an immediate financial transaction.
4. Visa Debit Cards – For Visa Debit Card payments, the physical address is required for the participant, not the PO box OR Criser Hall address.  This is because it is required by banking regulations.  In addition, these cards will expire in three years.  If they do, and the participant has a balance remaining the bank will issue a new card and mail to the participant to the address on the bank’s files.  If a PO box or Crise Hall, it will be delivered to our area at which time you will need to attempt to contact the participant to deliver the card to them.  In addition, if there is any address change with a participant, you must notify our office if they have this card type, otherwise the bank will maintain the original address on file.

The SSN is required unless the study will pay participants $199 or less in a calendar year.

Last Reviewed

Last reviewed on 06/28/2024

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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