Currently the Internal Revenue Service requires UNLV to report all cumulative payments for service by non-employees in excess of $600.00 in a calendar year.
Any payments to NSHE employee (including student workers) will be reported to the IRS as W-2 wages regardless of the amount paid. This would include payments to research and survey participants. Any payment made to an employee of NSHE will be subject to income tax and other withholdings as applicable. Please contact the Payroll Department if the payment needs to be grossed up to cover appropriate taxes.
Payments made to persons other than US Citizens or Permanent Resident Aliens must follow the policy and procedures set forth in the NSHE Manual "Payments Made to Nonresident Aliens." Under no circumstances should payments be processed to Nonresident Aliens unless it has been approved by the UNLV Nonresident Alien Tax Specialist.
Researchers are encouraged to work closely with the Office of Research Compliance (ORC).
Approval to Conduct the Research
Before participants can be paid (regardless of the funding source), the research and payments must be approved by the Institutional Review Board (IRB) for Human Subjects.
Limit on Single Cash Payments to Individuals
Unless specifically approved by the IRB, single cash payments to individuals may not exceed $50.00.
Payments using a UNLV Procurement Card
Using a UNLV Procurement Card to purchase goods or gift cards as compensation for research subjects is not allowed.
Payments via University Check
Payments via University check are allowable but do to present confidentiality issues, consult the Office of Research Compliance if you anticipate payments to human subjects via University check.
Payments to NSHE Employees
Any payments to subjects who are NSHE employees (including student workers) must be reported to the IRS as W-2 Wages, regardless of the amount paid. A supplemental compensation form must be submitted to Payroll for all payments to NSHE employees. Consult the Office of Research Compliance if you anticipate payments to NSHE employees.
Payments to Non-Resident Foreign Nationals
There are various tax and NSHE policy issues that must be addressed regarding payments to known non-resident foreign nationals (including foreign students). Consult the Office of Research Compliance for further information.
Using Non-Cash Items as Subject Compensation
The IRS considers gift cards/certificates to be cash equivalent, thus the same tax issues apply to these as with more traditional payment methods. Gift cards/certificates must be treated like cash. Consult the Office of Research Compliance for further information on tangible items of small value and gift cards/certificates.
The entire policy can be obtained from the website of the Office of Research Compliance.
To obtain cash for direct payment to research subjects by the researcher:
- After protocol approval by the IRB and coordination with ORC, prepare a payment voucher (PV), for the total amount required, payable to the principle investigator. The following must be attached to the PV.
- A copy of the IRB approval letter.
- A schedule of planned subject payments (attached or included on the PV).
- The PV must be signed by someone authorized to sign on the account.
- If the PI is signing as the account authority, a Chair or Dean must also sign the payment voucher.
- Submit the complete PV package to the Office of Research Compliance (ORC) for review and approval a minimum of 12 working days prior to the date the funds are required.
- ORC will submit the PV package to Accounts Payable for payment within 2 working days after receipt.
- Accounts Payable will issue a check to the PI within 10 working days after receipt.
- Accounts Payable will call the researcher when the check is ready for pick-up in Accounts Payable. Please indicate on the PV what phone number to call for pick-up.
- The "Affidavit" will be attached to the check and must be signed by the PI before it will be released from Accounts Payable. The PI must personally come to pick up the check.
Reconciliation of the Payment Voucher
- After the subject payments have been made the PV must be reconciled with the "Research Subject Payment Record" (RSPR).
- Submit the RSPR to the Office or Research Compliance as soon as possible.
- ORC will send the RSPR to Accounts Payable to reconcile and close out the PV.