What are Human Subject Payments?
University research projects may require the participation of human subjects (also known as research participants). Often, these individuals receive payments or incentives–in the form of cash, checks or non-cash items–for their participation. Principal Investigators (PIs) and other faculty/staff members who are conducting sponsor funded research or internally funded research are responsible for ensuring that subjects are eligible to receive payments and ensuring that the payment process is appropriate. Compensation or payment to research participants for participation in studies is not considered a benefit. Rather, it should be considered compensation for time and inconvenience. The amount and schedule of all payments should be presented to the UM Institutional Review Board (IRB) at the time of initial review.
More information regarding the IRB process, including forms for establishing MOUs for paying participants, can be found on the IRB website at http://www.umresearch.umd.edu/RCO/New/index.html.
What costs are Human Subject Payments?
Generally, Human Subject Payments include cash, checks, gift cards, gift giveaways, food, drawings, etc. given to participants in research that are consistent with the approved IRB protocol. These payments/incentives must be directly related to research activities. Budget justifications should include correlation between the payment and the research activity.
- Providing cash or cash equivalents to participants for their time spent on a particular research survey, activity, etc.;
- Stuffed animals given to children for their completion of child-based research activities;
- Pizza for focus groups or long-duration research activities; or
Being entered in a raffle upon completion of a survey.
What costs are not Human Subject Payments?
Human Subject Payments do not include costs that would fall under Participant Support Costs (PSC) defined by 2 CFR 200.75, more information on PSC can be found here: https://ora.umd.edu/resources/participant-cost-guidance.
Budgeting Human Subject Payments and F&A?
Payments for human subjects should be budgeted either to Object Code 3130 – Research Study Payments (cash payments) or 3135 – Research Study Participant Payments (non-monetary payments).
Human Subject Payments shall be treated as Other Direct Costs in the budget and the full F&A rate is applicable.