Overview: Paying Human Subjects

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Control of Funds

Study administrators assume fiduciary responsibility to ensure proper accounting for funds spent in the study. Adequate controls must be in place for the distribution of the funds and costs must be allocable to the PTA charged.

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Protecting Participants

Human Subjects are protected under California State laws and HIPAA regulations. As a result of these privacy requirements, certain business processes must be followed.

  • Human Subject Expense Requests transactions will not be viewable by anyone but the preparer, approvers, individuals with authority over accounts charged, and authorized central office staff.
  • It should be noted that the first 30 characters of the business purpose of Expense Requests Non-PO Payment transaction will appear in the expenditure reports of the designated project, task and award. It is extremely important that the subject's name NOT be included in the first 30 characters of the business purpose. It is recommended that the statement of business purpose be generic, i.e., "Human Subject Payment." See Resources: Guidelines for Writing a Clear Business Purpose for examples.

The University is aware that many studies are sensitive in nature and information concerning Human Subject participants is confidential. In those instances, the study should not be named in the requisition, but can be referred to by a protocol number or other study identifying number.

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Tax Treatment for Incentives

All Human Subject payments and gifts are considered income to the recipient. See table below for tax treatment relating to specific scenarios.

Important Note:  When tax reporting is required, all confidential data, including Social Security Number or other tax identification and residency information, must be submitted directly by the payee or an authorized agent via the secure Supplier / Payee Request Portal. No confidential information should ever be uploaded as backup documentation with Expense Requests transactions.
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Payment Methods by Incentive and Payee Type

Payments to human subjects or to administrators in order to fund payments or purchase gifts, are initiated within the Expense Requests system, or a Stanford Purchasing Card may be used to purchase gift incentives valued under $200. See table below for various scenarios.

Important Note:  When direct payments to human subjects are requested, all confidential data, including Social Security Number or other tax identification, residency information, and banking information must be submitted directly by the payee or an authorized agent via the secure Supplier / Payee Request Portal. No confidential information should ever be uploaded as backup documentation with Expense Requests transactions.
Payment Methods by Incentive and Payee Type
Incentive / Payee Type Payment Method(s) Required Documentation Taxable?
Monetary, any amount,
paid to Stanford and SLAC employees participating in study for their department or related to their employment		 Stanford Payroll Contact the department HR Manager Yes, as income
Monetary, any amount,
paid to Non-resident alien		 Direct, Non-PO Payment, requested by administrator in Expense Requests, paid directly to Human Subject Payee or authorized agent provides banking, residency and tax info via secure Supplier / Payee Request Portal Yes, 30% Federal Withholding at time of payment. See examples.
Monetary, $200 or more,
paid to legal US residents (except SU and SLAC employees participating for their work or dept)		 Direct, Non-PO Payment, requested by administrator in Expense Requests, paid directly to Human Subject Payee or authorized agent provides banking, residency and tax info via secure Supplier / Payee Request Portal Yes, reported by Stanford via 1099 for every U.S. resident who is paid $600 or more in a calendar year
Monetary, <$200,
paid to legal US residents (except SU and SLAC employees participating for their work or dept)

Direct, Non-PO Payment, requested by administrator in Expense Requests, paid directly to Human Subject


~ OR ~

Payee or authorized agent provides banking, residency and tax info via secure Supplier / Payee Request Portal

Yes, reported by Stanford via 1099 for every U.S. resident who is paid $600 or more in a calendar year
Advance requested by and paid to administrator for cash disbursement to Human Subjects, followed by Expense Report to clear advance Administrators retain a record of the Human Subjects' names, addresses, $ value of the incentive, and the Human Subject's signature evidencing receipt, or optionally complete and retain Human Subject Incentive Certification Form Yes, administrators should alert Payment Services when an individual payee receives multiple incentives totaling $600 or more in a calendar year and Stanford will prepare a 1099
Gifts*, valued <$200
provided to any Human Subjects

• Advance requested by and paid to administrator to purchase gifts followed by Expense Report to clear advance

• Expense report for reimbursement of gift purchase

• Stanford Purchasing Card

Administrators retain a record of the Human Subjects' names, addresses, $ value of the incentive, and the Human Subject's signature evidencing receipt, or optionally complete and retain Human Subject Incentive Certification Form

Upload receipt for gift purchase with Expense Requests transaction,

~ OR ~

Fax receipt when verifying PCard purchase in PCard Module

 Not tax reported

* Non-cash gifts are especially useful for those individuals that may not have Social Security Numbers, non-resident aliens or for studies where a small incentive is appropriate. Non-resident aliens and Stanford or SLAC employees may receive non-cash gifts. Gifts valued at $200 or more are highly discouraged and are subject to tax reporting.


For specific instructions on initiating the various payment methods in the Expense Requests system:

Direct monetary payment to human subject How To Create New Non-PO Payment Request – Single Payee
Direct monetary payment to up to 50 human subjects in one transaction How To Create New Non-PO Payment Request – Multiple Payees
Request cash advance for human subjects incentives, or to purchase non-cash incentives for distribution to human subjects How To Create Advance Request
Request reimbursement and/or clear an advance for domestic human subject incentives How To Create Domestic Expense Report for an SU Payee
Request reimbursement and/or clear an advance for foreign human subject incentives How To Create Foreign Expense Report for an SU Payee
Request reimbursement for domestic travel expenses for a human subject How To Create Domestic Expense Report for a Non-SU Payee (Visitor Reimbursement)
Request reimbursement for foreign travel expenses for a human subject How To Create Foreign Expense Report for a Non-SU Payee (Visitor Reimbursement)
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