Research Participation Remuneration Standard Operating Procedure

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SOP #: 
FIN 406.001 PR
Executive Owner: 
Research Officer
This SOP applies to all employees and agents of AdventHealth University (AHU) conducting human subject research.
This SOP describes procedure and internal controls related to the IRS tax reporting obligations and data-security protocols when making Monetary Remuneration to human subject research at AHU. AHU is responsible for complying with IRS tracking and reporting requirements for all payments which fall under the reporting regulation and CWF 85.5 Federal Reporting Information Returns - Form 1099 Policy. Individuals conducting AHU research studies that compensate human subjects must collect and document all personal information necessary to comply with IRS tax-reporting regulations. The personal information AHU collects in order to comply with IRS regulations is confidential, and AHU has an obligation to protect it.

Process required by Federal Regulations and AHU policies governing human subject research.

  1. If the research involves intervention or interaction with human subjects or obtains identifiable data about them, the Institutional Review Board (IRB) must have reviewed and approved the research process before the study may start. 
  2. IRB review is required for all human subject research; regardless of funding source. This SOP assumes that the Principal Investigator (PI) or researcher has obtained IRB approval.
  3. The IRB is responsible for the protection of the rights and welfare of participants in human subject research. All proposed Monetary Remuneration, including all amendments, to human subject research must be reviewed and must be approved by the IRB prior to implementation.
  4. The informed consent document (ICD) for all studies that involve Monetary Remuneration shall disclose the IRS compliance requirements in a manner approved by the IRB.

Internal Revenue Services (IRS) Reporting Requirements 

  1. The IRS treats human subject Monetary Remuneration, whether cash, check, bank card, gift card/certificate or in-kind items (books, DVDs, etc.) as taxable income to the recipient. This means the recipient is supposed to report the payment when he or she files a personal tax return at the end of the year. As the payer, AHU must follow IRS regulations. The tax treatment of human subject payments depends on the amount paid, the recipient’s tax status, and whether the study takes place inside or outside the U.S.
  2. Reporting: when AdventHealth System exceeds the threshold in service payments to a US tax resident during the calendar year, then a Form 1099 is issued to the recipient to report the payments to the IRS. AHU will follow IRS regulations when making payments to foreign nationals.
  3. Research remuneration is not guaranteed until final clearance from the Business Office.  It is recommended that the research or data collection begins after receiving remuneration clearance.
  4. The following information must be submitted by the researchers to the Business Office via email to and for research participants that have signed the consent form.  The Grants Manager ( must be copied on all grant-funded research remuneration expenses (including honorariums) for grant expense recording and grant reimbursement to the department.
    • For all AdventHealth/AdventHealth University Employees:
      1. Legal name (as it appears on employee record)
      2. Employee ID (as listed on employee paycheck)
      3. Type of remuneration 
      4. Amount of remuneration  
      5. Date of remuneration
    • For Non AdventHealth/AdventHealth University Employees:
      1. Legal name 
      2. Type of remuneration
      3. Amount of remuneration
      4. Date of remuneration
      5. Request Form W-9, ICQ, and Fillalbe PDF invoice which researchers will share with the participants
        1. Participants then submit the form W-9, ICQ, and the fillable PDF Invoice to the Secure Link
        2. PI or researchers should not release non-employee gift cards until they have confirmed with the Business Office receipt of the non-employee required forms.
  5. Tina and/or Marissa will let the PI or researcher know if the participant has been cleared to receive the remuneration.

Grant Tracking for Remuneration

  1. Gift cards need to be purchased out-of-pocket by PI/Faculty member and an Expense Report submitted (per AHU signature policy) including the purchase receipt. The PI/Faculty member will need to provide gift card receipt evidence to the Grants Manager ( prior to Expense Report payment processing.
  2. Gift card receipt evidence may include email confirmations or a signed/initialed and dated list from individuals who received gift cards.
  3. Honorarium - The PI must submit a payment request to the Business Office via email to and  The Grants Manager ( must be copied for grant expense recording and grant reimbursement to the department.  The IRS Reporting Requirement, as noted in number 4 above, must be followed for honorarium payments.

Drawings of Chance 

  1. Drawings of chance (e.g., raffle) should not be used for research remuneration. Please note any remuneration should be uniformly provided to all research participants.

Human subject: as defined according to 45 CFR 46 means a living individual about whom an investigator (whether professional or student) conducting research: (i) Obtains information or biospecimens through intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimens; or (ii) Obtains, uses, studies, analyzes, or generates identifiable private information or identifiable biospecimens.

Monetary Remuneration: Cash equivalent payment options such as cash, gift cards, vouchers, honorarium, etc.

Non-monetary Remuneration: Gifts, promotional items, other tangible items, etc.

Reimbursement: Reimbursement is the act of compensating someone for an out-of-pocket expense by giving them an amount of money equal to what was spent.

Remuneration: Payment including Reimbursement, which may be monetary or non-monetary, for participation in research.


CommitteeDate VotedMinutes Code
Strategic and Operational PlanningWednesday, May 26, 202121:08
President's CouncilMonday, October 18, 202121:100
Approved by: 
Approval Date: 
Thursday, July 20, 2023
Effective Date: 
Monday, October 18, 2021
Review Date: 
Thursday, July 20, 2023