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Human Research Subjects

Accounts Payable Procedures

As provided in BPPM 2:250, the University treats all research projects involving human subjects as confidential whether or not there is a specific external requirement to do so.  To ensure confidentiality, follow the procedures below when making payments related to participants.

Subject Payments Made Directly To Participants on Non-PO Vouchers

1.                  A Social Security number is required for vendor set up to enable proper tax reporting.  (Please contact Kyle Newell in Accounting Services regarding any exceptions to this policy.)

 2.                  Use CX442 MoCode and 742000 Account. 

3.                  Attach a note to the voucher that includes the departmental mocode/account, a contact person, and what the payment is for (example: “subject payment”).   We will remove the note before microfilming.  Accounting Services will do a transfer from your chartfield string and send you the journal number.

4.                  In the invoice description field on the non-po voucher assign a number that represents the participant to the department. Perhaps if you have a participant number for them already you can use that.  Do not use a description that identifies who the subject is or what they are being paid for.

5.                  On the non-PO voucher do not fill in the line description.

6.                  The comment section should say "Documentation on file in the department."  The department is responsible for keeping all records on file for 5 years or longer because on a grant the documentation must be kept for 3 years after the date of the final report to the agency.

7.                  Provide a letter from the chair (see below).

Recap:  If you think about what shows in the system when you do a voucher and that backup is microfilmed, that helps you figure out what to do.  You don’t want identifying information in either place.

 Reimbursements to Subjects for Mileage etc., on a Non-PO Voucher

Vouchers for subject reimbursement are basically the same as the direct payment to the subject, except that a Social Security number is not required.

  1. A SS number is not required for a reimbursement. 
  1. Use the CX442 MoCode and 742000 Account.
  1. Your departmental MoCode/Account, what the payment is for (example: “mileage”) should be put on a note attached to the voucher, which we can take off before microfilming.  Accounting Services will do a transfer from your chartfield string and send you the journal number.
  1. In the invoice description field on the non-PO voucher assign a number that represents the participant to the department. Perhaps if you have a participant number for them already you can use that.  Do not use a description that identifies who the subject is or what they are being paid for.
  1. On a non-po voucher the line description should not be filled in.
  1. The comment section should say "Documentation on file in the department."  The department is responsible for keeping all records on file for 5 years or longer because on a grant the documentation must be kept for 3 years after the date of the final report to the agency.
  1. Provide a letter from the chair (see below).

Vendor request for subject payment reimbursements:  Since a SS number is normally required when setting up an individual for payment, please indicate on the voucher create form, “Payment is not taxable.” 

Paying Expenses on a Non-PO Voucher Associated With a Subject 

Examples might be a hotel or rental car that are direct billed to the University, but the receipt or folio is in the subject’s name.

1.      No reference to the subject should be put on the voucher.

2.      White-out the subject’s name and or SS number on a copy of the receipt or folio and send with the voucher to Accounting.  The original must retain the subject’s name and be retained in the department’s records.

3.      Use your departmental chartfield string.                

4.      The comment section should say, “Expense for subject participation, additional information on file in the department”.  The department is responsible for keeping the original documentation including who the payment was for, for 5 years or longer because on a grant the documentation must be kept for 3 years after the date of the final report to the agency.

5.      Provide a letter from the chair (see below).

Recap:

When you pay a hotel or rental car directly, you can use the departmental account because you aren't going to put the person's name on the voucher and you are going to white out the name on the attached documentation, so there is no association except in your department. 

Letter from the Chair

On each study involving confidential payments, the department chair needs to submit a letter to Accounting Services that provides the following:

§         He/she is aware that the department is responsible for keeping the required documentation for “Study XYZ" in the department, rather than following the normal University process of sending required documentation to Accounting Services.

§         The ChartField string for the project

§         Who is authorized to sign vouchers for this project

§         The chair’s original signature

A copy of the letter must accompany each voucher (when multiple vouchers for the same study are sent over together, one copy of the letter can be sent).  Accounting Services detaches the letter so it is not filed with the voucher.


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Last updated: July 11, 2005