For each funded grant project, a unique Petty Cash Fund is established to support the anticipated human subject reimbursement activities. (For ease of management for multiple-year grants, the initial fund can be opened against a non-grant account such as ledger 4 account — if funds allow).
The Principal Investigator should monitor all petty cash expenditures on a regular basis to insure consistency with agency funding requirements and that any variances from the operating budget are identified and addressed. However, staffing resources permitting, it is preferred that the fund custodian be someone other than the PI (but must be a full-time salaried officer or staff employee).
Establishing, increasing, and closing of funds should be accomplished as all other Petty Cash Funds with the following additional requirements:
The fund initiator is required to justify the base amount of the fund in the "Reason for the Fund" section of the Petty Cash Administration Form, regardless of funding source, as determined by the following:
• Projected subject volume per week/month
• Projected reimbursement amount per subject
• Projected time lag for fund reimbursement
The fund initiator should also provide proof of IRB approval on the PC Administration Form.
At the conclusion of the human research study, the Petty Cash Fund must be closed.
See Petty Cash in ARC Job Aid for more information.
For human subject payments or reimbursements, the study coordinator should distribute the cash to the subject and prepare a receipt or log for the subject to sign. Amounts may exceed $80 (please see Controller's Office for further guidance) but such amounts should be pre-approved as part of the fund creation process. All receipts/logs for human subjects need to be HIPAA compliant. (3-part HIPPA compliant receipts are available from the IRB - and are required for use at CUMC.) Receipts or logs must include the following information:
•Date of payment
•Protocol name or #
•Check box for "subject reimbursement" or "subject compensation"
•Name and signature of study coordinator
•Name of study subject (*)
•Signature of study subject (*)
•Replenishment Check Request #
(*) Under HIPAA guideline, these items are considered confidential subject information and will not be included on any receipt or log submitted to Accounts Payable. It is customary to give some type of receipt to the subject. Information identifying human subjects being paid should be kept at the research site as part of the permanent confidential records (and never sent to Accounts Payable), According to IRS regulations, annual compensation (subject incentives) to study subjects of $600 or greater is considered taxable compensation and reportable to the IRS. Plans for protecting patient confidentiality in these cases will be reviewed by the IRB as part of the protocol/informed consent approval process.
If a series of subject payments result in total compensation greater than $600 (not including travel or meal reimbursements), the departmental administrator will:
• Prepare a W-9 Form providing the subject's name, address, and social security number and submit it to Accounts Payable (see 1099 Section for information on submission of W-9 forms). Attach to the W-9 a memorandum outlining the total amount the subject is expected to receive in the calendar year.
•An IRS 1099 Form will be issued to the recipient.
If a given payment is greater than $600, the departmental administrator will:
• Submit a completed W-9 Form to Accounts Payable (providing the subject’s name, address and social security number), plus process a regular check request for the amount of the check.
• An IRS 1099 Form will be issued to the recipient.
The informed consent document, reinforced by the informed consent process, must clearly iterate the responsibility of the institution to report to the IRS as a taxable income all payments to an individual subject aggregating $600 or more in a calendar year. The IRB must review and approve the informed consent document prior to implementation. The IRB approval number must be provided when opening a new fund.
Internet based studies that require the processing of online payments through a third party vendor must have all compensation transfer arrangements pre-approved by Treasury Operations before any debits are made or any reimbursements are requested.
When using social security numbers (SSN) or when processing online payments through a third party, the University’s policies regarding SSN and identity theft protection must be complied with (refer to the Columbia University Policy Library).
For payments to nonresident aliens, please refer to the AP Foreign Payments site.
See the Petty Cash Policy for further information.
See Petty Cash Custodian Training for more info.