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Human subjects payment policy (interim)

Some researchers offer incentives to human subjects to encourage them to participate in research.  For the purposes of this policy, incentives means any gift or payment given to human subjects participating in a research projectSuch incentives should be of nominal value to avoid the appearance of undue influence on the subjects. 

The Internal Revenue Service (IRS) considers any single incentive (including cash payments, gift cards, property, goods, or services) that has a value of $100 (US dollars) or more to be taxable income that requires withholding and documentation, even for foreign nationals. Recurring incentives given to a single individual that will total $600 USD or more over the course of a calendar year are also subject to withholding and documentation.

All incentive plans must be approved by the Middlebury College Institutional Review Board as part of research-protocol review. The IRB will approve only incentives that comply with federal, state, local, sponsor, and College policies. Researchers must report any deviations from the approved protocol, including changes in the form or amount of incentives, to the IRB. They must also keep original receipts for all items purchased for use as incentives and must note on the receipt what they will be used for. If any individual incentives are valued at $100 USD or more, or if the incentives approved by the IRB will result in any one human subject receiving $600 USD or more during a calendar year,  the researcher must maintain a log of those incentives. Research subjects’ signatures are not required for this log.

To keep subjects’ identities confidential, the researcher should code the log, using the same identifier consistently for each participant. However, the researcher must also provide sufficient information to enable Accounts Payable to report these incentives to the IRS (i.e., name, address, social security or other identifying number, and total amount paid). This information should be marked as CONFIDENTIAL, and both the researcher and Accounts Payable should take prudent measures to secure any personally identifying information.

The log must be submitted to the Controller’s office on completion of the project and must also be maintained by the researcher, as other project records must be, for three years after the end of the project.

Summary of responsibilities

Principal Investigator

  • Describe any planned human subjects incentives in the IRB protocol submitted for review
  • Request funds for incentives:
    • From the grant sponsor if allowable
    • From an alternative source if not allowable
  • Retain original receipts for all goods and services purchased to be used as incentives, and note what they will be used for
  • Hold and distribute incentives
  • Maintain a log of all incentives valued at $100 or more and of multiple incentives given to a single person that total $600 or more within a calendar year
  • Retain coded identifying information for subjects who receive any such incentives
  • Maintain the incentives log, along with other research records, for three years after the end of the project
  • Report individual incentives of $100 or more, or multiple incentives totaling $600 or more in a calendar year, to Accounts Payable
  • Provide Accounts Payable with identifying information for participants who receive such incentives

Institutional Review Board

  • Set and maintain a consistent policy regarding incentives as part of Middlebury College’s IRB policy
  • Review incentives for allowability according to sponsor policy
  • Approve incentives as part of the research protocol and consent language provided to subject participants
  • Review any changes to protocols that involve incentives

Controller’s Office/Accounts Payable

  • Review incentives logs
  • Report to the IRS incentives of $100 or more given to individual participants at any one time
  • Report to the IRS incentives totaling $600 or more or more given to individual participants over the course of the calendar year

Using federal grant funds

All costs charged to federal grants, including human subjects payments, must be:

  • reasonable: recognized as necessary to perform the project, consistent with the way similar charges are handled by Middlebury College and within the researcher’s discipline, related to an action deemed to be within norms of College business and research conduct and not exceeding an amount deemed to be within those norms (i.e., the “prudent person test”)
  • allocable to the specific project: incurred solely to advance the work funded by the grant (or allocable to more than one grant or College activity in proportions that can be approximated using “reasonable” methods)
  • consistent with the way the same costs are treated in like circumstances at Middlebury; the cost must be treated in the same manner (i.e., as either a direct or indirect cost) when used in similar circumstances
  • allowable under federal cost principles, agency-specific policies, award-specific terms and conditions, and college policies

Allowable means that federal grant funds can be used. The items listed below are NOT allowable: federal law prohibits using federal grant money to buy them. If a researcher wants to use any of these items as incentives, another source of funds must be used. These prohibitions apply to all incentives given to human subjects by project personnel. Once an incentive has been given to a research subject, however, the researcher is not responsible for how it is used.


Researchers may not purchase alcoholic beverages using federal grant funds. For non-federal grants, follow standard College policies.


Researchers may not use federal grant funds to provide access to entertainment (for example, performances, exhibitions, racetracks, etc.). This prohibition includes meals.


Researchers may not use federal grant funds to purchase membership to civic, community, and social organizations under any circumstance. Memberships to professional organizations may be allowable if the expense is included in an approved grant budget or can be specifically allocated to the project; consult the SRO or the Grants Accounting Office.

Office Supplies

Researchers may not use federal funds to purchase office supplies, unless the expense can be allocated to a specific grant AND justified as a direct cost of doing the project. Office supplies may be allowable on non-federal grants; consult the SRO or the Grants Accounting Office.


Researchers may not use federal funds to purchase subscriptions to professional journals.

Click here for more details about using federal grant funds.