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Effective September 15, 2017

Departments conducting studies with volunteer participants are required to track any and all forms of payments (i.e. cash, check, gift cards or in-kind merchandise) to study participants.  Payment mechanisms for study participants must follow respective Tufts Accounts Payable policies and related Study Participant Payments Decision Tree.

The department must obtain an IRS Form W-9 from the individual and forward it to Accounts Payable with the total amount paid if the amount paid is greater than or equal to $600.

All payments to non-resident aliens (regardless of the amount) are subject to a 30% tax withholding. Due to the withholding and reporting requirements, all non-resident aliens receiving such payments must have a U.S. tax identification number (social security number or ITIN) and must be processed through the Accounts Payable system. A non-resident alien cannot be paid cash or cash equivalents.  An IRS Form W8-BEN and an Alien Payment Form are required.  Please contact Accounts Payable with any questions regarding payments to a non-resident alien.   Required forms can be found here.

Purchases of Incentive Cards

Bulk P-card purchases of research incentive gift cards for volunteer participants, including eGift cards or store cards, must be charged initially to a non-sponsored account (DeptID) except as noted below. After distribution to subjects participating in sponsored projects, the amount corresponding to the purchase value of the distributed incentive cards should be moved to an appropriate sponsored project account using a cost transfer.

OVPR Post-Award office approves allocations of incentive cards to sponsored awards via cost transfer paperwork. Cost transfer must be submitted within 90 days from the end of the month in which the incentive cards were distributed to the study participants.

Incentive cards for “immediate distribution” (within 3 months from purchase) to the subjects can be charged directly to a sponsored account. The cost of any cards not distributed to the subjects of the study funded by the sponsored account must be transferred to a non-sponsored account (DeptID) at the end of the third month. If any remaining gift cards are subsequently distributed to participant(s) then the value can be transfer back to the sponsored project account as described above.  No undistributed gift cards shall remain on a sponsored account for more than 3 months.

The approval of allowability for the purchase of cards for “immediate distribution” and direct posting to a sponsored account must be obtained by submitting to postaward@tufts.edu a memo describing the vendor, the method of purchase, denomination of incentive cards, and total number of incentive cards for the study. Post-Award will forward the approval to the Disbursement Compliance Analyst who maintains it in the file as backup documentation for the P-card or general audit.

Tufts units that conduct large volume of sponsored studies where incentive cards are issued to study participants may seek a blanket pre-approval from Post-Award to direct charge incentive cards to sponsored accounts when appropriate. Such pre-approval will only be issued when the unit has documented standard operating procedures for management of incentive card purchases and designated an individual to conduct regular inventory of incentive cards and audit proper charging.

All incentive card purchases on the P-card must be consistently coded using 5136 - Volunteer Subject Payments.

The department must upload the receipt / confirmation from the vendor website from the online vendor to the PeopleSoft P-Card application for purchase of any incentive cards whether purchasing them in small number or in bulk. This receipt should be added to the PeopleSoft P-card transaction by clicking on the “Justification Full Screen” icon. The attachment can be added on either unposted or posted transaction pages. Attaching the receipit in the system facilitates providing documentation for  external and internal audits and reduces requests for documentation from the departments. For additional information on how to attach paperwork within PeopleSoft please see PCard User Guide.

Distribution of Incentive Cards to Subjects

Documentation showing evidence of distribution of incentive cards is required, including instances when the approval of allowability has been obtained in advance. If the names of study participants must remain confidential, a unique participant ID must be assigned on the documentation.

A distribution log must be provided in order for allocating the cost of incentive cards to sponsored award(s). The log should list names of volunteer subjects or their participant IDs, value of received incentive cards, date of receipt, and the following additional information as appropriate for the type of distribution:

  • In-person distribution: signatures of the subjects who received the incentive cards.
  • eGift Cards: purchase receipt from the vendor, and
    • If sent directly to participants electronically: vendor receipt showing recipient and delivery details and confirmation of delivery.
  • Distribution by email: a copy of the emails sent, as well as a read receipt for each or a confirmation from the person that they received it.

Distribution by mail: a copy of delivery confirmation. Incentive cards must be sent via USPS Registered Mail, UPS, or Fedex with signature required from the recipient. NOTE: The fees charged for the registered mail and delivery confirmation must be allocated to a DeptID or other unrestricted fund unless allocation to the award is approved by the sponsor.