Expense Procedure: Payments to Research Participants

Purpose

The purpose of these Procedures is to set out specific steps in respect of Payments to Research Participants.   The University of Ontario Institute of Technology is a research-intensive university and conducts research involving human participants. This procedure has been established, to ensure compliance with Generally Accepted Accounting Principles, the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS 2) and University policies and procedures.

Definitions

For the purposes of these Procedures the following definitions apply:

“Fund Holder” means the individual responsible and accountable for the management and use of a research fund.

 “Payments to Research Participants” means any payment made to a human participant, as set out in  paragraph 2.2 of the University's Research Ethics Policy.  Payments can take the form of:

1. Money (e.g. cash or cheque),
2. Near-cash (e.g. gift certificates), or
3. In-kind (e.g. tangible items).

“Research Funds” means funds provided by a Sponsor, held in trust, and administered by the University to pay for expenses incurred in support of research at the University, including:

• Internal research funds, and
• Funds awarded through external sponsors.

 

Scope and authority

These Procedures apply to Payments to Research Participants involved in research studies approved by the University's Research Ethics Board.

The Vice-President, Administration, or successor thereof, is the Policy Owner and is responsible for overseeing the implementation, administration and interpretation of these Procedures.

Procedures

The Fund Holder, is responsible and accountable for the research study. If a research study requires human subject participation, a research ethics proposal must be approved by the Research Ethics Board prior to conducting any research on human subjects.

This procedure assumes that all research studies involving the participation of human subjects are confidential, i.e. that personal information of research study participants is not to be disclosed, aside from the circumstances set out in this procedure.  Further, this procedure assumes that research participants are responsible for reporting any tax consequences related to payments received.

For each Research Fund, the stakeholders keep records on the use of funding, including verifiable audit trails with complete supporting documentation for each transaction, for a minimum of seven years. The following indicates who is responsible for retaining supporting documentation:

1. Finance will retain: (i) supplier invoices indicating details of Payment to Research Participants (e.g. the supporting receipt(s) or invoice(s) for the purchase of the near-cash or in-kind payments), and (ii) the completed Deidentified Declaration of Remuneration to Research Participants Form.
2. The Research Ethics Board will retain approved applications with supporting documentation and all notifications of decision detailing the Payment to Research Participants.
3. The Fund Holder will retain proof of payment (e.g. receipts signed by participants, master list of research participants including names, research participant ID CODE and signature of participant confirming receipt of payment).

In most research projects involving human participants, a guarantee of confidentiality is offered as part of their participation. As per the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS 2), this means that knowledge about the participation of individuals and what they have said or done in the course of the research activity is kept in confidence and not shared with anyone outside those approved by the REB. At the commencement of the process of consent, the Fund Holder or authorized research delegate shall provide prospective research participants with the required elements of consent as outlined in Article 3.2 of the TCPS 2.

The university recognizes that all participants in research have the right to confidentiality. At the same time, Finance has an obligation to meet accounting and reporting requirements.  Finance is responsible for the following in regards to payments to study participants:

1. Reviewing requests for payment for completeness, accuracy, and eligibility
2. Issuing approved advances to Fund Holder
3. Issuing approved reimbursement payments to Fund Holder
4. Reviewing and approving reconciliations of spending of advanced funds
5. Ensuring any repayments of unused advances are deposited to the original project.

The Fund Holder has a duty of confidentiality to participants that includes safeguarding their information.  A Fund Holder must also satisfy institutional financial reporting requirements for the use of funds to pay for participation in research. To satisfy both obligations, a Fund Holder will submit a coded list of participants who received incentives to Finance. This ensures appropriate privacy protection for participants while providing acceptable supporting documentation.

There are instances where participant information is subject to external audit review (i.e. identifiable information about participants).  In the event of such an audit, the Fund Holder will release such information to the auditor, via the Research Ethics Board.  No other party shall have, or be provided, access to this information.  It is the responsibility of the Fund Holder to ensure participants, through the consent process, are aware that information may be subject to external audit.

There are two alternative methods for administration of payments to research participants, (i) reimbursement, and (ii) payment in advance.  Detailed requirements for both are listed below.  The completion of the below steps constitutes the Fund Holder as certifying the conditions of remunerating research participants have been satisfied.

Reimbursement

Under this approach, the Fund Holder pays the research participants out of pocket and is subsequently reimbursed.  The following steps are completed:

1. Fund Holder completes a CONCUR claim
2. Documentation attached to the claim must include:
   • For near cash or in-kind purchases this consists of an itemized receipt or invoice
   • The Deidentified Declaration of Remuneration to Research Participants Form
   • A copy of the Research Ethics Board Approval Letter
   • A copy of the compensation plan taken from research protocol as approved by the REB.   For purpose of clarify, this would be the section on compensation (para. 7.8-.9) in the research protocol; the full REB application is not required.

Payment in advance

Under this approach, the Fund Holder requests a cash advance, or purchases incentives via Corporate Card or other acceptable forms of payment.  The following steps are used to obtain and settle an advance:

1. Fund Holder requests an advance through CONCUR specifying that the advancement is for payments to research participants. The following documents shall be attached to the request:
   • A copy of the Research Ethics Board Approval Letter
2. A copy of the compensation plan taken from research protocol as approved by the REB. For purpose of clarify, this would be the section on compensation (para. 7.8-.9) in the research protocol; the full REB application is not required. The Fund Holder is responsible for advances
3. Fund Holder will remunerate each research participant as outlined in approved REB application
4. Fund Holder settles the advance within 30 days following the completion of the research involving human participants that resulted in payments. Settlement includes completing the Deidentified Declaration of Remuneration to Research Participants Form, obtaining the appropriate authorizations, reconciling the cash advance, and returning any unspent amounts.

Monitoring and Review

These Procedures will be reviewed as necessary and at least every three years.  The Vice-President, Administration, or successor thereof, is responsible to monitor and review these Procedures.

Relevant Legislation

Tri-Council Policy Statement 2 : Ethical Conduct for Research Involving Humans

Related policies, procedures & documents

Expense Policy

Expense Procedure

Research Ethics Policy

Declaration of Fees Paid to Research Subjects (Researcher Form)

Deidentified Declaration of Fees Paid to Research Subjects (Finance Form)