Collection of research participant names, permanent addresses, and social security numbers (SSNs) is necessary to meet Internal Revenue Service (IRS) tax reporting requirements for participant payments and non-cash incentives. The following guidelines for collecting information from research participants to meet tax reporting requirements apply to both check requests and petty cash disbursements, effective January 1, 2014.

  1. All necessary participant information must be collected on the Payment Acknowledgement Form (PDF) that accompanies a Check Request, Petty Cash Replenishment, or Petty Cash Closeout form. For any subsequent payments made to this person, only the individual's name, mailing address, and the last four digits of their SSN (in the applicable SSN field) need to be on the paperwork.
  2. To ensure HIPAA-protected information is closely guarded, and to reduce the risk of identity theft, UVM only requires SSNs when payments and/or noncash incentives to participants are $100 or more if the participant is a non-resident alien.
  3. Non-resident aliens are required to provide their SSN for a payment and/or incentive of any amount. Participants who respond “no” to the question on the Payment Acknowledgment form that states, “Are you a US Citizen or a Permanent Resident Alien?” should complete an International Information Form (IIF) (PDF).  If they self-identify as a Nonresident Alien in IIF Section E, a completed, signed, and dated IRS Form W-8BEN (PDF) should also be collected from the participant. All forms should be submitted with the Payment Acknowledgement Form with any questions directed to Tax Services. Upon receipt of all forms, Tax Services will review them for tax liability. If the participant is considered a Nonresident Alien, the net subject payment shall be grossed-up to cover requisite income tax withholding and the chartstring provided will be charged. An IRS Form 1042-S record will be created based for calendar-year end reporting.
  4. HIPAA-protected information should never be referred to on any payment forms.
  5. The HIPAA Code of Federal Regulations states that UVM is required to have “adequate provisions to protect the privacy of Research Participants and to maintain the confidentiality of data.” To meet this requirement, there must be no reference to the name or nature of the study on any of the forms sent to the Disbursement Center or Financial Reporting & Accounting Services, only that it is a payment and the date of the participation in the study. (Participant-specific information is needed on the Payment Acknowledgement Form, but no reference should be made to the name or nature of the study to ensure proper confidentiality. Participant information is only collected to meet IRS 1099 and 1042 reporting requirements.)

Check Requests or Petty Cash forms that do not meet the above requirements will be returned to the department for correction, which will cause a delay in payment(s).