Subject Compensation Via Gift Certificates Policy

Purpose:  The purpose of this policy is to provide guidelines for the use of gift certificates as a method of compensation to subjects for their participation in a research study when there is a continuing demonstrated need for this method of compensation. VMRF is committed to fair, honest and appropriate participation payments, independent of the mechanism of payment, and will cross-reference accounting records submitted to VMRF for payment against the appropriate IRB approved protocol to assure the adherence to the approved payment mechanisms and amounts. VMRF follows the requirements on payments to subjects as detailed in paragraph 12 of the VHA Handbook 1200.5, updated on 07/15/2003.

Overview: 

A.  The VMRF Chief Executive Officer has sole authority to authorize the use of gift certificates as a form of compensation to subjects.

B.  The gift certificate custodian is responsible for the ongoing reconciliation of the gift certificates.

C.  The VMRF Accounting Department will review the ongoing reconciliation of the gift certificates.

D.  The VMRF Contracts Coordinator will cross-reference accounting records submitted to VMRF for payment against the appropriate IRB approved protocol

E.  VMRF reserves the right to suspend the use of gift certificates at any time when management deems it appropriate to protect internal controls.

F.  Gift certificates and/or cash payments to a non-employee exceeding a total of $599 from VMRF sources during any calendar year will result in a form 1099 (Miscellaneous Income) being issued to the individual and a copy sent to the Internal Revenue Service. Gift certificates and/or cash payments made to a VMRF employee, at any time during the same calendar year, will be added to the employee’s W-2 for that year. VMRF reminds employees considering participation in a research study that participation has to be voluntary and without any coercion by co-workers, superiors, or any other person.

G.  In accordance with OMB Circular A-122, no alcohol or tobacco can be purchased with the gift certificates. Correspondingly, VMRF will only authorize the purchase of gift certificates from establishments that do not serve/sell alcohol or tobacco or establishments that have gift certificates that state “Cannot be used for alcohol or tobacco purchases”. The VMRF Accounting Department has a list of approved establishments from whom gift certificates can be purchased, but will consider other establishments on a case-by-case basis.

H.  VMRF balances a responsibility to maintain various levels of confidentiality for information about human subjects with record keeping requirements of the State of California, grantor agencies and the Internal Revenue Service.

I.  Bonus payments made to investigators and/or study staff to motivate or reward participant enrollment are not allowed.

Definition: 

Gift Certification Custodian: person responsible for overseeing the disbursements of gift certificates, the replenishment of the gift certificates on hand and the reconciliation of the gift certificates. This person is also responsible for ensuring that the gift certificates are kept in a safe and secure place.

Application:

Request for the Use of Gift Certificates: Requests to begin using gift certificates as a form of compensation to subjects must be submitted to the VMRF Chief Executive Officer. Requests must identify the VMRF funding source, explain the need for gift certificates, the proposed dollar amount and who the gift certificate custodian will be.

Gift Certificate Custodian: The gift certificate custodian is responsible for all expenditures via gift certificates. Each gift certificate that is distributed must be supported by an original, completed VMRF Subject Compensation Form.

Physical Security: Gift certificates must be kept in a safe and secure place at all times. Any missing or stolen gift certificates must be reported immediately to the VMRF Accounting Department. Projects will not be reimbursed for lost or stolen gift certificates.

Replenishment of Gift Certificates: When it is time to replenish the supply of gift certificates, the preferred method is to submit to the VMRF Accounting Department at 151A, a VMRF Check Request Form with copies of the original VMRF Subject Compensation Forms attached to support the amount previously distributed. The gift certificate custodian will pick up the check from the VMRF Accounting Department and take it to the establishment and purchase the gift certificates.  If the gift certificates are purchased by the PI or their representative, the gift certificates must be from an approved establishment, reconciliation must occur and the original receipt must be attached to the check request in order for a reimbursement to be granted.

Change of Gift Certificate Custodian: When custody of the gift certificates is to be transferred temporarily or permanently, the PI is to send notification to the VMRF Accounting Manager immediately for approval.

Exceptions:   Exceptions to the above policy must be approved by the VMRF Chief Executive Officer. 

Approved by the VMRF Board of Directors: June 11, 2010