Paying Institutional Study Participants

Policy Section
Buying and Paying

Effective Date
April 1, 2023
Responsible Executive
Vice President for Finance and Treasurer
Responsible Office
Financial Services
Jason Knoch
Assistant Vice President for Financial Services
(609) 258-9181


This policy sets out acceptable circumstances, methods, and amounts to pay individuals participating in institutional studies including surveys and human subjects studies.  These payments are offered as compensation for participation, or to incent participation in approved studies. 

This policy ensures appropriate use of University funds in support of its mission, follows Generally Accepted Accounting Principles (GAAP), and complies with federal, state, and local rules, and regulations.

II. Who is Affected by this Policy

This policy affects all staff, faculty, and students who have responsibilities for paying institutional study participants including human subjects and survey respondents.  

III. Definitions

Digital Disbursement

A payment where funds are issued electronically to recipients via email or mobile number.

Human Research Protection Program

The Institutional Review Board’s program to protect the rights, privacy, and welfare of human participants in research conducted by faculty, staff, and students.

Human Subject

A volunteer participant in a research study. Any person participating in a research study is known as a human subject (participant). Under the federal regulations, human subjects are defined as: living individual(s) about whom an investigator conducting research obtains: 1) data through intervention or interaction with the individual or 2) identifiable private information.

Institutional Review Board (IRB)

The Princeton IRB is comprised of a group of individuals charged with reviewing proposed research involving human subjects to ensure the protection of those individuals in accordance with, all applicable laws and policies governing the research, including the Common Rule, state regulations, the Federalwide Assurance, and institutional policies. 

Personally Identifying Information

Information that is used, alone or in conjunction with any other information, to identify a specific person, including: name, address, telephone number, social security number, date of birth, government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number, Princeton University identification number, computer's Internet Protocol address, or routing code.

Principal Investigator (Investigator)

A faculty or staff member with primary responsibility for the design, conduct, and management of a research project.


Campus activities defined as surveys, focus groups, research trials, or programs where the objective directly supports the mission of the University.

IV. Policy

Departments and investigators may pay individuals for their participation in institutional studies as compensation for their time and effort or as an incentive for completion of a survey. Eligibility for payment is dependent upon the nature of the study:

Human Subject Studies

Human subjects in studies approved by Princeton’s Institutional Review Board, and operated in accordance with the policies and guidelines outlined in the Human Research Protection Program can receive compensation for their participation. Disbursing payments or establishing an expectation of payment to participants may not begin until the investigator receives approval from the IRB and an IRB number is assigned. Proposed payment amounts to human subject study participants will continue to be reviewed, modified, or approved through the IRB application process.

Institutional Studies

Departments may offer an incentive for study completion when the study directly supports:

  • regulatory reporting requirements for the University or
  • decision making and planning for the University where a minimum participation (e.g. response rate) is necessary; or
  • the University’s primary mission of furthering education and research


Study participation payments to employees are not allowed if it can reasonably be assumed that participation is within the scope of their employment. Examples include completion of an employment climate survey or a service satisfaction survey.


If payments to study participants are made, they must be:

  • Documented and substantiated by the investigator;
  • Paid directly to the participant - payment to a third party, including but not limited to, an event sponsor or charity, is not allowed;
  • Compliant with applicable laws and regulations, University policies including those of the Office of Finance and Treasury, Institutional Review Board, Office of Research Integrity and Assurance, and any sponsor requirements;
  • Made to every participant who has met the study’s criteria for participation OR made to a subset of participants through a raffle, lottery, or other randomized/selective method that meets the following criteria:
    • Deemed essential for the study to obtain the necessary insights/research outcomes OR directly supports decision making and planning at an institutional level
    • The amount of each incentive is nominal (generally under $100)
    • The subjects’ participation in the study constitutes a negligible commitment of time and effort, e.g. completion of a survey of reasonable length
    • Completion of the study (or satisfaction of another performance metric) is not required for participation in the randomized selection
    • For human subject studies only: received approval from the IRB
    • The payment complies with any local gaming laws and regulations where the study is being performed (ex. municipal and state licensing requirements)


Investigators must follow all University and departmental procedures to request and disburse payments. Studies conducted with sponsored funds may be subject to additional requirements. Investigators are responsible for understanding and adhering to additional requirements that may be established by the funding agency.


The Internal Revenue Service (IRS) defines institutional study payments as taxable income to the recipient. The University is required to report payments to the IRS if a US citizen or resident for tax purposes receives aggregate payments of $600 or more in a calendar year. Payments to non-US citizens/permanent residents may also be subject to IRS reporting as well as withholding. Any individual receiving payments subject to IRS reporting will be required to provide personally identifying information including legal name and social security number/tax ID number.  Investigators must work with Procurement Services in advance to ensure recipients are appropriately set up for payments of $600 or more.


The University’s recommended method of payment to study participants is digital disbursement using the Zelle payment network accessible through the PRIME financial system. This option requires less information from the participant to facilitate, providing a fast and widely accepted option for low dollar, low frequency payments to small and large participant studies.

Traditional payment options such as check and ACH are available when use of digital disbursements is not feasible. In these instances, investigators must coordinate the collection of certain personally identifying information, banking information, and other documentation from the participants required to facilitate payment through the University’s financial systems in a manner that is compliant with various regulatory requirements.

Payments may also be made via incentive platforms such as Amazon Incentives. Crowdsourcing platforms providing study participants such as Amazon Mechanical Turk are also approved payment methods.

Payment method options may be limited by regulatory requirements based on the amount of the payment, participant nationality, and/or participant information collected (e.g. physical address, bank account).

Cash payments to study participants are not permitted, except in instances in which anonymity is a component of participation or where participants are in geographic locations lacking reasonably accessible banking options.

Payments to study participants may not be made with personal funds. Direct payments using personal or University issued cards linked to personal PayPal, Venmo, Zelle, CashApp, or other payment methods are not allowed.

Gifts to non-employees may not be given in lieu of payment for services or as a quid pro quo.


The method of substantiation for payments will vary depending upon the payment method. In all instances, substantiation must include:

  • For IRB approved human subjects studies only, a Notice of Approval letter issued by the Research Integrity & Assurance Office indicating the IRB number, title and Principal Investigator primarily responsible for the study;
  • For all studies, a roster/itemization of each payment including the participant name and amount disbursed;
  • When cash is disbursed, investigators or survey coordinators should obtain written acknowledgement that payment was received and can direct anonymous participants to provide only their initials to acknowledge payment. Acknowledgement can be maintained by the department authorizing the study to ensure privacy and confidentiality.



Revision Log

3/31/2023 - Added to policy library.