Using the Pay Card for Human Subjects Studies

A full-time salaried officer of Columbia University who has been assigned approval authority over inventory ordering and reconciliation for their respective hierarchy locations within the pay card system.

• Providing updated Payment Card Custodian information to the Pay Card team. 
• Approval of all card Inventory Submissions through Service Now. 
• Approval of all Inventory reconciliations, required at each inventory replenishment orders, after the initial order.
• Approval of all card funding Load request forms

The Pay Card Custodian must reconcile their Pay Card Card inventory on an ongoing basis. New card inventory orders will not be processed without it. Reconciliation ensures that card inventory on-hand reconciles to Pay Card System. For those Pay Card Administrators that monitor multiple Pay Card System locations, a summary reconciliation must also be maintained. For audit purposes, departments must complete and retain reconciliation and payment records for departmental files.

1. Department will initiate and approve a voucher in AP for the total amount of funding required for the cards to be loaded.
2. Additionally, they will include Voucher support as the card funding or Load form providing the card(s) to be funded with the specific amount of funds. Note: Focus Blue card funding will require Name, Address and Phone number
3. Accounts Payable will review the voucher and documentation. Email the Pay Card team with the supporting document and the load requirements.
4. Pay Card team will fund the cards via U.S. Bank’s Rewards and Focus Blue card administration tools. Once funding is verified in the bank system, a confirmation email is submitted to the Pay Card Administrator and Custodian confirming the card funding details.
5. AP releases the voucher hold so that the expenses are posted to the G/L.
6. Department distributes the cards to the study participants.
7. Department maintains a control log of the cards distributed and inventory for reconciliation purposes.

Note: The cards should only be funded when they are ready to distribute, since we are unable to remove the funds once a card has been loaded.

According to IRS regulations, annual compensation (subject incentives) to study subjects of $600 or greater is considered taxable compensation and reportable to the IRS. Plans for protecting patient confidentiality in these cases will be reviewed by the IRB as part of the protocol/informed consent approval process.

The informed consent document, reinforced by the informed consent process, must clearly iterate the responsibility of the institution to report to the IRS as a taxable income all payments to an individual subject aggregating $600 or more in a calendar year. The IRB must review and approve the informed consent document prior to use.

If a series of subject payments to one individual result in total compensation of $600 or more in any given calendar year, the clinical trial participant must prepare a W-9 Form providing their name, address, and social security number and submit it to the department administrator. The department administrator/custodian is responsible for identifying the individuals who are in-scope for tax reporting and ensuring the proper forms are completed and submitted in a timely manner. This includes ensuring the clinical trial participant is established as a vendor in ARC and for communicating the applicable compensation amount to Accounts Payable when requested.

Note: The Pay Card Administrator/Custodian must aggregate 1099 requests and submit them to Accounts Payable as a single package.