Using the Pay Card for Human Subjects Studies
Pay Card Program Overview
Benefits
The Pay Card Program is designed to compensate and/or reimburse clinical trial participants via prepaid and/or debit card. It aims to reduce or eliminate the need for petty cash.
Human research relies on volunteers to participate in studies. It is not uncommon for a researcher to reimburse subjects for travel or other expenses that they may incur as a result of participation in a study. Some studies may also offer compensation as a means to attract volunteers. All plans to compensate participants/subjects in research studies must receive prior approval from the Institutional Review Board (IRB). The pay card is used to process those compensation payments.
Departments interested in the Pay Card Program will reach out to the Pay Card team at [email protected]. New department setups are required to complete the “On-Boarding Form,” which will provide set up details needed to establish the department in the bank system. This form will also provide the authorized users for the Pay Cards within each Department.
For an overview of the pay card, please refer to the Pay Card Community Brochure.
Find resources for Pay Card Cardholders, Custodians, and Admins.
Roles & Responsibilities
Departments will be required to established an authorized Custodian and Administrator which will serve as the primary contacts for all card issuance and funding. The users assigned to these roles will be responsible for the management of the pay cards within their Department. They will be required to complete the pay card Training, which is provided in the Resources section.
A full-time salaried officer or staff employee of Columbia University responsible for ordering card stock, performing inventory reconciliations, and distributing and securing card stock.
- Adherence to University requirements for all reimbursements and payments made to clinical trial participants
- Reconciling card inventory on an on-going basis
- Managing card inventory (including ordering, securing, distributing, and collecting)
- If approved for the voucher initiator security role, enter voucher load requests in ARC for processing
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
Any updates required for the Pay Card Administrator/Custodian, will require submission of an “On-Boarding Modification Request” form provide authorization for any Department updates/modifications.
Types of Cards Issued
There are two types of prepaid cards that you may request through ServiceNow:
- Focus Blue Card: a reloadable card with cash access that must be registered to a recipient.
- Corporate Rewards Card: a one-time-load card that also allows for recipient anonymity with the University.
The table below provides the attributes of each.
Pay Card Types
- REWARDS CARDS (Non-reloadable)
- Anonymous: Yes (e.g., clinical studies)
- FOCUS CARDS (Reloadable)
- Anonymous: No
- REWARDS CARDS (Non-reloadable)
- Cash Access: No
- FOCUS CARDS (Reloadable)
- Cash Access: Yes
- REWARDS CARDS (Non-reloadable)
- International Usage: Yes
- FOCUS CARDS (Reloadable)
- International Usage: Yes
- REWARDS CARDS (Non-reloadable)
- MAX Load limit: $599.99
- FOCUS CARDS (Reloadable)
- MAX Load limit: $600
- REWARDS CARDS (Non-reloadable)
- MIN Load Limit: $10
- FOCUS CARDS (Reloadable)
- MIN Load Limit: $1
- REWARDS CARDS (Non-reloadable)
- Reloadable: No
- FOCUS CARDS (Reloadable)
- Reloadable: Yes
- REWARDS CARDS (Non-reloadable)
- Card Expiration: 24 Months
- FOCUS CARDS (Reloadable)
- Card Expiration: 36 Months
- REWARDS CARDS (Non-reloadable)
- Multiple Cards Per Participant: Yes
- FOCUS CARDS (Reloadable)
- Multiple Cards Per Participant: Yes
- REWARDS CARDS (Non-reloadable)
- Pre-loadable At Time Of Order: Yes
- FOCUS CARDS (Reloadable)
- Pre-loadable At Time Of Order: No
- REWARDS CARDS (Non-reloadable)
- Per Card Cost: $1.50
- FOCUS CARDS (Reloadable)
- Per Card Cost: No Cost
- REWARDS CARDS (Non-reloadable)
- Card Replacement Cost: $15.00
- FOCUS CARDS (Reloadable)
- Card Replacement Cost: 1 Free Per Year
- REWARDS CARDS (Non-reloadable)
- Card Holder Registration Required: No
- FOCUS CARDS (Reloadable)
- Card Holder Registration Required: Yes
- REWARDS CARDS (Non-reloadable)
- *Card Activation Required: Yes
- FOCUS CARDS (Reloadable)
- *Card Activation Required: Yes
- REWARDS CARDS (Non-reloadable)
- *Rewards activate with 16-digit card # and CVV2 Code
- FOCUS CARDS (Reloadable)
- *Focus activate with 16-digit card #, CVV2 Code, and Zip Code
*Rewards card cost of $1.50 per card is allocated at the time the card is ordered.
How It Works
Columbia uses U.S. Bank’s systems to order card stock and fund the cards. ARC’s voucher process is used to account for the expense and bank funding activity. Departments which are interested in participating in the Pay Card Program will reach out to the Pay Card team at [email protected], and provide an “On-Boarding” Form in order to establish the authorized Custodian and Administrators for that Department.
- Department initiates a card inventory request via ServiceNow, which will provide the Card Type and number of cards needed. This request must be approved by the designated Pay Card Administrator for that Department. The Department may note card delivery address in the Comments section. (Note: The form will require a chartstring for any Rewards cards ordered. The cost is $1.50/card which is allocated by the Pay Card team.)
- Pay Card team will validate and process the request:
- Submit the order to the bank for processing.
- Rewards cards only: Process a journal to allocate the cards fees to the chartstring noted on the ServiceNow inventory request.
- Forward a confirmation order to the Department including the card inventory details.
- The bank will forward the cards directly to the Department address either (1) on file or (2) alternate address, if noted in the Comments section of the Service Now request.
- Department confirms receipt of the card inventory order, and the ServiceNow request is closed.
Note: Inventory Reconciliation form completion is required with each Inventory request submitted, after the initial inventory request.
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.
- Department will initiate and approve a voucher in AP for the total amount of funding required for the cards to be loaded.
- 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
- Accounts Payable will review the voucher and documentation. Email the Pay Card team with the supporting document and the load requirements.
- 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.
- AP releases the voucher hold so that the expenses are posted to the G/L.
- Department distributes the cards to the study participants.
- 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.
Resources for Using the Pay Card
Visit the Pay Card Resources for Cardholders, Custodians, and Admins document page to find available how-to guides and instructions.