Administrative Policies and Procedures Manual - Policy 2480: Incentives to Program Participants

Date Originally Issued: 06-01-2008

Subject to Change Without Notice

Authorized by Regents' Policy 5.9 "Sponsored Research"

1. General

As part of a sponsored project the University may conduct programs, workshops, conferences, symposia, and similar activities that require or benefit from specifically identified participants taking part in the event.  To encourage participation, monetary and non-monetary incentives may be provided to participants if allowed by the contract or grant, this policy, and made in accordance with applicable laws, regulations, and University policies.  Services cannot be required of participants; any compensation paid for services such as internship stipends are not participant incentives and must be processed through the University Payroll Department.  These incentives do not include travel and conference fees paid for University employees to attend work-related events.    

2. Allowable Incentive Methods

Principal Investigators should contact the Office of the Vice President for Research and Economic Development or the Office of the Executive Vice President for Health Sciences for assistance in determining if a participant incentive is appropriate.  Monetary and non-monetary incentives provided to participants may consist of:

• Materials and supplies valued at less than $500 related to the program.
• Minor equipment valued at less than $1,000 related to the program.
• Reimbursements or allowances for materials and supplies less than $500 related to the program.
• Tuition and fees to attend a workshop, conference, or symposium.
• Reimbursements for lodging, meals, mileage, ground transportation or air fare in accordance with Policy 4030 "Travel."
• Small items or incentive payments equal to or less than $250 to attend the event.

Incentives other than those listed above must be approved in advance in writing by the Vice President for Research and Economic Development, the Executive Vice President for Health Sciences, or their designees.

3. Required Documentation

The following information should be collected from each participant before the incentive is granted:

• Name, social security number, and address of the participant.
• Participant's signature acknowledging the receipt of the incentive and that the value of the incentive may be reported to the Internal Revenue Service (IRS).
• Date incentive was provided to the participant.
• Fair market value of the incentive.

If this information is not collected before the incentive is granted, it must be collected before the total value of all incentives granted to an individual in a calendar year equals or exceeds $100 .  If the above information is not collected, the department conducting the program will be responsible for all penalties and accrued interest assessed by the Internal Revenue Service for non compliance.  

This information must be protected in accordance with Policy 2030, "Social Security Numbers," UBP.  Click here to print off a form that can be used for gathering the required information.  The form is also available from the applicable accounting office.  Within two (2) weeks after the program or event is completed, the principal investigator must report this information to accounting using the computer application found on the Financial Services website.  Click here to be directed to the computer application.

4. Tax Reporting

4.1.  University Employees

Payment of incentives to University employees must comply with all University policies including those pertaining to compensation and conflict of interest. The value of incentives other than travel reimbursements given to participants who are University employees, including student employees, may be taxable and reported to the IRS.  An employee can avoid taxation by refusing personal receipt of the incentive at the time the incentive is  offered/earned.  The employee can request that the incentive go to a University department for University use.

4.2. Non-Employees

The value of incentives other than non-reportable travel reimbursements given to non-University employees may be taxable and reported to the IRS.  Taxability will be determined by the applicable accounting office.

4.3. Foreign Nationals, Employees, and Students

All payments to non-resident aliens must be reported to the University Taxation Department for approval prior to the program or event, and made in accordance with Policy 2180 "Foreign Nationals, UBP.

5. Confidentiality

Departments are responsible for complying with the Health Insurance Portability and Accountability Act (HIPAA), the Family Educational Rights and Privacy Act (FERPA), and other relevant laws and regulations pertaining to confidential information.  Do not include any protected information when reporting the information required in Section 3. herein; however, departments are responsible for maintaining all required supporting information in the appropriate files documenting incentives paid to participants. 

6.  Exceptions

All exceptions to this policy must be approved in advance in writing by the Vice President for Research and Economic Development or the Executive Vice President for Health Sciences.