Guidance on Cash/Gift Card Incentives for Human Subject Research

DRAFT – 8-5-14

Allowable & Best Practices for Cash and Gift Card Incentives for

Human Subjects Research Participants


Cash and gift card incentives for human subject research participation are generally permitted from Fund 25 and 30 budgets – IF they are implemented consistent with Mississippi State Law and University policy.

To satisfy law and policies, you must:

  • provide sufficient justification documentation to Procurement and
  • establish an audit-sufficient paper trail on how the cash or gift cards were distributed


1.       Submit a memo of justification to Rachel Bost ( that includes:          

  • Justification for purchasing gift cards or giving cash          
  • details of internal controls established for the disbursement of the cards / cash (detail how you will select winners, deliver, and track in real-time)
  • a statement that the PI or project personnel and their family members will not be compensated participants, that members of the PI's department or unit will not be compensated participants, and that the study is open to the public and an effort will be made to seek participants beyond University employees (tell how this will be done)
  • a statement that participants will sign for the cards / cash and you will maintain those records for a period of 7 years after the last payment (or you will track as under 3.b. below)
  • your IRB-approved consent form with incentive information highlighted
  • If your study is sponsored by funds external to UM, document sponsor approval of the payments & method with excerpts from your grant or contract (or separate letter from sponsor)

2.       Obtaining cash or gift cards from Procurement

***Use gift cards instead of cash whenever possible (reduces risk of audit and loss)
*** Use a Procurement VISA card whenever possible for purchasing incentives
***Request funds / gift cards up front instead of paying participants out-of-pocket and requesting subsequent reimbursement (reduces risk of audit; avoids risk you will not be reimbursed)

          a.       For gift cards:
                   i.       Submit a request for payment to the PI [contact Rachel Bost for form] & purchase gift cards with the payment
                   ii.      Better:  use your UM Procurement VISA to purchase the gift cards [contact Shelley Morrison  to raise the monthly purchase limit, if needed]

          b.      For cash:
                   i.      [contact Rachel Bost for information]

3.       Distributing & tracking incentives

          a.       Have participants print & sign names showing they received an incentive with the date received and value of the incentive (add ID#s for students).  Keep this documentation separate from your research data and have it available in case you are audited.
          b.       If you mail gift cards (e.g., there is no in-person contact with participants), document participant name, date mailed, and incentive value. Keep this documentation separate from your research data and have it available in case you are audited.

4.       Reconciling VISA statements –  submit the following:

          a.      Your list from #3.a. or #3.b. above
          b.      Your memo of justification from #1 above
          c.      ***If all gift cards have not been distributed when the visa document is due, include a statement that you will keep similar records of card distribution.  When all cards have been distributed, send the list with your copy of the VISA document to Shelley Morrison .


If a subject could receive more than $600 in cash + gift cards in a calendar year – from your study or from multiple studies:

UM must report to the IRS payments from UM accounts that exceed $600 per participant per calendar year (IRS considers gift cards/certificates equivalent to cash). This case requires subject name, address, and social security number – which should be disclosed to subjects in the IRB consent form along with the fact that the IRS will receive a 1099 MISC Form and they will likely have to pay tax. A 1099 MISC Form should be completed [contact Rachel Bost for information].    Do not include the study name on any check.