IRB amendment bounce

Dear Barbara:

The notion of a "confidential" study seem to be a bit of a red herring. The only hard requirement from the IRS is that the University must report payments that are $600 or more in a calendar year, regardless of how the study is classified. See https://www.obfs.uillinois.edu/bfpp/section-18-taxes/section-18-10.

I think the problem is actually with inaccuracies in the OBFS policy document https://www.obfs.uillinois.edu/bfpp/section-8-payments-reimbursements/open-program-advance-pay-human-subjects. I just submitted the following comment on its content:

The text seems to imply a few things that I don't think are true. First, it says that non-confidential studies may not pay more than $100 to an individual in a tax year. I think it is trying to say that we can't pay $100 *or more* without reporting the subjects name and address to UPAY1099, as stated in https://www.obfs.uillinois.edu/bfpp/section-8-payments-reimbursements/tax-implications-for-payments . The issue here is about taxation, not about establishing an upper limit on incentives that can be paid to human subjects. Is this not correct?

Indeed, https://www.obfs.uillinois.edu/bfpp/section-18-taxes/section-18-10 says that we are not *required* to report anything if the subject receives less than $600 in a calendar year.

The policies documented in the three links provided above are not entirely consistent.

Another problem is with the blanket statement that *all* payments to human subjects must be made through a program advance. Is it not allowable to derive funds from those that have been forwarded to my department's FOAP? Again, I think recording 1099 information when payments are $600 or more is the only hard requirement. Note that https://www.obfs.uillinois.edu/bfpp/section-18-taxes/section-18-10 does not mention program advances.

Please advise.

Many thanks,
Dave

​I am going to add a "Winner's Survey" in Qualtrics to collect the information we need from the lottery winners in a secure way:

1. Are you an employee of the University of Illinois?
2. Are you required to file a federal income tax return in the United States?
3. For tax purposes, are you a non-resident alien of the United States?​
4. For income reporting purposes, please provide your mailing address:
5. Have you received a total of $500 or more in the current calendar year for participating in research studies hosted by the University of Illinois?
6. [If yes to #5] As it is required for income reporting purposes, please provide your Social Security number:

​This way, we leave the current survey(s) untouched.

​I plan simply to go through normal IRB channels to get this reviewed again. I think I understand the issues involved now, and if I was in the reviewer's shoes, I would be annoyed by email, especially from some grad student.​