Human Subject Incentive Program SSN Policy FAQ

Policy link: HSIP SSN collection policy

1. What is changing?
   • Previous policy mandated collecting SSNs from participants if their potential total payment from a single study exceeded $400 in a calendar year. The updated policy changes this rule by increasing the dollar amount threshold to $1,600 in a calendar year.
   • For studies potentially paying over $1,600 in a calendar year, SSNs must be collected before the initial payment.
2. Why is this change happening?
   • The policy change is happening to streamline the process for collecting study participant information, ensuring better tracking, and compliance with federal IRS payment reporting requirements. This shift aims to standardize the SSN collection process when participant compensation reaches or exceeds a certain threshold ($1,601 or more), regardless of individual study payments. 
   • This change will also create more flexibility in participant recruitment and remove the administrative burden of collecting and storing SSNs for many studies.
3. How will this affect new studies?
   • After November 7, 2026, new studies will be expected to follow the new policy. This should cause minimal to no disruption as prior requirements of collecting a payee's name and address remain the same.
   • All new studies will need to include language in the informed consent document informing participants of the requirement around providing their SSN.
4. How will this affect existing studies?
   • After November 7, 2026, existing studies will be migrated to the new tier system over the next 12 months as study amendments are submitted. This is expected to have minimal disruption and will relax the data collection requirements for many studies, removing the need to collect SSNs from all payees and only collecting when an individual has been compensated more than $1,600 or the study is designated as Tier B.
   • Existing studies that are not submitting an amendment may still show the old tier system under certain circumstances. HSIP will handle these cases manually and the threshold remains at $1,601. 
   • Existing studies may need to notify participants informing them of the requirement to provide a SSN if they are compensated more than $1,600.
5. How will new and existing studies be supported in transitioning to this new policy and what resources are available to assist with compliance?
   • The HSIP team will be available to answer questions and provide guidance. HSIP will contact studies teams if it identifies a payment that pushes a participant over the $1,600 threshold. HSIP can be contacted at [email protected].
   • Starting 11/7/26, eResearch will update eligible payment tiers automatically. Other updates to IRB records and consent materials should be made with the study’s next amendment, unless the IRB directs otherwise.
6. What steps should a study team take if a participant is approaching the $1,601 threshold?
   • The study for which the participant is currently seeking to receive payment when reaching this threshold is responsible for collecting the SSN to enable any payment that places the participant’s total payment during a calendar year at $1,601 or more.
   • When a participant's yearly earnings from studies hit $1,600, HSIP will alert the principal investigator and payment requestor of the last study paid. This notice informs the team that exceeding $1,600 in annual compensation requires the participant's SSN. The notice can prompt early SSN collection by the study team, which is highly recommended before payments reach $1,600.
7. What should a study team do if they become aware of non-compliance with this policy?
   • Study teams are strongly encouraged to track participant payments when they are disbursing multiple payments directly to participants and have received a notification from HSIP that a study participant is close to the $1,600 limit to ensure compliance and inform participants about SSN submission requirements for future paid research participation.
   • If a study team becomes aware of non-compliance with one of its participants, it should inform the HSIP Office and inform the research participants they can: 
     • Provide their SSN to continue to receive payments

Or 

• Decline to provide their SSN and forego any future payments for the calendar year. 
• Non-adherence to these guidelines may result in the HSIP Office notifying the director of the human research protection program.
• If a participant withdraws consent due to unwillingness to provide their SSN for payment, the study team should file an ORIO report with the IRB.
• HSIP monitors and conducts weekly audits of participant payments and will notify research teams of any issues it identifies.

8. What is considered noncompliance with this policy?
   • Noncompliance occurs when a study team fails to collect required information for payments that are distributed. For Tier A Studies this is the name, address, payment amount, and payment date. For Tier B studies this is the name, address, SSN, payment amount, and payment date.
     • If a participant refuses to provide information (e.g., name and address) a study team can document that refusal to demonstrate efforts to comply with the policy.
     • When a participant has been compensated more than $1,600 in a calendar year regardless of study tier assignment, all information is mandatory for that participant and study teams are expected to collect this information before distributing compensation to avoid noncompliance.
   • Noncompliance is evaluated holistically, with a focus on patterns or systemic issues in following payment policies rather than isolated incidents.
9. In case of policy noncompliance, how can a study team regain the ability to distribute payments directly to participants?
   • Study teams must show they can adhere to the policy. If participants refuse to share specific information, documentation attempts by study groups to gather the required information will be considered compliant and can result in the reinstatement of the ability to distribute payments directly to participants. 
10. How should a study team handle participant consent and payment if the participant does not have an SSN?
    • If a participant does not have a SSN to provide and is residing in the United States, they should be paid through payroll and not through HSIP. If there are questions please contact [email protected] for help in determining what is appropriate.
11. Are there any special considerations or alternative procedures for sensitive studies that involve vulnerable populations?
    • Requests for exceptions to this policy should be submitted in advance of payment distribution to the HSIP Office. Decisions regarding exceptions for sensitive studies will be made in collaboration between the HSIP Office, the IRB, Office of Tax Compliance and Planning, and the Human Research Protection Program to comply with federal regulations in both domains.
12. Do I need to update the informed consent document?
    • Informed consent documents must clearly state that participants must provide the university their TIN or SSN for payment if they earn $1,601 or more within a calendar year from research participation. If participants have received $1,600 from the university in one year for research participation, but refuse to provide their TIN or SSN, they can still join studies, but won't be paid for any participation for the rest of that year. 
13. What are the implications for a participant if they choose not to provide their SSN after reaching the $1601 threshold?
    • The participant can (1) decline to give their SSN and not be paid or; (2) decline to give the SSN and be paid only up to the $1,600 threshold in the calendar year.
14. Can a participant retract their SSN after they have provided it?,  
    • HSIP is unable to remove SSNs from U-M systems once they have been submitted. 
15. Can I delete SSN once I’ve submitted it to the HSIP system?
    • Study teams should store the payment information collected until they receive an email notification that their HSIP request has been completed. Once study teams have been notified that HSIP has received payment information, they can delete payment information, which may include a SSN. 
    • To reduce the risk of accidental exposure, securely delete unneeded electronic records and shred unneeded paper records containing SSNs for currently enrolled participants, in accordance with U-M’s secure data and device disposal guidance and applicable records-management and data-security requirements.
16. What is the role of the principal investigator in ensuring compliance with the new policy?
    • SPG 501.07 states financial management is in the hands of the PIs and with their study teams. The PI should understand the financial authority and obligations related to Human Subject Payments.
17. What are the potential consequences for the university if IRS penalties are applied due to noncompliance with this policy?
    • When U-M does not issue a 1099 to participants paid $2,000 or more in a calendar year, IRS penalties could be applied to the university and the research participant.  Further, when a study team fails to collect a SSN when required by IRS regulations and the research is federally funded, the study is in breach of terms requiring adherence to applicable laws and requirements (2 CFR Part 200.300­ & 2 CFR 200.303). The study team has a responsibility as stewards of U-M and federal funds to minimize the possibility that the university is subjected to any IRS penalties and adhere to contractual terms of federal grants.
18. Why does U-M collect Social Security Numbers at $1,600 when the federal reporting threshold is $2,000?
    • U-M combines each participant’s payments across university studies during the calendar year. Collecting an SSN at $1,600 gives participants advance notice and time to choose whether to provide an SSN and continue receiving payments or decline and discontinue participation in the study. It also helps U-M complete required tax reporting accurately if total payments reach $2,000.