When is the collection of social security numbers required for human subject participation payments by Vanderbilt University?
The IRS requires Vanderbilt to file form 1099-MISC (Miscellaneous Income) for each person receiving taxable payments of at least $600 during the calendar year. Guidelines for the 1099-MISC are listed at the following link: https://www.irs.gov/instructions/i1099msc.
In order to satisfy our IRS reporting obligations, Vanderbilt collects the appropriate paperwork (which includes social security numbers) for human subject participants (i.e., U.S. citizens, permanent residents and non-resident aliens or foreign nationals) who receive individual payments equal to or greater than $300.
You do not need to collect SSN’s from human subjects receiving individual payments less than $300. Please note that your specific study/sponsor may require the collection of social security numbers for these individuals. While this opens the university up to some risk from not collecting SSNs for recipients who might receive $600 or more per year through participation in multiple studies in a given year, statistical risk analysis shows the benefits of this practice to the investigators performing studies to be far greater than the marginally minimal risk to the university overall.
For additional information pertaining to human subject participation payments, please visit the Finance website at https://finance.vanderbilt.edu/policies/index.php.