Payments to Individuals Guidelines

Last updated: February 8, 2024

Background

The following definitions and procedures apply to all Wisconsin Partnership Program grant recipients and their subcontractors.

NOTE: Internal grant recipients — those within the Universities of Wisconsin — should also refer to the UW–Madison Payments to Research Participants Policy UW-3005 and Payments to Individuals Policy UW-3003.

Definition

Participant support costs: Participant support costs (PSC) are small payments to individuals who participate occasionally in research, education, or community-based programs. A $100 incentive limit per occurrence applies for non-research-related participation.

Payments to trainees: Payments to participants who complete an ongoing training or curriculum provided by a WPP grantee.

These payments may include compensation to, or on behalf of, participants or trainees (but not employees) in connection with official meetings, conferences, symposia, training or research projects.

These costs are allowable if they have received prior WPP approval and are included in the approved budget. Payments may be made in the form of check, gift cards or other non-cash items or incentives. Cash may not be used.

Requirements

Grant recipients are required to make the determination whether the individuals receiving payments are participants, employees or independent contractors. Employees of the grantee organization are not considered eligible participants and cannot receive payments. Payments to individuals must receive prior WPP approval and be reflected on the approved grant budget.

Reasonable expenses: External grantees — organizations outside of the Universities of Wisconsin — should request reimbursement based on participant involvement and the type and duration of the activity as outlined in the approved project budget. Such allowances must be reasonable and in conformance with the usual policy of the recipient institution or organization.

  • Participant support costs — A $100 incentive limit per occurrence applies for non-research-related participation.
  • Payments to trainees — An approximate hourly rate must be included in the project Budget Narrative.

Internal grantees — those within the Universities of Wisconsin — should refer to the UW–Madison Payments to Research Participants Policy UW-3005 and Payments to Individuals Policy UW-3003.

Administrative fees: Expenses for surcharges on gift cards are allowable if reasonable; in this instance reasonableness is defined as under 5% of the value of the gift card.

Procedures

Monitoring and tracking: Grant recipients are accountable for safekeeping and appropriate documentation and must have a monitoring and accounting mechanism in place (i.e., sub-account code) to differentiate between regular salary and PSC payments.

Requests for reimbursement must include the following documents:

  • Proof of disbursement — A copy of a cancelled check, a mobile payment service receipt (Venmo, Zelle, etc.) or a bank statement supporting the occurrence of the transaction.
  • A timesheet or log detailing the hours of a trainee’s attendance, or a signed statement by both the trainee and grantee certifying the number of hours completed. A business purpose is required so that the WPP Finance Team may reasonably conclude that the payment is appropriate.

IRS Rules: Providing non-cash incentives to individuals are normally taxable events. The grant recipient should be aware of IRS reporting limits and requirements. Payments of $600 or more in a calendar year must be reported on a form 1099-MISC.

Gift Cards: The WPP will only reimburse external grant recipients for gift cards based on actual cards distributed during the grant period. Documentation of gift cards distributed must accompany the request for reimbursement on the Financial Reimbursement Report. Grant recipients will not be reimbursed for gift cards purchased, but not yet distributed. Additionally, receipts and/or invoices must be submitted for gift card purchases. For example, if a grantee purchases 50 gift cards and only 20 gift cards were distributed during the first quarter of the grant period, then only the value of cards distributed should be included on the quarterly Financial Reimbursement Report.

Internal grant recipients must comply with the gift card procedures outlined in the UW–Madison Payments to Research Participants Policy UW-3005 and Payments to Individuals Policy UW-3003.