RESEARCH PARTICIPANT POLICY

Purpose

The Research Participant Policy has been created to provide guidelines for the appropriate establishment, use, and accountability of such funds.  Procedures have been established to encourage effective administration and internal control of cash handling operations throughout the University. 
 

Summary

Research participant funds are established to enable principal investigators (P.I.) to pay subjects on a research grant when the department is unable to determine who the subject will be in advance or when anonymity is required. The amount of the research participant fund is established at the time the fund is approved and should be included in the Grant Approved Budget.  Expenditures must meet the legal requirements of University funds and may not be used to circumvent current purchasing procedures.

If the PI knows the identity of study participants before payment is made, then the normal process for completion of a requisition and issuance of a purchase order should be followed.  If the identity of study participants is unknown before the payment is due, then a specified petty cash account designated as a Research Participant Fund shall be established. The procedure for establishing this fund is described below.

Any individual handling university cash is responsible to Texas Woman’s University for proper security and accountability.   Due to the personal liability involved in performing cash handling functions, it is important that only authorized employees handle monies for university business.   Employees are required to appropriately safeguard, account for and document all cash maintained on behalf of the University.    The cash should be maintained in a secure, locked device or some other location appropriately approved by the Controller’s Office.
 

Applicability

This policy is applicable to every University department, administrative office, and affiliated organization involved in handling any University cash.  Employees with any type of cash handling function are required to be familiar with the requirements of this policy.
 

Authority and Responsibility

Texas Woman’s University has delegated the authority and responsibility for establishing policies and procedures for all cash handling activities to the Controller’s Office.  In carrying out this duty, the Controller’s Office is responsible for:

1. Establishing and enforcing policies and procedures governing the receipt, handling, custody, and disbursement of funds.
      

2. Requiring the establishment and maintenance of records accounting for funds received and paid by the University.
        

3. Performing periodic audits of departments with cash handling operations.
       

4. Establishing and authorizing banking depositories to be used for University funds.
        

5. Establishing and authorizing procedures for granting, maintaining, and terminating departmental research participant funds.

6. Reconciling all research participant funds on a monthly basis.

Segregation of Duties

Cash handling operations must be subject to daily supervisory review and management.  To minimize the potential for mistakes or misappropriation of cash, the segregation of cash handling duties is recommended.  The duties of collecting cash, maintaining documentation, preparing deposits, and reconciling records should be separated among different individuals.  In departments where the separation of duties is not feasible, strict individual accountability and thorough management supervision and review is required.
 

Written Departmental Procedures

In addition to the cash handling procedures established in this document, it is highly recommended that each department that manages a significant amount of cash, have its own specific procedures.  Written procedures should minimally include authorization of person(s) to act as the P.I., guidelines for the safekeeping of funds, procedures for usage of funds, steps for reimbursement of funds, and procedures handling overages and/or shortages including instructions on notifying the appropriate campus authority in the event of a loss.
 

Safekeeping

Departments handling cash are responsible for the safekeeping of these University assets.  Physical security should be emphasized to every employee involved in cash handling.  The following general guidelines should be followed to help maintain the integrity of those areas handling cash: 

• Unauthorized persons are not allowed in areas where cash is handled.
    

• Doors should be locked at all times in areas where cash is handled.  Safe doors should be kept closed during working hours and locked at times when it is not necessary to be in and out of the safe.
    

• Large sums of cash should be counted and handled out of sight of the general public.
    

• Individuals should keep working funds to a minimum at all times.  Excess funds should be in a locked device or deposited in the Bursar’s Office.
    

• Cash should NEVER be unattended.  This applies to cash registers, desk tops, and cash drawers.  If an employee leaves his or her work station for any reason, regardless of how briefly, cash must be appropriately secured in a locked place.
    

• For overnight storage and during other periods when cash is not being used, it should be kept in a safekeeping device, either a safe or locked container.
    

• Under no circumstances should an individual keep University cash with their own personal funds, deposit University funds in a personal bank account or take University funds to one’s home for safekeeping.
    

Refunds

Refunds cannot be made directly through the use of research participant funds unless specifically authorized.  All refunds should be processed through appropriate procedures as established by the Controller’s Office, depending upon the type of transaction involved.  These funds will not be used to reimbursement employees for out-of-pocket expenditures. 

Research Participant Guidelines

• Adequate documentation must be maintained to support all transactions made from the research participant fund.

• Expenditures must meet the legal requirements attached to the source of University funds used to establish the account.

• The research participant fund may not be used to circumvent University purchasing procedures.

• The following expenditures from research participant accounts are prohibited:
          - Travel-related expenses (e.g., parking)
          - Sales Tax
          - Alcoholic Beverages
          - Donations
         - Tips or Gratuities

• A research participant fund may be revoked at the discretion of the Controller.

• The amount of the research participant fund may be reduced at the discretion of the Controller.

Establishing a Research Participant Fund

• Complete a Certification for Cash Payment to Research Participants.  This form identifies the principal investigator, requested amount, funding source and justification for payment to research participants.
   

• Forward the certification form to the Office of Research & Sponsored Programs (O.R.S.P.). O.R.S.P. will check to confirm Institutional Review Board (I.R.B.) approval.
   

• When I.R.B. approval is confirmed, O.R.S.P. will forward the certification form to the Controller’s Office.
   

• Once the form has been reviewed and approved by the Controller’s Office, a check will be issued to the P.I. to establish the research participant fund.
   

• The P.I. will be notified when the check is available for pick-up.
  
  
   

Duties of the Principal Investigator

Each research participant fund established is specifically assigned to one individual who is designated as the P.I. This individual should have exclusive access to and control of the fund.  In carrying out the duties assigned, it is the P.I.’s responsibility to understand and follow the procedures below:

1. The principal investigator is responsible for dispersing funds according to allowable costs set forth in the approved grant budget and according to the cost principles of the grant.

2. Research participant funds must be properly safeguarded.  The P.I. is personally responsible at all times for the appropriate and adequate safekeeping of these funds. The money should be kept in a secured, locked location and should never be commingled with an individual’s personal funds or any other University funds.  Only the P.I. and the department head should have access to the keys or safe combination.

3. The P.I. is responsible for keeping accurate records of the fund. A Participant Payment Log must be maintained.  Each time monies are withdrawn from the fund, a participant payment log should be appropriately completed.  This form shows the name and signature of the participant along with an address, amount, date and P.I. approval.
    

4. The P.I. should maintain appropriate records on a daily basis, as this research participant fund is subject to audits, at all times, by the Controller’s Office, the Internal Auditors, and State Auditors.

5. Departments are required to forward the participant payment log’s to the Controller’s Office by the 15^th day of every month.

6. The P.I. will be personally accountable for the research participant fund until all of the funds and/or participant payment logs have been submitted to the Controller’s Office and the account closed.
    

Overages and Shortages

Both overages and shortages should be noted and tracked by the P.I. and then reviewed and certified by a department supervisor.  Significant amounts should be immediately reported to the Department Head and the Controller’s Office.  If there appears to be a growing pattern or anything unusual or strange about the overages and shortages, that information must be disclosed immediately.