I strongly oppose the adoption of these policies. The safety and privacy of research participants should be the priority of UIC, and these requirements will inhibit the trust and respect necessary to work with and for local communities.

As someone, who conducts most of his research online, targeting globally distributed populations, these requirements will make it practically impossible for me to collect data. In many developing countries, for example, it may be impractical for them to receive a check from the US. Also, as someone surveying people living under opressive regimes about their political views, I may put them in danger by requiring them to identify.

On a different note, prohibiting the use of personal funds for research may significantly hinder the work of graduate students, many of whom are actually willing to spend their personal, hard-earned, funds to compensate their participants. Unless the university provides adequate funding to support gradaute student research, implementing such ban will hurt our marticulation rates and, in some cases, literally kill gradaute students' research.

I strongly urge that these guidelines not be adopted, particularly related to tax identification numbers for nonresident aliens and no personal payments of participants. As many others have noted, the policy for nonresident aliens creates a barrier to research with vulnerable populations, which has negative implications for the University mission to reach underserved populations, the ethical responsibility to protect vulnerable populations, and the need to reach scientifically valid conclusions through representative sampling. Researchers (such as myself) who predominantly study these populations will also have a difficult time continuing their research agenda. Additionally, not allowing personal payment of participants will decrease graduate student ability to conduct research and complete their Ph.D., as graduate students often do not have funding and pay for their dissertation out of pocket.

I strongly oppose this rule change. It is unethical and would contradict the university's mission and values of serving communities and people of color. It would ruin community relationships with the university, and discourage individuals from participating in research.

I strongly urge that these guidelines not be adopted. The goal of our work is to partner with communities and work to remove injustices and structures that inhibit health and well-being and this policy directly thwart that mission. It will create a barrier to research and evaluation participation that will ultimately harm research endeavors, the University's relationship with these communities, and will inhibit the work that aims to find ways for communities to better promote health and wellbeing. 

Elizabeth Jarpe-Ratner, Evaluation Director, MidAmerica Center for Public Health Practice 

I strongly oppose this policy change. Aside from the complete disregard of any consideration of the ethical implications of the proposed change, it is also discordant with the mission of the University of Illinios at Chicago. This mission include commitments to underresourced and underprivileged communities. 

Furthermore, as a new faculty member who came here to conduct community engaged research with a population that includes a variety of immigration statuses, this policy change could impede my (and others'!) work to such a degree that we might have to take our research (and grant dollars) to another institution.

Thank you for the new FAQ, which includes this information:

"Yes, OBFS and the customer focus groups reviewed a number of human subject payment policies prior to drafting this policy.  This review demonstrated that there is no consistency amongst universities to address the IRS reporting requirements.  Policies for payments to nonresident alien human subjects ranged from (i) the extreme of not allowing payments to human subjects who are nonresident aliens if they have not obtained authorization from their sponsoring agency to receive compensation to (ii) requiring tax identification numbers be obtained only if it is known a human subject is a nonresident alien.  The University’s policy proposed is in the middle of the spectrum of the policies reviewed to ensure compliance with mandatory IRS reporting requirements."

If a policy must be adopted, I strongly urge you to adopt policy (ii) (only ask for ITIN if the subject is known to be a nonresident alien -- to the investigator or to the payer, I'm not sure which) rather than try to fall in the middle. Proactively choose a policy that puts the safety of research subjects and the ability to conduct valid research first.

The proposed change directly violates federal law regarding the protection of human subjects participating in research (The Belmont Report).  It is not clear that any currently IRB-approved studies would continue to meet ethical standards if the proposed change was implemented, as we would be  a) endangering a specific subset of participants, b) treating participants differently based on their immigration status, or c) conducting biased sampling.

I strongly urge OBFS to reconsider this proposal. I deeply oppose these proposed changes for compensating potential research volunteers. The purpose of an Institutional Review Board review is to minimize risk and eliminate potential harm to prospective research subjects. This proposed change would work in direct contravention to this stated purpose.

To continue with this proposal would put potential research participants at unnecessary level of risk. This burden is unnecessary and should be avoided. I work closely with UIC’s Survey Research Laboratory because they conducted scientifically sound research; the proposed change puts our relationship at significant risk. This proposal is not good for participants, and not good for UIC. I am ashamed that my alma mater would even consider this policy. This is not what is expected of a research-intensive university.

"Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements."

Several of our PIs expressed the concern about this policy breaches the confidentiality requirement of human subject research.

I work at Enlace Chicago, a community-based organization that has done research with UIC. Requiring studies to ask about citizenship status will effectively make it impossible to do research with undocumented residents, a vulnerable group that is already difficult to get to participate in research. This will negatively impact research and practice. 

Kevin Rak

Data Specialist, Enlace Chicago

I strongly opposed this policy change as it is unethical and puts vulnerable populations at risk. This policy change should not be implemented. 

I am strongly opposed to this policy change. This policy proposes the implementation of an unnecessary risk to some of our most vulnerable populations. 

I am strongly opposed to this policy change affecting payment of very small funds to non-resident aliens. It will make it all but impossible to do any kind of research with undocumented communities. This is fundamentally at odds with what President Kileen has U of I as a Welcoming University. 

I deeply oppose these proposed changes for compensating potential research volunteers. The purpose of an IRB review process is to minimize, if not eliminate, risk and potential harm to prospective research subjects. This proposed policy change would work in direct contravention to this stated purpose. These reporting guidelines would put immigrant research participants, especially Latinas/os, in great risk given the increased surveillance by federal authorities against all immigrants, in particular those who lack documentation. In addition to the clear ethical violations this proposed policy would create, it will undermine the research mission of the University of Illinois System. Any researcher who is involved in volunteer recruitment knows how difficult that process is in the best of conditions. If these changes are allowed to go into effect, then they will make recruitment substantially harder. In the long-run, this could even have the effect of researchers leaving Illinois to do their research at institutions without such regulations, and could even impact our ability to recruit future researchers.

I am opposed to new policy and its requirement that researchers inquire as to the immigration status of study participants. It is unethical, will interfere with research, and contradicts UIC's stated policies on immigration and documentation.

I have grave concerns about whether this revised policy is ethical or not. I urge the OBFS to solicit and publish statements from the University's ethics officer and IRB officials on their interpretation of the ethical status of the proposed changes. As many other people have posted, this creates an additional danger to people who are not US citizens. This is not a hypothetical danger either. I'm sure you are aware of the case some years ago of the Iranian student at UIUC who got into huge trouble for taking part in a study and being paid a very nominal sum. An internal account audit somehow obtained payment information, realized the student was not allowed to earn $20 and reported them to the authorities. Isn't it strange we don't talk about that real world case in our IRB training?

I am absolutely opposed to this proposed policy change. The University of Illinois frequently claims to be invested in the well-being of its students. If this policy were to be implemented, the message would be clear: the University of Illinois cares for SOME students, but chooses to treat the others as though they are not humans. 

This policy change should have never been an option, and it certainly should not be implemented. 

I am against researchers being required to ask for documentation of citizenship.  It hampers research on important topics facing our nation.  As a member on the CEAB, we are always asked about increasing subject numbers.  Adding this burden to researchers will greatly reduce their credibility.  Similar issues have occured in the past with police outside places where drug studies were taking place.  That greatly increases the risk for the subject.  The more personally identifiable the subject is the greater the risk.  

This would be an egregious mistake.

To whom it may concern:

I strongly oppose this or any other change to university policy that discriminates against people on the basis of their immigration status, including undocumented status.  

Such changes are wrong for participants.

• They put people at risk of being exposed as undocumented.  This can open people up to harassment, discrimination, or violence.
• They make it harder for participants to be compensated for their labor.
• They make it harder for students to find opportunities to learn about research.

Such changes are wrong for researchers.

• It is already incredibly difficult to find participants, but these changes would only make it harder to find enough participants to conduct meangingful research.
• It is especially difficult to find enough participants to conduct research on special populations, like undocumented immigrants or DACA recipients.  Researchers who need these unique participants will be hit the hardest, and the diminished quality and/or quantity of their research will influence their career trajectory.

Such changes are wrong for the University of Illinois.

• The University of Illinois is rightfully regarded as a powerhouse of high quality research.  Making it harder to obtain participants will damage our research and our reputation.
• The University of Illinois also prides itself on its diversity.  This or similar policies undermines this inclusive spirit.

These days it seems like I get an email every other week telling me how devoted to diversity and non-discrimination this university is, but those are just words.  If you mean it, prove it.  

Thank you,

Emily K. Sanders

Doctoral Student

Social Psychology

I oppose this change. Our research studies require the participation, observation and investigation of diverse populations. The research questions we concern ourselves analyze conditions outside the norm. We often include persons with a diverse backgrounds, age, race, ethnicities, gender, locations, etc. Examining populations with diverse backgrounds help identify resolutions for a broad segment of our populations and not isolated segments.

We recruit and seek to include human subjects that fit requirements to study our concern. We ask them to trust us and agree to do no harm. We protect their privacy and confidentiality in response to their participation and trust. These are difficult conditions for vulnerable persons. Requiring payments to non-residents in a research study to be made by check, complicates recruiting members of the population we seek. This increases a non-diverse sample and results may not be as meaningful for all. Please allow for non-residents confidentiality and do not change the requirement. Allow them cash payments and to be treated fairly along with the all other study participants.

I'm surprised this is even legal because putting human research subjects at more than minimal risks completely goes against the legislation put into place via implications from the Belmont report. Additionally, I find it hard to grasp how the scientific research concerning humans will be as reliable as before since it is basically excluding a whole subset of people. This issue isn't relevant to science, science needs to seriously consider the safety and wellbeing of all human research subjects.

This policy change is unethical and should not be implemented. I strongly oppose this policy change.

I also strongly disagree with this policy. With more research being done in undergraduate learning, I fear this policy would deter, instead of encourge, students to avail themselves of the learning and tutoring services provided at UIC.

- Tim Boester

Director, Mathematical Sciences Learning Center

I am against this policy, I do not believe that it is ethical to ask study participants about their documentation status. The research that we do is to serve vulnberable populations, the undocumented being one of them. If this policy goes through, we will be doing a diservice to marginalized groups.

This policy change is unethical in how it targets undocumented people. This change should not be implemented. I strongly oppose this policy change. 

I am strongly opposed to this proposed change. I am opposed to a policy that requires research participants to disclose their immigration status.

I am extremely opposed to UIC collecting information regarding immigration status from any research subject. As a university with Chicago in its name and with Chicago being a sanctuary city, how can this be occurring in 2017. UIC has been a university that embraces diversity, promotes inclusion and generally encourages others to do the same. This act goes against everything the university says it stands for. I encourage the administration to take a good look in the mirror and reassess how it is living up to its vision and mission.

1. This policy stands to violate several policies upheld under the Office of Protection of Research Subjects, including those pertaining to confidentiality and equitable treatment across populations. Specifically, this policy would jeopardize recruitment efforts if the human subject is anonymous and if the research is aimed to address health among communities with a larger than average number of non-resident aliens, including Latinos and other minority/immigrant groups.

2. By jeopardizing and delaying our ability to conduct research is such communities, this policy may impact individual researchers, such as myself, in our ability to secure future external funding.

3. In addition, this may add additional burden to current researchers,such as myself, having to apply this new policy process to open/ongoing approved IRBs. Especially if there is ongoing recruitment.

4. The proposed policy change would effectively create unequal participation barriers for non-resident aliens by requiring that researchers ask for documentation and forbidding cash incentives when participants do not have documentation.

I ask that this policy not be put forth as it may create further barriers to recruitment and instill an envelope of mistrust from future/current participants toward researchers and additional program outreach staff.

I agree with many of the concerns expressed here. This by Timothy Johnson, Director, Survey Research Laboratory, captures it well:

I strongly urge OBFS to reconsider the proposal to require new tax reporting procedures for payments to non-residents. Our research projects avoid asking about residency status out of respect for individual's privacy and the legitimate concerns of some that revealing this information can place them at risk for deportation. This becomes a serious risk of research participation, one that my colleagues and I believe can and should be avoided.

--Timothy Johnson, Director, Survey Research Laboratory

I strongly oppose this proposed rule change. Asking subjects about their immigration status hugely raises the risks research poses to them and therefore rightly inhibits them from participating in research. My research is with religious and racial minorities, who are especially impacted by such concerns.

I strongly oppose this policy and urge OBFS to reconsider. This policy compromises ethical standards concerning the protection of human subjects as privacy and confidentiality cannot be maintained if the legal status of participants, and the incentives they received for participating have to be reported.  

I strongly oppose this proposed policy. This policy is discriminatory, unethical, and unnecessary for research purposes.

If approved, this policy will create barriers to participation in research study that might affect the representativeness of the samples for research studies. It will also contradict the University of Illinois' efforts to maintain and promote a diverse, safe, and equal study and research environment. Finally, it will turn researchers into immigration officers by obligating them to check participants' legal status, which is definitively not their role at the university.

I oppose requiring human subjects to disclose their immigrant status. Such a requirement seems to go against many of the principles involved in the ethics of research with human participants, particularly that of confidentiality. More generally, it seems to go against the idea of UIC being a partner with and serving the Chicagoland community. 

UIC announced that they would stand on the side of immigrants and including all the undocumented. I was proud when the school made voices to fight for ridiculous policies and orders. But what is this for? Haven't you sent out an email, saying anybody in the campus would not have responsibility to report one's immigrant status, even if asked by government officer? Then why study participants should report their status to participate in research? 

This will seriously be a downer. The quality and quantity of research will go down. You don't want to make UIC as a better research school? Well, looking at this, obviosuly you don't. 

I strongly object to the requirement that researchers obtain information on respondent documentation status. This will likely reduce research participation among all foreign-born communities, and poses substantial barriers to scholars attempting to conduct research. Part of the "bargain" of many research endeavors is that the people being researched are allowed to maintain their anonymity, or at least privacy, particularly when identity- or behaviorally-linked attributes may amplify the risk for human subjects. The "legal" question is just such an example.  Requiring differential treatment of and documentation for participants based on their documentation status is problematic for researchers, and essentially puts them in the position of becoming "soft" enforcers of immigration law. We cannot enact this policy without putting many in our community at risk, damaging the ability of UIC scholars to conduct rigorous research, and frankly, without diminishing our reputational status among peer institutions and ability to compete for top intellectual talent.

Amy Kate Bailey, Assistant Professor, Sociology

I oppose this policy proposal. 

I strongly oppose this proposed policy. Researchers should not ask for a participants immigration status and cash incentives should be open to all participants. 

I am extremely worried and unhappy to hear about this proposed change. Asking participants to disclose their immigration status immediately adds extra (unnecessary) risk to their participation in research studies. These challenges make it far less likely that researchers could conduct quality research about a variety of topics related to race and ethnic background and also could consistute greater harm in the research that they already undertake. I strongly oppose such a change to our research policies.

I strongly oppose this proposed change.  I am against any policy requiring research participants to disclose their legal status. 

Lorena Garcia, Sociology and Latin American & Latino Studies

While unofficial legal status maybe in question with the current law and conversation in our country to force school officials to comply with the law is unethical and not their job to kick undocumented people out their job is to provide a space for those getting an education and if they qualify they should be left alone to study what happens to outside after our before enrollment is between them and law officials.

I strongly oppose this proposed policy.  In addition to the adverse consequences to a vulnerable population, which in and of themselves are sufficient reason to oppose the policy, it would also make it virtually impossible for research with any populations to happen.  By implication, the policy would require that researchers who want to study *any* population would have to ascertain the status of *all* of their subjects.  These are sensitive questions, even more so in recent months, and asking them would automatically increase the potential risks to the subjects and undermine the quality of the data collected.  On a practical matter, it would require almost all of our IRB protocols (any that involves respondent/subject paymetns) be redone.  And I suspect many would find it impossible to gain IRB approval with these new requirements.

So undocumented immigrants are no longer human? Or are they human enough for you to study for bogus surveys and then not have to pay them? Fine tradition of exploration! 

Requiring undocumented students to out themselves is unnecessary, ridiculous and dangerous. Why is this even being put on the table? Absolutely not.

Having worked with community based participatory research with many undocumented participants, I strongly urge not passing these policies. Working with vulnerable populations requires a building and trusting relationship. Many members of these communities live in fear, and are strongly opposed to institutions because of the consequences that may occur. To require individuals to dispose of this information will break established bonds and set research and advancement behind. It would erase strides that have been made. This would just give vulnerable communities another reason to hide. 

I, as a daughter of undocumented immigrants and current student at the UIUC, strongly oppose a change in policy that would require non-resident "aliens" to provide documentation in order to participate in research. 

The University of Illinois at Urbana-Champaign prides itself as an institution whose "research drives life-changing innovations, permeates our classrooms and fuels our outreach" (http://illinois.edu/research/). I strongly believe that passing a policy of this sort would affect the quality of research and hurt its reputation. In fact, this would also put into question the Inclusive Illinois campaign and commitment.  

Researchers should continue to compensate their subjects WITHOUT asking them for documentation; this is extremely harmful and unethical. A change of that magnitude perpetuates marginalization and criminalization. It's not respecting and incorporating the identities Inclusive Illinois commits to uphold. 

All in all, I STRONGLY OPPOSE this discriminatory change. 

- Inés Nava, Senior at the University of Illinois at Urbana-Champaign 

I vehmently oppose any policy that requires researchers to request documentation from research participants and forbids cash incentives for undocumented participants. These policies directly contradict UIC's commitment to diversity, and cannot be separated from racist and xenophobic discourses, particularly in the present cultural and political environment. Undocumented persons are already underrepresented in research, and this policy will create further barriers to including them. As a scholar in disability studies, we are becoming increasingly aware of the ways in which threats of deportation, incarceration in immigration detention centers, and racist/xenophobic cultural rhetoric is disabling. We need more research that explores these complex issues, but these policies will make that impossible. As a university, we should be eliminating barriers to research participation for marginalized groups - not creating and reinforcing them. 

Hailee Yoshizaki Gibbons

PhD Candidate in Disability Studies 

Please do not pass this. Requiring undocumented students to out themselves is unethical and dangerous. 

There is a longstanding tradition in this country when individuals with undocumented status are paid less their citizen counterparts. The removal of cash incentives for participants of this study that do not satisfy a certain immigration status is a microcosm of an already pervasive and exploitative trend. Education is touted by many to be the universal equalizer. For this reason, it is problematic and harmful for this institution of higher education to single out select participants based on their immigration status.

I strongly oppose this policy of researchers asking for documentation and forbidding cash incentives when participants do not have documentation. This is discriminatory and as a university we shoud enable everybody to participate in research rather than make it hard. 

Piyush Labhsetwar

I strongly urge OBFS to reconsider the proposal to require new tax reporting procedures for payments to non-residents. Our research projects avoid asking about residency status out of respect for individual's privacy and the legitimate concerns of some that revealing this information can place them at risk for deportation. This becomes a serous risk of research participation, one that my colleagues and I believe can and should be avoided.

--Timothy Johnson, Director, Survey Research Laboratory

I vehmently oppose any policy that requires researchers to request documentation from research participants and forbids cash incentives for undocumented participants. These policies directly contradict UIC's commitment to diversity, and cannot be separated from racist and xenophobic discourses, particularly in the present cultural and political environment. Undocumented persons are already underrepresented in research, and this policy will create further barriers to including them. As a scholar in disability studies, we are becoming increasingly aware of the ways in which threats of deportation, incarceration in immigration detention centers, and racist/xenophobic cultural rhetoric is disabling. We need more research that explores these complex issues, but these policies will make that impossible. As a university, we should be eliminating barriers to research participation for marginalized groups - not creating and reinforcing them. 

Hailee Yoshizaki Gibbons

PhD Candidate in Disability Studies 

I am strongly opposed to the requirement of documentation and forbidding cash incentives when participants do not have documentation. This is very discriminatory towards undocumented students. As a campus we should help everyone get education and participate in research not restrict them becuase of their documentation status.

I OPPOSE forcing students to disclose their citizenship status when participating in research. It is unjust, unethical, and unneccessary. 

I strongly oppose the new amendment requiring the requirement to ask participants for their  residential status. 

I am strongly opposed to any policy that requires someone to disclose their immigration status, and that treats people differently based on that status. This is not only unethical, it's bad policy that will hurt participates and researchers alike. 

I am strongly opposed to this proposed policy change.

I firmly believe that the disclosure of immigration status poses a risk to our research participants, and that it will lead to the degredation of our University's research.  Trust built with participants, especially hard to reach or at risk communities, is critical to any quality research study.  I feel that this policy change represents a potential breach in that trust, and that it will ultimately serve as a barrier to participants.  The University of Illinois serves everyone in the state, regardless of immigration status, and that this should be reflected in our policy. Furthermore I believe it to be unethical to pay participants differently based on their immigration status.

As apart of UIC's mission to be a leader not only in Chicago, but propelling all great cities into the 21st century we can not let this proposed change pass.  It reflects poorly on us as an institution, and is not in line with our values of inclusivity. 

I am against any policy requiring research participants to disclose their immigration status, and that paying participants differently based on that status.

I strongly oppose thispolicy change requiring disclosure of immigration status as it goes against what UIC stands for. There's no point in implementing this policy as it would cause harm to UIC's reputation and hinder research.  

I oppose this policy. It is unethical and violates the privacy and confidentiality of research participants, and may increase the risk of harm to participants. 

Thank you for soliciting feedback.

I agree with my many colleagues, asking individuals to report their immigration status is unethical and will likely result in fewer research participants and hurt our understanding of issues facing vulnerable populations.

I strongly oppose this and am extremely disappointed that this is even being proposed here at UIC. While being a student at the School of Public Health and working to bridge the inequities in health care, especially for minorities, it would highly disappoint me if we did not practice what we preach. I don't believe that it would be fair to pay undocumented research participants any differently, and as a researcher, I don't feel comfortable asking a participant their status. My goal as a researcher is to gather the information I need to work towards improving our understanding of certain health conditions. A participant's documentation status is none of my business, and I do not want to treat them any differently. My goal with research is to improve an individual's health, not inquire about their documentation status.

I agree with the GEO's stance on this policy being unethical and harmful.

"GEO opposes this policy on the grounds that it is unethical and constitutes extreme risk of harm for research participants by violating their privacy and potentially depriving them of compensation for their time and efforts in research. Further, the proposed policy violates UIC's own statements of being a welcoming university for all, regardless of documentation status. We believe the proposed policy change will stifle ethical and meaningful research at UIC."

Thank you for the opportunity to provide comments on the proposed policy changes.

I am deeply concerned that requiring research participants to disclose their immigration status (and recieve payment in a different manner) would violate the privacy of the individuals in question, not to mention decrease the quality of data and diverse responses that bolster research findings. UIC should be setting an example of thoughful and inclusionary research, I am afraid this policy does the opposite. Please reconsider. 

Sincerely,

Marisa Wishart, MPH candidate, CHS/MCH

I am strongly opposed to requiring undocumented individuals to report their status. As a scientific community, we have already created strife within vulnerable populations based on past research practices.

Not only will this amplify the mistrust that stands, but it will perpetuate resistance to participate in research and add to the health disparities that already exist in scientific research.

As an alum of UIC, I strongly oppose the change in policy asking non-resident aliens for documentation in order to participate in research and eliminating cash incentives. Don't make your researchers police an overly policed and vunerable population. It will have terrible effects on research, because of the mistrust that will develop between the University and the community, also you would be violating your own non-discrimination policy. 

Paying "non-resident aliens" differently is unethical. They are sacrificing their time and bodies to help the advancement of science and medicine. To treat them and pay them differently because of their residency status is horrific and only exacerbating an already vast gap in health outcomes between gender, SES, race, and residency status.

Asking undocumented individuals to disclose their status poses a high risk to their involvement in research; should the data be compromised, or the University be required to deliver such data to federal law enforcement, the livelihood and safety of undocumented participants would be greatly threatened. These changes to UIC's research policy would limit UIC researchers' ability to gather knowledge on diverse sets of the U.S. population, and a commitment to such research is a cornerstone of the UIC mission. I strongly oppose the enactment of this policy change.

-Class of 2020 Student, College of Medicine

I am opposed to forcing "non-resident aliens" as it exposes individuals to potential harm, it is unscientific, and it is against the University's mission of offering a safe and welcoming environment for all. 

BA - Student 

Theses changes could pose significant harm to immigrant communities, foster mistrust of research, and harm UIC's reputation as an institution. Researchers are not ICE agents. Please do not require researchers to determine participants' immigration status. As a UIC grad student and researcher, I am strongly opposed to the proposed changes. 

I strongly oppose the new amendment requiring the requirement to collect residential status for study participants. Limiting the ability of UIC researchers to study immigrant populations will harm the university's mission of celebrating diversity and inclusion. It will additionally harm Chicago residents as disparities research is an area UIC's researchers excel in. 

For those of us who do research among marginalized and hard-to-reach populations, requirements related to gathering individual identifiers, such as SSN, for tax purposes and distribution of incentives, have always posed an ethical dilemma.

The proposed changes related to non-resident aliens i.e., that "non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements", in essence require all human subjects researchers to ask their participants their immigration status. This creates any number of additional practical and ethical problems, which should be self-evident to any entity that is truly invested in the protection of "human subjects". The discontinuity between IRB policies, accounting policies, and the stated mission and vision of many universities has been ignored for quite some time, and this proposed change furthers this disjuncture.  

I am strongly opposed to this proposed change. 

Inquiring about immigration status is inappropriate, irrelevant and unethical. It is equally inappropriate and unethical to then treat undocumented particpants differently. This type of discriminatory practice should not have a place in UIC's research protocol. I sincerely hope the administration reconsiders this change. 

I am commenting in regards to changes to Section 8 and Section 18.10, especially regarding the nonresident alien changes.

I'm against the proposed reporting requirements regarding “non-resident alien” human subjects and want it removed from any policy updates. The language is racist, the policy would go against UIC's commitment to intellectual freedom, and it could potentially pose harm for those involved. 

I oppose the proposed update concerning requirements to inquire about immigration/residency status to fulfil IRS requirements.

I oppose these changes because they directly contradict the Belmont Report principle of beneficence (that makes the researcher responsible for the physical, mental, and social well-being of the research participant) and go against IRB concerns about ensuring privacy and confidentiality when performing research with human subjects.

I oppose these changes because they directly contradict one of UIC’s strategic priorities,i.e., Chicago and Community Involvement. Indeed, the mere mention of immigration/residency/citizenship status when recruiting research subjects is likely to distance and alienate exactly those vulnerable communities our university is most committed to.

I oppose these changes because, by adding another layer of bureacracy in the payment/reporting process, it unecessarily creates additional burden to research faculty and staff.

Hi. Please do not make changes that would translate to requiring knowledge of immigration status. Always but now especially - under the current U.S. administration - taking this action can only bring much more harm than good. 

I would like to echo the sentiments made here that asking "non-resident aliens" to out themselves is bad policy. This community has been further marginalized by direct and indirect messaging by the current U.S. government administration and makes collaborating and including this community in research an even greater challenge. Such a policy exacerbates the issue and cripples research even further. Beyond research, this policy contributes to the current messaging by the government of 'non-resident aliens' place in our society and puts in harms way the university's mission of inclusion.

Did someone just not think this through?  UIC researchers have been leaders in conductung research with Latinos and immigrant populations.  A policy requiring people to reveal their immigration status is unethical and may lead to exposing people to something that may be harmful to them. Furthermore it would end research with Latino populations at UIC.  

I oppose the proposed changes that require researchers to ask research participants about their immigration status.  This will impose an unncessary risk on undocumented research participants and would infringe on the right to privacy that research participants are entitled to. 

This proposed policy change is deeply disconcerting to me. A person’s residency status has no impact on our research which involves people with co-occurring mental health/physical health conditions. I’m very concerned that by including this question in our interviews, some participants may become untrusting of the research process. Though, even more importantly, it may cause serious distress. To me, this proposed policy is contrary to the University’s ethics in terms of respecting diversity, and seems to demonstrate ethnic profiling of a disenfranchised community. This could very well jeopardize important community partnerships, recruitment efforts among this specific population, as well as funding opportunities by agencies who reject this type of unequal treatment of a vulnerable population.

I OPPOSE the reporting requirement for "non-resident aliens." The existence of this requirement will have a chilling effect on our relationship with immigrant communities as research partners that will extend far beyond the individuals who receive payment for their participation. It is crucial that the University be an ally to the immigrant community, and the single most important tenet of this friendship is non-discrimination based on immigration status.

I am adamantly opposed to forcing "non-resident aliens" to out themselves as a prerequisite for participating in research. It is unethical as it would expose human subjects to potential harm, it is unscientific as it would hinder meaningful research, and it is inimical the University's professed mission of offering a safe and welcoming environment for all. Please scrap this terrible idea.

Jeff Schuhrke

PhD student, History Department

I strongly oppose the proposed policy, specifically the portion: 

Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements.

This proposed change directly contradicts the ethical principles that are the foundation of research with human participants.  Namely, a respect for participants' right to privacy and the right to have participation treated confidentially.  Furthermore, this proposed change also stands in direct opposition to our purported mission as a University, which is one of "access, equity, inclusion, and non-discrimination" (the Chancellors' exact words).  Given the current political hostility towards immigrants it is paramount that we as a university set an example and continue to act in ways that unequivocally reaffirm that our interest lies firmly in protecting and ensuring the rights of ALL of our students.     

Thank you for the opportunity to comment on your proposed policy changes regarding the residency status of research subjects at UIC (Section 8 - Payments to Human Subjects; Section 18.10 - Human Subject Payments and IRS Reporting Requirements). I’ve been involved in research with vulnerable populations for most of my career. I’m deeply concerned to learn about the possibility of being required to ask subjects about their residency status, and to pay them in a different way. Asking about residency status may inequitably increase the risk potential associated with research among many vulnerable groups, thereby violating the core tenet of beneficence that all UIC researchers have committed to via UIC OPRS-mandated training/certification. It also may affect our ability to recruit subjects into our research because we are required to tell them in advance the types of sensitive information we will be gathering. Hearing that we would ask about residency status, and treat people differently depending on how they answer, would likely negatively impact our ability to recruit. Also, it could tarnish UIC’s reputation as one that values diversity and work with vulnerable populations. Additionally, we are able to conduct high quality research because of the relationships we’ve worked hard to form with organizations serving vulnerable populations. A policy such as the one being considered is likely to jeopardize our existing community partnerships, as well as our ability to form new ones, which would negatively impact our ability to conduct and/or receive extramural funding for our research. For all these reasons, I oppose this policy and ask you to reconsider it.

Collecting data identifying the documentation status of research participants places them and their families at significant risk of harm. It creates a barrier for these individuals to participate in research while eliminating their privacy and confidentiality. This potential policy change places UIC researchers in the position to inflict harm on an extremely vulnerable population. In addition to the direct harm to undocumented participants and their families, this policy would also disrupt research at UIC and undermine UIC’s commitment as a land grant institution to the community. Do NOT implement this policy change!

The proposed policy change requiring that undocumented immigrants (inapropriately and harmfully called "aliens" in the policy) disclose their immigration status and receive reimbursement through different routes than documented residents will severely limit the University's ability to conduct meaningful research among undocumented immigrant populations. Under the current federal administration this research is absolutely vital and it is unconscionable that this university would move to undercut its researchers in this way.

I am a MPH candidate at UIC SPH and I strongly oppose the stipulation in this policy change requiring disclosure of immigration status. To do so would be malpractice. 

Claire Simon

Master of Public Health Candidate

Community Health Sciences

The proposed changes would pose a great and unreasonable risk to participants and their families who are already at increased vulnerability.Undocumented immigrant students are one of the most vulnerable populations on college campuses. Passing such a proposal would not only cause direct harm to these communities of students, but would significantly limit the research of faculty and students at this institution. 

I strongly urge you to reconsider the changes listed above. My specific arguments and requests are in total agreement with a letter you should have already received, co-signed by professors from the Psychology department, School of Public Health, Institute for Minority Health Research, Nursing, Learning Sciences, Race & Public Policy, and others.

As an additional note, this policy would be particularly harmful for the psychology department. Considering that introductory psychology classes require participation in UIC research projects, this would likely have a detrimental effect on student enrollment and participation in psychology.

Inquiring about residency status (non-resident alien) is not a research practice.  Has OBFS included The Office of Protection of Research Subjects regarding this proprosed policy?  What about anonymity and confidentiality of the human subject?  This proposed policy raises serious concerns for protection of human subjects not to mention long standing relationship with university community partners.

Do not require researchers to ask participants about residency status. We can't ask participants to put themselves at risk. 

UIC should not require that researchers inquire about participants' immigration status. This is harmful to individuals who already experience great risk, and is in direct opposition to UIC's stated policy on immigration. It is wrong for the following reasons.

1. Collecting such data would present direct risk of harm to participants and their families; 

2. Including questions about legal status would create a barrier to individuals to participate in research studies and discourage equitable participation of subjects;

3.  Requesting these data from all participants would breach participants’ privacy; and

4. Collecting such data would alienate this already vulnerable population.

U.S. immigration law has not changed, and the Trump executive orders (travel bans) are currently being challenged in court. Why would UIC be compelled to change its policy on this issue at this time?

UIC can no longer claim to care about diversity and inclusion if it goes through with this policy. In a city with many communities already under constant fear of deportation and detention by immigration officials (regardless of immigration status at times with this new administration), how are we as researchers to establish any trust and reliability if we must question participants about their immigration status?

The requirement to include information regarding 'non resident aliens' not only violates standard procedural research ethics (thus undermining the quality of research) but also represents a movement away from the morally-oriented inclusiveness of UIC more generally. I don't see how it can be justified or in fact implemented.

Jessica Bird, Department of Criminology, Law & Justice 

I strongly oppose any change to our research policies that would require us to ask about a human research subject's immigration status. This proposed change could have serious consequences for people who volunteer for research, in that they could be targeted by law enforcement because of their status or fear that they could be targeted. Such fears have already affected immigrant communities in recent months, preventing people from living their normal lives or even from seeking medical care or help when they have been the victim of a crime.

This proposed change challenges our ability to conduct ethical research with human subjects. It presents a risk (unwanted attention from immigration enforcement) and a harm (fear of such attention) when neither is necessary to actually carry out the research. In addition, by the nature of this policy change to report income, it fails to keep potentially damaging information about human subjects confidential. None of these are ethical or morally acceptable ways to conduct research with human subjects.

Collecting unnecessary and potentially damaging personal information, and breaking subject confidentiality to report it to the federal government, is a transparently dangerous and unethical way to treat research volunteers that would never be considered with any other personal characteristic. Our commitment to the safety and confidentiality of research subjects has to be our first priority.

I am a Chicago community member, researcher and student at the University of Illinois at Chicago and vehemently oppose these changes as it pertains to undocumented status of research subjects. By forcing the status of the participant to be known we are immediately introducing bias and limiting our exposure to fulfilling our research goals. I urge the OBFS to reconsider these changes as we strive to provide accurate, innovative and equitable treatment of our participants, and community members alike.

As a state research institution, we are conferred some power in how we conduct policies that have the potential to inflict damage upon people. Asking undocumented immigrants negatively impacts the type of research that can be conducted and inflicts unnecessary harm for the participants involved, which would impact the data collected. Paying participants differently due to documented status is a form of discrimination. 

In short, the proposal to collect information from research subjects regarding undocumented status will cause direct harm to students’ well-being, health,  and sense of belonging on campus if enacted. The specific ethical problems with regards to research are outlined below:

1. Collecting such data would present direct risk of harm to participants and their families (Hernández, Nguyen, J., Casanova, Suárez-Orozco, & Saetermoe, 2013). These data could be utilized, subpoenaed and/or accessed by third parties to detain, deport, and/or otherwise harm students and their families (McLaughlin & Alfaro-Velcamp, 2015), which is not unprecedented as government officials have previously asked researchers to disclose the identities of their participants (Adler & Adler, 2001). This can potentially lead to officials having the ability to access information that could lead to deportations, which is a form of direct harm and remains a major fear for this population (Birman, 2005; Magaña-Salgado, 2014).

2. Including questions about legal status would create a barrier to participate in research studies and discourage equitable participation of subjects. For instance, the fear of having their information and status disclosed to authorities would discourage undocumented students from participating in research studies in the first place (Birman, 2005).

3. Requesting these data from all participants would breach participants’ privacy. It is common practice among leading scholars who work with undocumented populations to not collect these data at all or to take extensive precautions to ensure participant anonymity if they chose to collect this information (Teranishi, Suárez-Orozco & Suárez-Orozco, 2015; Suárez-Orozco & Yoshikawa, 2013).

4. Collecting such data would alienate this already vulnerable population (Lahman, Mendoza, Rodriguez, & Schwartz, 2011; McLaughlin & Alfaro-Velcamp, 2015) and further compromise their sense of belonging on campus. Such questions would predicate participation on "coming out of the shadows," which empirical evidence demonstrates will threaten students’ sense of safety, belonging and physical and mental health (Enriquez, 2011; Gonzales, Roth, Brant, Lee, & Valdivia, 2016; Huber & Malagon, 2007; Nienhusser, Vega, & Carquin, 2016).

5. The proposed change to have students disclose status disrupts UIC’s commitment to fostering an inclusive learning environment. “UIC is deeply committed to fostering an inclusive environment for students of diverse backgrounds including undocumented students. We take seriously our public mission and land-grant commitment to not only expand educational pathways for undocumented students, but also to ensure that they have high-quality educational experiences” (https://diversity.uic.edu/undocumented-student-support/). Fear of status disclosure, especially in the socio-political current climate, would limit the kinds of projects in which undocumented students can participate, and, in turn, would limit data PIs gather.

As a researcher who works extensively with undocumented college students, I have never collected information regarding legal status with any identifying information. Doing so would pose to great a risk to participants and their families who are already at increased vulnerability. Passing such a proposal would not only cause direct harm to these communities of students, but would significantly limit the research of faculty and students at this institution.

I strongly oppose inquiring about participants' undocumented status. Undocumented immigrant students are one of the most vulnerable populations on college campuses. While their status ensures access to K-12 schooling (see Plyler v. Doe, 1982), there are no such mandates for higher education, creating increased vulnerability for this population during this time of life (Abrego, 2006; Gonzales, 2011; Nienhusser et al., 2016; Perez et al., 2010; Suárez-Orozco, Katsiaficas, Birchall, et al., 2015). 

Roughly 10% of undocumented students who graduate from high school make it to college (Mendoza, 2010; Passel, 2003) as a result of the barriers that they face including lack of access to financial aid (Abrego & Gonzales, 2010; Diaz-Strong et al., 2011). Once they arrive on college campuses undocumented students face a series of obstacles in their daily lives such as a lack of access to resources (Chávez, 1998; Contreras, 2009; Teranishi et al., 2015), and discriminatory laws, policies and interpersonal interactions (Gonzales, 2011; Nienhusser, 2014).

 These experiences can negatively impact their physical and mental health (Sullivan & Rehm, 2005), social belonging (Gonzales et al., 2013) and family processes (Abrego, 2008). As a result of this vulnerable status, empirical evidence demonstrates that many students do not access resources that are available to them for fear of having to disclose their status (Garcia & Tierney, 2011; Munoz, 2013).  While few students choose to come forward with their status, the majority choose to remain in the shadows for fear of discrimination, violence, political persecution, and placing themselves and their family members in danger of deportation and family separation (Gonzales, 2016).

In addition, empirical evidence suggests that these vulnerabilities place undocumented students at increased risks for mental health issues such as increased anxiety and depression (Garcia and Suarez-Orozco, 2017; Gonzales, Suárez-Orozco, & Dedios-Sanguineti, 2013), a compromised sense of belonging  (Gonzales, 2011), feelings of isolation (Gonzales, 2016; Muñoz, 2013), and other forms of socioemotional distress including a sense of hopelessness, shame, and uncertainty (Perez et al., 2010).

Thinking first of immigrants' rights, the proposed non-resident alien change is terrible; it is a potential violation of the researcher imperative to protect informants from harm and also seems a violation of academic freedom. 

The proposed changes that would require researchers to ask all research participants whether they have residency documentation would put researchers in the position of harassing and intimidating research subjects, in violation of university policies to the contrary, and in violation of the spirit and letter of the human subjects training we all receive. Any researcher who followed this recommendation should be subject to investigation for ethics violations. I would ask that the OBFS staff meet with researchers who can explain the objectionable and dangerous consequences of this proposed policy prior to the next revision of the policy, assuming it will not go forward in this form.

Researchers should not be required to inquire about a research participant's residency status. Trust is essential in research relationships, and asking this question will create distrust.

I am writing to comment on the proposed change “Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements.”

From a research (and social justice) perspective, I have a major concern about requesting participants to disclose their immigration status, require additional paperwork to be completed, and only pay them by check. As indicated in previous comments, this requirement would be impractical and impact the quality of the work. It would raise distrust in the broader community, make the public question the intention of our work, and also increase the potential for inaccurate responses on surveys, in interviews, etc. This also would have an impact on students, requiring them to jump through additional hoops to receive reimbursement.

Why is our public university, likely on the chopping block in Betsy DeVoss' America REGARDLESS of its policies, and boastful of its inclusiveness in all recruitment material BENDING OVER BACKWARDS to anticipate the hateful, discrimatory, unethical & hypocritical politics of fearmongering and nativism? 

Paying subjects differently & even having to ask about immigration status will disrupt unbiased research & deter participation from studies, further marginalizing members of these communities in social policy discourse. The university should not make these changes.

Jeff Wheeler

MA/PhD student & Teaching Assistant

Department of History

I strongly OPPOSE this proposed policy change. Under the new rule, researchers would have to inquire about a participant's documentation status. As someone who does research with victims of sexual violence, asking about immigration status is the fastest way to lose someone's trust and to put their safety at risk. The goal of research is to maximize benefits and minimize harms. This maximizes harms and takes away any monetary benefits. It is one of the most unethical policies one could design for human subjects and deeply concerning to me and my colleagues.

I am against asking about subjects' resident status (I.e., "legal" or "illegal"). This is in direct conflict with the university's values to respect diversity and will make it extremely difficult to conduct research in immigrant communities where severe health inequities persist. The process would deter participation in research and the university's standing in immigrant communities. 

UIC should not make the change regarding “non-resident alien” human subjects as it will have a widespread chilling effect on our ability to conduct survey research and will bias answers and thus undermine the entire endeavor.

Generally when conducting public health surveying, one is looking for truthful and forthcoming answers. Asking potential respondents about their immigration status will:

1. Deter some from answering

2. Likely elicit inaccurate responses

3. Undermine UIC's position in the community

4. Promote racial or ethnic profiling

5. Bias results

6. Undermine public health efforts that rely on accurate reporting

This policy is in direct opposition to the Chanceler's position that UIC welcomes all students, faculty and staff, regardless of their resident status.

Anne Marie Murphy, Ph.D.

Adjunct Faculty

School of Public Health

I am concerned about the fact that UIC wants to ask all research subjects if they are legal immigrants or not, and if they are not, that UIC will have them fill out separate paperwork and receive separate reimbursement. Based on the teaching of the school of public health that has said it supports the privacy and safety of immigrants, I believe that this new policy would infringe upon those teachings. By implementing this policy we would confirm the political rhetoric that sees immigrants as "others".  Also, this would significantly impact the ability for UIC to do research with any immigrant community as these types of questions would break the trust that has been established between many researchers and the immigrant communities. Lastly, I believe that having the information stored would be very dangerous. Hospitals in Chicago are taking measures against being forced to give out immigration status information of their patients that they have stored to ensure the safety and well-being of their patients. Woud UIC be put in a difficult situation if UIC was asked to disclose this information?

The proposed reporting requirements regarding “non-resident alien” human subjects are deeply problematic on two key counts: (1) Information on citizenship status should requested or recorded for many or all human subject research projects, hence requiring a special procedure is impractical or impossible in many instances; (2) Requesting that human subjects express their immigration status and, presumably, proof of citizenship represents a huge impediment to scholarship in virtually every discipline at the University of Illinois and might place human subjects in an untenable position. Hence this particular change should not be implemented.

In the policies and procedures relating to payments to human subjects in Section 8 and Section 18.10, REMOVE THE FOLLOWING PROPOSED UPDATE:

• Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements.

Policies that single out “non-resident alien” human subjects would be a detriment to science and potentially put at risk an already marginalized and disenfranchised community. Individuals that are not comfortable sharing their citizenship status are already a hard to reach population for purposes of research and services. Having to directly ask them about this may completely deter them from participating in studies and not to mention the difference in payment processing that would make their information available to other government agencies, putting them at risk of further repercussions that would affect their well-being and that of their families.

I recommend that the university does not adopt this policy point for a number of reasons, "Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements."

1. This goes against the university's and the Chancellor's statement about protecting undocumented individuals.

2. This will erode trust that the university has established with communities with large number of undocumented individuals.

3. It is not the role of the university to police the communities we serve.

I request that the university NOT implement the proposed policy changes regarding the payment of “non-resident alien” human subjects. The policy is deeply concerning because this policy is in direct opposition to the Chanceler's position that UIC welcomes all students, faculty and staff, regardless of their resident status.

In the policies and procedures relating to payments to human subjects in Section 8 and Section 18.10, REMOVE THE FOLLOWING PROPOSED UPDATE:

• Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements.

Policies that single out “non-resident alien” human subjects would be a detriment to science and potentially put at risk an already marginalized and disenfranchised community. Individuals that are not comfortable sharing their citizenship status are already a hard to reach population for purposes of research and services. Having to directly ask them about this may completely deter them from participating in studies and not to mention the difference in payment processing that would make their information available to other government agencies, putting them at risk of further repercussions that would affect their well-being and that of their families.

I am very worried about the rule regarding disclosure of immigration status and payments to “non-resident aliens" hindering UIC's community partnerships and ability to recruit research participants. This does not live up to the university's promise to protect the undocumented individuals we work with. It is already difficult to gain the trust of subjects when they see we ask about documentation status. Given the current anti-immigrant political climate, this rule may appear to our community partners as especially egregious. I believe this rule will adversely affect UIC standing with the communities we work with and our researcher's ability to recruit participants and should not be implemented.

I appreciate all of these changes except the nonresident alien changes. Although I appreciate that Federal tax rules require form 1042-S (and potentially backup withholding) for any payment known to be made to a nonresident alien, as a researcher I am rarely interested in whether my participants are citizens or not and am concerned about the impacts of asking about their status (both in terms of the risk/benefit calculus for the participant and the potential resulting effect on the ability to appropriately and justly sample participants).

It appears that SSN/ITIN, etc. information is necessary from all participants when they are being paid by check. For payments by cash/gift cards, and particularly in confidential studies, where the university would normally not collect this information or file a 1099 for a citizen, it would be the responsibility of the participant receiving payment to report it for tax purposes. It would be consistent with this (and with UIC's justice commitments) to presume that any participants so paid who do not volunteer on their own initiative that they require backup withholding should not be treated differently based on their citizenship status. This would prevent researchers from being put in a position to ask potentially harmful questions (to which the participant might also have a fifth amendment right to refuse to answer). Consent forms for such studies could include language like "You are responsible for any income taxes on payments you receive. If you believe your payment is subject to backup withholding and would like to provide your SSN/ITIN to UIC in order to comply with that requirement, please let the investigator know. However, you are not required to do so in order to participate."

I request that the university NOT implement the proposed policy changes  regarding the payment of “non-resident alien” human subjects.  The policy is deeply concerning for several reason:

1. This policy is in direct opposition to the Chanceler's position that UIC welcomes all students, faculty and staff, regardless of their resident  status.

2. Asking individuals about residency status would change the benefit harm  ratio for many research particpants, and unfairly present risks to one specific group.

3.  Inequitable treatment/questioning of certain groups  will jeopardize hard won longstanding community partnerships and community stakeholders that work day-to-day in achieving equity for their communities.

4.  Due to the proposed policy/procedure University researchers and programs will risk losing the ability to secure future funding if the ability to recruit participants in an equitable manner is jeopardized.

5. Asking this information will alert students and communities that UIC generally and researchers from UIC are not "safe"  and any promises of anonymity in research is not trustworthy.    This will harm UIc's reputation and make recruitment very difficulty, in effect shutting it down. 

6. Research protocols do not propose one form of payment for one group and a different form of payment for another. If the cash incentive payment is removed as an option, it creates inequitable treatment of ‘non-resident aliens.’       This will likely be an issue with The UIC Office of Protection of Research Subjects (OPRS) as ‘non-resident alien’ human subjects will be treated in an unequal manner when participating in research.

I am encouraged by these proposed changes. Especially important is the ability to have multiple advances for multiple projects. The process time in between closing out one advance and getting a new one is very disruptive, and it's never made any sense that I can only have one advance for multiple projects that pay participants.

1. There needs to be more precise clear instructions on what documentation is needed to have on file in the event of an audit. There is nothing in the policy that states the documentation that will be looked at is the research documents that most business office personel has no access to. This should be specified in the policy.

2. There needs to be a mandatory meeting/training for PI's and business office staff in order to request an advance. This should cover all the details needed for reconciliation and documentation.

3. I would like to see more of allowable/unallowable cost for use with human subject payments. Example: a PI used some of the advance funds to purchase food and beverages at the focus groups locations for human subject participants. This is unallowable, but it is not listed anywhere and these items are part of human subject costs.

This policy still lacks the detail information related to reconciliation of the research data to the funds dispersed.  

This does not explain the level of detail required to be captured in the event of an audit (accounting of subjects, signatures, proof of payment)

This does not state that the person in which the advance is named, is personally responsible for the funds, even in the event of a theft.

The University has not addressed training needs for Business Office staff or PIs on the requirements or stipulations of Human Subject Research.  ie-documentation required, consent forms, approved IRBs (how is the department to know if the PI has this or not), allowable and unallowable uses of funds (PIs have used cash from Human subject money to purchase snacks for focus groups), (A different PI gave gift card(s) to the agency that allowed them to collect data at their location) 

Unallowable expenses and unreconciled studies then become an obligation of the College/Department- however the University's policy does not protect the College/Department from this risk.

This policy should be immediatly followed with required training for all PI's, business offices and University Payables so that everyone is completly advised prior to the issue of IRB approval and any human subject research of all implications, policies and proceedures of Human Subject Research.  

A few edits, comments, and suggestions.  Thank you!

1 - in the IRS Reporting Requirements for Human Subject Payments to Non Resident Aliens, the sentence about the Form 8233 seems oddly written - they should file the affidavit with UPB immediately prior to them entering the US.  the current wording makes it sound like the enter the US with UPB.

2 - Collection of Tax Id.. Number for Human Subjects section -- this is the first reference to an SSN being one type of a TIN when it refers to Section 19.  I'd suggest making an earlier example of what a TIN is and including it in the definitions section - other types of numbers are referenced on the Flow Chart - SSN, ITIN, HUID, FNIF - but I didn't see a definition of those acronyms anywhere.

3 - Still confused by the Policy Statement for Reconciliation of a Program Advance.  If it's not closed within 60 days... it may be reported as income to the PI.  If it's not closed within 90 days... it may be deducted from PI's wages.  Is it one or another - not both?  So if I don't close it and it's been 75 days and I'm not responding to you at all, will you report it as income?  and end the collection effort?  or will it proceed to > 90 days and then you would deduct it from my wages too?  might just be me not understanding, but I don't think we would do both corrective actions and i'm not sure who/why/when would decide to do the first one or wait until > 90 days to do the 2nd one.

4.  In the Replenish a Program Advance section, I think we need the same references to most are processed as ACH, but if you want a check you need to do the same couple of steps that were mentioned in the "Open a Program Advance..", so it's printed at their USFSCO office and they've indicated the denominiations, etc., and that it could add up to 3 days...

5.  In the Close a Program Advance to Pay Human Subjects - there is a specific deposit form that UPAY requires the PI to bring with the unused cash to USFSCO.  That needs to be stated and linked, it's on the OBFS Forms page:

Cash Handling Forms - OBFS

Travel or Program Advance Closure

• Travel or Program Advance Closure Form [updated: 5/15/13]

I would suggest raising the limit to the IRS-required $600 when there is no reason to think subjects are receiving other human-subjects payments. I have had (off-campus, out-of-state) research derailed because the policy increases risks to human subjects who would otherwise remain de-identified.

I personally find that reconciliations every 90 days is arbitrary and unnecessary busy work. Why not every six months? Or at the beginning of every semester? (Once at start of Spring, Once at start of Summer and once at start of Fall). Similar results would be obtained and I think that it would make for easier management if "set" dates where in place for PIs. 

The following proposed policy changes would be extremely helpful in reducing the workload associated with managing open program advances and would allow PI's to recruit subjects more effectively:

• Requires that a reconciliation event occur every 90 days (OBFS recommends monthly reconciliation).
• Does not require closure of an advance at fiscal or calendar year end.
• Limits the time an advance can be open to 18 months.
• Increases threshold for collection of tax identification numbers for human subject payments from $100 to $200 per calendar year.
• Allows a Custodian to have one advance for each approved IRB Protocol.

1. What is the process for enforcing that a reconciliation occurs at least every 90 days?

2. In the event that a study exceeds 18 months, does the custodian need to open one advance for the first 18 months, close that advance out at the end of 18 months and open a new advance for any period beyond the first 18 months?

3. In cases of loss, who will make the determination of whether the custodian is liable or if it was beyond his/her control and is chargeable to the unit’s budget?

I have a few questions:

1. The title of the section is payments to human subjects, but there is no details on how to use E-Codes (also an OBFS procedure) or reference procedures for Mechanical Turk payment/reimbursement.  Will those be added? 

2. There is no specific information on what documentation is required to be provided for partial clearing, closing, or replenishment of an advance.  If it is not a confidential study, what is required? If it is a confidential study, what is required?  The process just refers to job aids.  Will the job aids address these needs?

3. There is no detail on what a reconciliation actually means for the custodian, nor details on whether it should be documented or retained. The majority of the custodian's in this particular process are PI's that are not trained in financial procedures.

Otherwise looks good.

Under the Close a Program Advance/If there is CASH OR CHECKS to be returned... - This new policy does not reference to use the Program Advance Closure form that is currently in the policy. I would recommend keeping the form as a requirement when depositing remaining advance funds with USFSCO