Crossing a boundary?
Many researchers are required to collect the Social Security numbers of
participants to process payments to them. Is that asking too much?
By James M. DuBois, DSc, PhD
My colleagues and I recently conducted an online study with the objective
of validating a new measure of professionalism in research. We wanted
to obtain a convenience sample of 300 investigators and postdoctoral
trainees who have been funded by the National Institutes of Health
(NIH). We paid participants to complete an hourlong battery of tests
and to provide demographic information.
Even with payments, we needed three months from our
initial recruitment announcements to accrue 300 participants.
After sending three requests to each potential participant and
making follow up calls, we obtained a participation rate of
approximately 15 percent, because participation was so time-intensive for busy investigators.
However, one requirement hindered our ability to attract
even more participants with payments: To process the
payments, we were required to collect participants’ Social
Security numbers (SSNs). Accordingly, our informed consent
form notified participants that they would need to provide their
SSNs in order to process payment. Further, the institutional
review board (IRB) at my university required that our consent
form disclose the risk that other people, including staff at
federal agencies, might become aware of the respondents’
participation in the study.
The reaction to the consent form was swift. Within one
day, a potential participant contacted us to tell us that while
our study was interesting and she would like to participate,
she would not provide her SSN. Within one week, another
participant contacted the IRB to complain that we required a
SSN to process payments. This pattern continued throughout
the study. At least four participants submitted incorrect
SSNs, which required correction before payment could be
processed, and 10 participants declined payment rather than
provide their SSNs.
These study participants were not irrational in their
concern. In the event of a breach of confidentiality, none of
the information we collected could lead to harm as significant
as abuse of their SSNs. This is why an increasing number of
government agencies, financial institutions, and employers
have discontinued the practice of using SSNs as identification
numbers despite the convenience of doing so. Moreover, many
people feel a strong sense of privacy regarding their financial
matters; because SSNs are so closely tied to our financial lives,
some people may have felt that the request crossed a boundary.
So how did we reach this situation? My IRB simply wanted
to disclose all significant risks involved in participation —
hence the consent form referenced SSNs and the possibilities
that confidentiality might be breached or that a funding agency
might wish to review study records. The university’s tax office
simply wanted to manage legal risk arising from Internal
Revenue Service (IRS) rules pertaining to Form 1099-MISC,
Miscellaneous Income. According to legal and accounting
professionals, the IRS views research participation as a taxable
event (“other income”).
Institutions must issue 1099-MISC tax forms to people who
receive $600 or more in a tax year. Accordingly, many institutions
request SSNs for all payments greater than $10 per day to enable
tracking of payments. For research participants who are nonresident aliens, payment procedures are more onerous, involving
completion of Form 1042-S and mandatory withholdings. From
the perspective of the IRS, providing gift cards is no different
from cash or check payments. The administrative burden of
such payments is significant: The survey study mentioned above
required my institution to complete paperwork to create 300
“vendors” prior to mailing checks.
The policy of collecting SSNs can also make it difficult to
The policy of collecting SSNs can
also make it difficult to recruit
participants from certain groups or