HRPP UPDATE: Research Participant Payments and Tax Reporting Requirement
(Effective January 1, 2026)
The IRS reporting threshold for research participant payments has increased from $600 to $2,000 per calendar year effective January 1, 2026. Payments to VCU research participants totaling $2,000 or more will be reported via Form 1099 (Miscellaneous Income), and all research payments remain taxable income.
At VCU, studies that include total payments over $250 must be tracked, and the participant’s social security number collected, to ensure compliance with tax reporting rules. The previous threshold was $50.
Next Steps:
- New or amended consent forms must include the updated template language explaining the new threshold (see #2 below).
- For ongoing studies with previously approved consent forms, study teams must provide participants who will be paid in 2026 with the IRB approved Consent Addendum (see appendix 1) to ensure they have been informed of this new information.
- At the next IRB modification or continuing review, researchers must update consent forms if the study is open to enrollment and continues to compensate participants. If the total compensation is less than $250 in calendar year, the template language can be deleted from the consent form.
- If the mod is to update study staff only, the consent does not need to be changed at that time.
For additional information, visit the Office of Procurement Services website:
https://procurement.vcu.edu/i-want-to/pay-an-individual/compensate-a-research-participant/
1. What changed on January 1, 2026?
Starting January 1, 2026, VCU will issue a Form 1099 (Miscellaneous Income) to research participants who receive $2,000 or more in research participant payments during a calendar year. This replaces the prior $600 reporting threshold.
This change is the result of federal tax legislation commonly referred to as the “One Big Beautiful Bill,” which amended IRS information reporting thresholds.
2. What is the new template consent language for projects on or after January 1, 2026?
For studies starting on or after January 1, 2026, or for studies updating their consent forms, study teams should use the following standard template language in the “Payment,” or “Compensation,” section of the consent form, if total compensation is over $250 in a calendar year:
“Total payments within one calendar year that exceed $2,000 will require the University to report these payments annually to the IRS and you. This may require you to claim the compensation you receive for participation in this study as taxable income. VCU is required by federal law to collect your social security number. Your social security number will be kept confidential and will only be used to process payment.”
Study teams should not reference prior reporting thresholds (e.g., $600) in new or revised consent forms approved on or after January 1, 2026.
3. Does this mean payments under $2,000 are not taxable?
No. All payments for research participation continue to be considered taxable income, regardless of amount. The $2,000 threshold only determines when VCU is required to issue a Form 1099.
4. What should study teams do if a currently approved consent form still lists the old $600 reporting threshold?
If a consent form approved before January 1, 2026 still references the former $600 IRS reporting threshold, study teams do not need to immediately halt enrollment for this reason. Study teams should revise the consent language at the time of their next planned modification or continuing review
Until the consent form is updated and IRB approved, study teams should provide participants with the IRB approved consent addendum: Participant Payments (appendix 1).
- A signature is not required.
- The form can be distributed in person or via email.
- The participant’s consent research record should be updated to reflect receipt of the new tax reporting requirements.
The consent addendum provided by the VCU IRB does not need to be reviewed and approved on a study-by-study basis and can be used starting January 1, 2026, provided the only customization is the inclusion of the study details at the top of the form (PI name, study title, HM#). You are not required to upload the form to VIRBs.
5. What if the total payments for an active study met the $50 threshold, but not the $250 threshold?
If the total payments in a calendar year is less than $250, please delete the template language from your consent form at the next continuing review or modification involving changes to the study.
Participants who have or will sign a consent form noting the $600 limit and who will receive payments over $50 in 2026 should be given the Consent Addendum so they know the IRS reporting threshold is now $ 2,000.
6. Is reconsent necessary when the sole revision is the inclusion of threshold language and participants have already been notified?
No. Providing participants with the consent addendum as described in #4 is sufficient notification for the updated tax reporting threshold. Because this revision does not require a standalone modification submission, whether reconsent using a revised consent form is required will depend on any additional changes requested at the time of review.
7. Where can I find the consent addendum?
The consent addendum will be posted to the HRPP website and placed in the VIRBs library under templates. It will be labeled HRP-502a.
_____________________________________________________________________________________________________________
APPENDIX 1 -HRP-502a
Consent Addendum
Participant Payments and Tax Requirements
Title of research study: [insert title of research study]
Investigator: [insert name of principal investigator]
Study #: [insert HM#]
You previously signed a consent form to participate in this study.
Some of the information provided in that form has changed.
Specifically, as of January 1, 2026, the IRS reporting threshold for participant payments has increased from $600 to $2000.
Old language:
Total payments within one calendar year that exceed $600 will require the University to report these payments annually to the IRS and you. This may require you to claim the compensation you receive for participation in this study as taxable income. VCU is required by federal law to collect your social security number. Your social security number will be kept confidential and will only be used to process payment.
Replaced with this updated language:
Total payments within one calendar year that exceed $2,000 will require the University to report these payments annually to the IRS and you. This may require you to claim the compensation you receive for participation in this study as taxable income. VCU is required by federal law to collect your social security number. Your social security number will be kept confidential and will only be used to process payment.
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