May 2026

Effective January 1, 2026, the U.S. IRS reporting threshold for research participant compensation has increased from $600 to $2,000 per calendar year.  While the institutional reporting threshold to the IRS has increased, research participant compensation remains subject to taxation and is reportable. Reimbursement for documented participant expenses related to participation is not taxable.

To facilitate informing research participants of these responsibilities, the following procedures should be followed:

Studies where payments to participants are <$200 per individual in a single calendar year:

Payments to participants in research studies may continue to be paid via gift cards and petty cash without collection of SSNs/ITINs if they do not exceed $200 per individual per calendar year.  Since there will be no change to our policies and procedures, no communication is required to inform previously consented research participants of these changes to reporting.  Links to these guidelines can be found here.  We will not be increasing the threshold for using cash equivalents as a result of the IRS reporting change.  

Studies where payments to participants are >=$200 per individual in a single calendar year:

Studies with active participants (enrollment complete):

Investigators must provide a copy of the IRS Reporting Update Information Sheet to all research participants at their next interaction. This may be shared with participants electronically, by mail, or provided in-person at a study visit.

Please note that the IRS Reporting Update Information Sheet is IRB-approved and cannot be modified other than insertion of the PI name, protocol title, and contact information where indicated.

Studies with ongoing enrollment:

Investigators must provide a copy of the IRS Reporting Update Information Sheet at the time of consent OR alter the consent for future enrollment (see “Studies with future enrollment”).

Please note that the IRS Reporting Update Information Sheet is IRB-approved and cannot be modified other than insertion of the PI name, protocol title, and contact information where indicated.

New studies initially submitted for IRB review on or after 9/8/2026

The JHU IRBs have updated their consent templates. The new consent templates must be used for any studies submitted on or after 9/8/2026. The updated consent templates include the following language:

Payment for research participation is considered taxable income and needs to be reported  to the Internal Revenue Service (IRS) when you file your taxes. You may be required to provide your social security number to be paid for taking part in this study. If your total payments from Johns Hopkins exceed the IRS reporting threshold per year, Johns Hopkins will report these payments to the IRS and you will receive a 1099-MISC form from us.