Cash advances for subject payments

[Liz Hinske]

We have had a recent go-around with Disbursements regarding Cash Advances for subject payments. It seems some people use the term 'participant' interchangeably with 'subject' and that has caused some audit issues for Disbursements and they are not critically reviewing Cash Advances. Be sure to provide information in the justification some language that indicates the cash advance is for subject payment rather than participant or you will risk having the CA denied. Because we cannot be specific about what the payment is for or even list the name of the study under which the subjects will be paid, the following text was given as something Disbursements might be looking for in the justification:
"Investigator conducting "research" is gathering data through intervention or interaction with the individual or identifiable private information".
We didn't include this particular text and the coordinator who filled out the CA request used the word study 'participant' and as a result of these two factors, we were denied Cash advance because Disbursements could not determine the payments were for research and invoked HIPPA. Eventually after a number of edits and back-and-forth struggles to clarify to Disbursements without violating privacy issues, it went through. I thought it might be useful to share this experience to help others avoid delay for this reason.

I invite any others who have tips or useful experiences with Cash Advances to share and provide additional comments.

[Jerian Lind]

Just to clarify - when you refer to the CA being denied, you mean the Cash Advance, not the Certified Approval?  So it's Disbursements looking for specific information to determine that the advance is for research rather than the certified approver looking to determine allowability on a research project?

Very helpful tip. I can see how "participant" gets interchanged for "subject" and how that can make all the difference in getting a Cash Advance to go through.  Thanks for sharing! 

[Liz Hinske]

Yes, in the context of my original post, "CA" refers to Cash Advance rather than Certified Approver.