HSIP Threshold Change FAQs

Effective November 7, 2026 | Last updated: Oct. 28, 2026

IRB, consent, and eResearch guidance for principal investigators and study teams.

This page provides Institutional Review Board (IRB), informed consent and eResearch Regulatory Management (eRRM) guidance related to U-M Treasury’s revised Human Subject Incentive Program (HSIP) policy for collecting Social Security Numbers (SSNs).

For payment and processing policies, tax-reporting requirements, required participant information, noncompliance, and exceptions, consult U-M Treasury’s HSIP policy and FAQs.

This page will be updated as additional questions arise.

Overview

What is changing?

Effective for tax year 2026, the Internal Revenue Service (IRS) reporting threshold for certain income reported on Form 1099, including research participants payments, increased from $600 to $2,000.

In response, U-M Finance is increasing the threshold for collecting research participants’ SSNs from more than $400 to more than $1,600 per participant per calendar year, effective November 7, 2026.

What does my study need to do?

Required actions depend on the maximum compensation a participant may receive from your study during a calendar year.

Study compensation range	eResearch action	SSN beginning November 7
$0.01-$400	No technical action required; remains Tier A	No change
$401-$599	Automatically converts from Tier B to Tier A	Stop collecting SSNs
$600–$9,999, with maximum compensation of $1,600 or less	Select the new compensation range at the required application update	Stop collecting SSNs from newly enrolling participants
$600–$9,999, with maximum compensation above $1,600	Select the new compensation range at the required application update	Continue collecting SSNs

Additional requirements for consent forms, participant notification, and previously collected SSNs are described below.

Actions by compensation amount

Beginning November 7, 2026:

Stop collecting participants’ SSNs.
Securely dispose of the SSNs that are no longer needed, following U-M’s secure data and device disposal guidance and applicable records retention and data security requirements.
Provide the “Dear Research Participant” letter to current participants and those enrolling on or after November 7, 2026, until the IRB approves an updated consent form for your study.

eResearch will automatically convert the study from Tier B to Tier A. Update the application and consent form according to the schedule above.

First, determine the maximum compensation a participant may receive from the study during a calendar year.

If the total compensation is $1,600 or less:

Beginning November 7, 2026:

Stop collecting SSNs from newly enrolling participants.
Securely delete unneeded electronic records and shred unneeded paper records containing SSNs for currently enrolled participants, in accordance with U-M secure data and device disposal guidance and applicable records-management and data-security requirements.
Provide a digital or printed copy of the Dear Research Participant letter to all current participants and participants who enroll on or after November 7, 2026. Continue providing the letter until the IRB approves an updated consent form.

If the total compensation is more than $1600:

Continue collecting SSNs under the study’s existing procedures.

Update the eResearch HUM application and consent form at the next consent form by amendment at the time of next continuing review, whichever occurs first. For studies that do not require continuing review, obtain IRB approval of the required updates no later than November 7, 2027.

HSIP may contact the study team to confirm the maximum compensation. See the HSIP SSN collection policy and FAQ for how HSIP will process payments while eRRM still displays the former tier.

If the study has finished paying participants, no payment-tier action is required solely because of this threshold change.

IRB applications and amendments

No. The U-M IRBs will not require an immediate amendment or require investigators to new consent from participants solely because of this change.

Investigators must update their eResearch HUM applications and consent forms at the earlier of:

The study’s next consent form amendment; or
The study’s next continuing review.

For studies that do not require continuing review, the updated application and consent form must receive IRB approval no later than November 7, 2027.

When you next update the eResearch application through an amendment or at the time of your next continuing review, you will receive an automated message indicating that your previous responses to the compensation and HSIP Tier questions are no longer valid.

You will need to select the study’s new HSIP Tier based on the maximum compensation a participant may receive during a calendar year.

Follow instructions from the reviewing IRB and eResearch. Your submission may need an updated compensation range before it can be approved.

Consent forms and participant communication

Use the current template for the reviewing IRB and study type:

Updated templates reflecting the policy change will be posted before November 7. Please check the applicable template page again before submitting your consent form.

Yes. Continue using the approved consent form until the IRB approves an updated version.

While using a consent form that states the previous threshold:

Follow the new SSN collection requirements beginning November 7, 2026.
Provide the Dear Research Participant letter as applicable.
Do not obtain new consent solely because of this change.
Update the consent form according to the required amendment or continuing review schedule.

Provide a digital or printed copy of the Dear Research Participant Letter to:

All current participants; and
Participants who enroll on or after November 7, 2026.

Continue providing the letter until the IRB approves the updated consent form.

NOTE: Reconsent is not required solely because of this change.

Yes. However, a verbal explanation does not replace the Dear Research Participant letter while your study uses a consent form that includes the previous threshold.

No. Participants who have completed the study and are no longer enrolled or receiving research participant payments do not need to be notified because of this change.

Previously collected SSNs

Beginning November 7, 2026, securely dispose of study team records containing SSNs that are no longer needed.

Do not dispose of information that:

Is still needed to process a participant’s payment; or
Must be kept for another authorized purpose.

SSNs already submitted to central U-M systems may be subject to university records retention requirements.

Follow U-M’s secure data and device disposal guidance and all applicable records management and data security requirements.

Electronic records: Follow U-M’s secure data and device disposal guidance. Simply deleting a file or emptying a computer’s recycle bin may not securely remove the information.
Paper records: Follow U-M’s sensitive-paper shredding guidance. Use a confidential paper-shredding bin or, if unavailable, a cross-cut shredder. Do not place records containing SSNs in wastebaskets or unsecured recycling bins.

eResearch regulatory management (eRRM) changes

Beginning November 7, 2026, eResearch will assign payment tiers based on the maximum compensation a participant may receive during a calendar year:

Tier A: $1,600 or less – no SSN required
Tier B: More than $1,600 – SSN required

Most existing studies will not require immediate eResearch action. Some studies will be converted automatically, while others will need to select a new compensation range at their next required application update.

eRRM will recalculate the tier when the applicable amendment is approved.

No. The technical conversion updates eResearch data only. It does not update approved consent forms, participant materials, or study procedures.

Study teams must follow the November 7, 2026, SSN collection requirements and update study materials according to the applicable IRB timeline.

Special study circumstances

Determine the maximum annual compensation and SSN requirement for each participant group.

For example, one group may receive $1,600 or less per calendar year, while another group may receive more than $1,600.

Use the multi-tier designation in eResearch when it is available. If eResearch does not support the designation your study needs, contact HSIP.

Follow the reviewing IRB’s requirements and complete all applicable U-M local-context, HSIP, and eResearch requirements.

Support

The IRB may contact study teams when available eResearch information does not clearly indicate whether a participant’s maximum annual compensation is more than $1,600.

Study teams remain responsible for reviewing and following the applicable guidance.