The Greenphire ClinCard Policy has been revised and goes into effect on June 01, 2021. The primary changes affecting investigators and research study teams are:
- W-9s and W-8s now only need to be completed if subjects will receive $200 or more in a calendar year. Previously, all subjects were required to complete W-8/W-9s regardless of the amount of compensation provided.
- Departments/divisions will be charged for the cost of unassigned ClinCards that expire or are lost while in the investigator/study team’s possession.
- Quarterly reports will be generated of all manual transactions (transactions where the amount of reimbursement is typed in by the study team). Any staff member who both loads and approves the same manual payment is in violation of Section 2(a) of the attached policy. This is NOT new; however, OCR will reeducate study members who are in violation. Individuals who continue to load/approve the same manual payment will be referred to either Research Regulations and Compliance or Research Compliance for investigation.
- Research Regulation and Compliance will monitor compliance with this ClinCard Policy during routine monitoring.
Since W-8/W-9s won’t be collected for subjects receiving less than $200, SS# do not need to be collected. All studies where the expected compensation is less than $200 will be set up in Greenphire to allow you to assign ClinCards without the SS#s. Studies expected to compensate $200 or more will continue to require the SS# to be entered.
The entire updated policy can be accessed here. Questions about the updated policy can be directed to Lori Simon, RN, BSN, CCRP, Director, Office of Clinical Research.