Remuneration of Investigators from Project Funds
This policy describes the limited conditions under which health care professionals who conduct sponsored research in association with Children's & Women's Health Center may be paid from research funds for services provided to a project (in an ethical manner as defined by policy). The policy recognizes that such remuneration is sometimes appropriate. However, it also recognizes that appropriate circumstances must be carefully defined with approval from the relevant department head.
Elements of this policy are as follows:
- Investigators shall adhere to the policy of granting agencies that provide them with research funds. In Canada virtually all granting agencies prohibit salary payments to investigators. Only persons identified in the grant application as providing a necessary service to the study as employees or consultants can be paid a salary. Exceptions exist with some US granting agencies. Depending on the project, the terms "employee" and "consultant" encompass the full range of healthcare professionals, including physicians, but do not include the named investigators.
- Investigator remuneration may be feasible for research projects sponsored by companies or governments. Such contracts generally include payment for professional services rendered by the named investigators. Since contract awards are usually for fixed sums and deficits are not allowed by host institutions such as UBC or C&W, investigators must ensure that all other costs can be covered before investigators may be paid from any balance. In the event of budget forecasting errors or cost over-runs, no balance may be available to pay investigators or the amount may fall short of what was expected.
- Remuneration of an investigator should be readily justifiable to, and approved by, the individual's department head. Approval must be sought before the project begins. This policy recognizes that investigators' income sources differ within the institutions, with some receiving core salary support to conduct research and others having to do so entirely on their own time. Whatever the circumstances, investigators will not be paid for work done in time for which they are already paid from another source.
Reasonable justification of investigator remuneration would include:
- Research done by fee-for-service health professionals when doing research requires giving up normal clinical activities or extending the work day. Such persons should be especially careful to separate activities generating fee-for-service income from those involving remunerated research if the research is patient-centered.
- Research done by salaried health professionals whose job description includes a certain amount of research time but whose contract research project substantially exceeds their research allocation and requires considerable evening and weekend efforts.
- For full time salaried researchers, only exceptional efforts required by a contract-funded project would justify additional remuneration.
- The department head should ensure that strict accounting for time is maintained.
- Remuneration of an investigator should be based on a record of billable hours, (or subjects studied as permitted by the department head during the approval step) and a reasonable rate of pay for the individual as based on appropriate BCMA or MSP scheduled fees as appropriate. The record of billable hours will include an accounting of times and dates. Billing activities allowed for include: patient contact, phone conversations, associated clinical trials meetings, management of clinical trials (ie. regulatory issues, administrative time).
- Payment from a research account to an investigator should be routed through the individual's usual paymaster, or when none exists, through the institution which is managing the research accounts. Income tax obligations are to be addressed in the process.
- Investigators affiliated with C&W will arrange all research contracts through the Research Institute (BCCHR) and avoid any direct payments for research project activities from the sponsor to themselves.
- Investigators should note that remuneration may have later consequences. Research ethics boards may require investigators to declare any anticipated remuneration for a sponsored project in the consent form for volunteers. Medical journals often require declaration of corporate sponsorship and are becoming more explicit about personal income. Many scientific conferences require speakers and presenters to declare personal income from corporate sponsors of research. Such support may make individuals ineligible to serve on certain policy committees considering use of the products which they were paid to investigate.
- Investigators may choose to apply residual balances from research contracts (including unclaimed amounts for professional services) to the betterment of their research program. Such discretionary funds can be applied to the research program upon the approval of the Investigator's Department Head and may include, but not be limited to: training of staff, retention of key staff between projects, planning of subsequent applications, purchase of equipment, development of training modules and standard operating procedures, travel funds to attend relevant scientific conferences, trainee's small projects, contributions to research endowment accounts. Contract balances are virtually the only source of discretionary funds available to investigators, so careful thought is appropriate about how best to expend them.
Revised - May 2006