This page provides information related to the financial management of an active clinical research study.  Please contact OCR Finance with any questions or request for assistance related to the financial management of your study.

Research Billing in PennChart
Professional and Technical Fees

PennChart captures all professional charges and hospital charges in a centralized environment called Research Billing Review Report. The charges will not move forward to billing to either the patient’s insurance or research grant until research teams review and make the necessary adjustments in the report.       

Billing Discrepancies 

Billing discrepancies, including any professional or technical charge erroneously billed to the patient’s personal family account (i.e., insurance company), send a copy of the patient’s bill to OCR Finance at for immediate resolution. Please include the study Research Billing Number (RBN) and indicate the specific dates and charges that are in dispute.

Subject Payment
Instructions by Payment Type

Details about the process for subject payments can be found in the Penn Manual

Frequently Used Forms

C-2 Human Subject Voucher 

This is the supporting documentation for human subject compensation and out-of-pocket reimbursement and is required for all payments over $100. It is to be used as the petty cash voucher.

Form W-9

A W-9 needs to be completed when participants are either being paid through a University check or are paid through petty cash, gift cards or money orders and cumulative remuneration payments from the University are expected to total more than $600 in one calendar year for a single participant. 

W-9 form is necessary because the University is obligated to report to the IRS all individuals who receive income greater than an annual threshold of $600 per year.  

Greenphire ClinCard

Penn has partnered with the Greenphire ClinCard, a reloadable prepaid card available to research coordinators as a payment option to compensate or reimburse human subjects for participation in research trials. The card offers a faster and safer method to pay your study participants and will provide an excellent alternative to AP checks, gift cards and petty cash. In addition, Greenphire supplies a convenient administrative tool for loading, tracking and reporting your studies’ payments. 

Consent Considerations

If subjects will receive monetary compensation for their participation by check, or an amount of $100 or more, include the following language in your consent form compensation section. 

Please note: In order to be compensated for your participation in this study, you must provide your Social Security Number. Additionally, the University of Pennsylvania is required to report to the IRS any cumulative payments for participation in research studies that exceed a total of $600 in a calendar year

CMS Submissions Overview

All Category A and B Device Studies containing routine care costs to CMS (Centers for Medicare and Medicaid) must have prior approval from Medicare before enrolling and billing a CMS eligible patient.  

The cost of a Category A device may not be billed to CMS or other third-party payors, though the cost of a Category B device may be billed to CMS upon written approval from Medicare.  CMS approval must be granted prior to enrolling and billing any CMS-eligible patient.  Category B devices provided at no cost to the Health System may never be billed to CMS.

If the sponsor is providing the device at no cost and reimbursing UPHS for all associated routine care costs including insertion, monitoring, and treatment of adverse events caused by the device, then Medicare approval is not required.

How to Submit for CMS Approval

Study Teams should work with respective hospital Admission Departments to ensure that all precertification requirements are completed by patients’ third-party insurance companies prior to enrollment

Who to Contact

Hospital of the University of Pennsylvania — HUP

Glenn Pennington

Phone: (267) 584-1342


Penn Presbyterian Medical Center

Arthur Schimmel

Phone: 215-662-9107   

Email: ​

Michael Rudnick, MD

Phone: 215-662-8730 

Email: ​

Pennsylvania Hospital

Feargal Roche

Phone: 215-829-5764

Email: ​