UNIVERSITY OF PITTSBURGH POLICY 05-11-01
CATEGORY: FINANCIAL AFFAIRS
SUBJECT: WePay Stored Value Card
EFFECTIVE DATE: May 1, 2009
This policy is applicable to all research studies conducted by the University of Pittsburgh
(University) where compensation payments or expense reimbursements are made to
research participants. In addition, this policy explains the purpose and function of a
centralized research participant payment system, known as WePay, which was
developed jointly by the University and UPMC using a stored value card (Cash Card) as
the method of payment. The Cash Cards are currently provided by and processed
through RBS WorldPay (formerly RBS Lynk), which is a subsidiary of the Royal Bank of
Scotland through its U.S. operating group, Citizens Financial. Should this vendor change,
notice will be provided to appropriate individuals or groups.
The WePay system was developed to achieve the following goals: effective oversight
and management of the University’s financial assets; replacement of the manually
intensive workflow with an internally-developed and customized software application; an
aggregation system allowing the University to become compliant with IRS Form 1099
reporting; acknowledgement of and adherence to other regulatory requirements
including HIPAA (control of protected healthcare information), Sarbanes-Oxley (financial
monitoring and control) and USA Patriot Act (increased due diligence of bank accounts,
foreign asset control and anti-money laundering); all while maintaining confidentiality of
research participant data within a secure technology environment.
Studies Which Qualify for WePay
Participant payments for all University-wide research studies will be executed via the
WePay system (Please refer to Section IV. Cash Payments for additional information on
individual participant payments less than $10.) Participant payments will be made via a
Cash Card. All existing payment methods which are cash-based in nature, such as
petty cash (both bank accounts or cash on hand), Payment Processing checks, travel
advances and store gift cards will no longer be acceptable payment methods for
participants in research studies.
Any requests for use of other payment mechanisms for research participants must be
approved in writing by the Director of the University’s Institutional Review Board (IRB). A
copy of the written approval of such IRB exemption shall be provided to General
Accounting by the department or Principal Investigator (PI).
In addition, exceptions to prohibited uses or uses of the Cash Card other than for
research participant payments must be approved in writing by both the General
Accounting and Payment Processing departments.
The WePay Cash Card may not be used for any purpose other than payments to
research participants to compensate them for their time or reimbursements for expenses
such as parking, transportation or meals. The WePay Cash Card may not be used for
- Participant payments to Foreign National Individuals. These payments require
special handling due to tax regulations, and need to be submitted on a disbursement
request to payment processing along with a Foreign National Tax Information Form
(available at http://www.bc.pitt.edu/payment/forms.html) and forwarded to the Foreign
National Tax Processing Unit at 207P Craig Hall.
- Department purchase using WePay (or any other purchase mechanism) of other
retailer gift cards for distribution to research participants.
- Department purchases of goods and services from external suppliers or internal
service centers. These are subject to existing Purchasing policies such as 05-02-15,
Required Use of Contracted Suppliers; 05-02-16, Competitive Bidding; 05-02-17,
Directed or Sole Source Purchase Justification; 05-07-01, Travel and Business
- Employee payments including wage advances, supplemental payments, employee
travel expenses, employee travel advances, or any other employee reimbursable
expenses subject to IRS Accountable Plan rules and possible federal tax withholding
- Cashing personal checks.
All existing studies which meet the WePay criteria above will be migrated to the WePay
system. The participants will be paid via WePay upon the next study visit. The
participant will be given the Participant Payment Fact Sheet as referenced in Section VI.
herein before his/her payment is made.
III. CASH CARD MANAGEMENT/CASH CARD SECURITY
Managers are responsible to ensure that staff under their supervision complies with all
WePay policies and procedures. Misuse of WePay Cash Cards or the WePay system
may result in sanctions including the possibility of termination of employment.
Cash Card Security
University personnel are responsible for properly securing and handling all Cash Card
inventory, therefore unloaded Cash Cards are to be secured like cash or blank checks.
Cash Cards are the personal responsibility of the party to whom they are assigned within
the WePay system. Cash Cards in transit between two parties are the responsibility of
the sending party until receipt is acknowledged via the WePay system by the receiving
party. Following are specific security rules:
- Cash Card owners are responsible for all Cash Cards identified as theirs in WePay.
Cash Cards should be kept in a locked facility and treated like cash or blank checks.
- Do not accept ownership of Cash Cards within the WePay system until the actual
Cash Cards are in your physical possession.
- Cash Card owners must ensure that the Cash Cards owned in the WePay system
match the Cash Cards in their possession. Discrepancies must be resolved
- The actual Cash Cards should always be delivered and accepted in person.
Interoffice mail should never be used to deliver Cash Cards. For offsite locations, a
courier with tracking capabilities such as FedEx is acceptable.
- Cash Cards assigned to a new WePay user remain the responsibility of the sending
party until the new owner accepts the Cash Cards in WePay. WePay will send an
email notification to both users when Cash Cards are in transit for longer than 3, 5
and 7 business days, Finance/Audit is notified on the 7th day.
- If a Cash Card owned is lost, stolen, or damaged, it must be disabled within WePay.
Cash Cards disabled within the WePay system can never be activated/loaded.
- Older Cash Cards should be used first. Cash Cards expire after three years, and
cannot be issued or reloaded in the six months before expiration.
Unusable Cash Card Disposition
All excess, expired or otherwise unusable Cash Cards will be returned to Payment
Processing, a local Card Manager (CM), Administrator (ADM) or Business Office Manager
(BOM) (as defined in IV.) for destruction as practical. The Cash Cards will be destroyed
under dual control using a shredder that is capable of shredding these Cash Cards.
Identifying information including Cash Card numbers, dates of destruction, and names of
the persons who actually destroyed the Cash Cards will be recorded onto a Cash Card
destruction certificate and confirmed by the individuals destroying the Cash Cards. This
record must be kept for a minimum of 12 months by each user with a copy to Payment
Processing and the Office of Finance. Cash Card remnants may be disposed of at the
discretion of the individuals destroying the Cash Cards. A sample form (of destruction
certificate) is included in the RBS WorldPay documentation referenced in Section VI. below
(RBS Lynk Security Plan for MasterCard® Participant Incentive Payment Program.)
IV. SPECIFIC ACTIVITIES
Roles and Responsibilities
Users of the WePay system are assigned a specific “user role.” Each role is entitled to
perform specific functions in the system. A WePay user may be assigned to only one of
the six available roles, either administrative or payment-issuing, and may perform the
tasks associated only to that role. Further, each role is responsible for monitoring and
reconciling the activities of their projects or studies to appropriate accounting records.
The terms “project” and “study” are defined in more detail below in Section IV.
Acceptance into WePay: Written documentation confirming authorization to add a WePay
user will be approved by the appropriate University authority (e.g., responsibility center
head or designate) and for WePay Administrators, further approval by General
Accounting before entry into the WePay system. The WePay User Guide (Chapter 6) as
referenced in Section VI. herein describes the process for Acceptance in the “Users”
section and appropriate forms are provided in its appendix. The Office of Finance will
manage the overall process of User access to the WePay database.
Termination from WePay: When a WePay user is terminated from the University, their
access to WePay will be immediately revoked by the appropriate University authority
(e.g., responsibility center head or designate) and confirmed in writing. The WePay User
Guide (Chapter 6) describes the process for Termination in the “Users” section and
appropriate forms are provided in its appendix.
Following are general descriptions of the primary duties of each role.
- Administrative Roles:
Finance/Auditor role – designed to oversee and monitor the system, is only able to
access reports within the system, and view transactions in order to verify their
appropriateness. This role is generally not available to the departments.
Card Manager (CM)
Primary CM – serves as the primary depository of Cash Cards on behalf of both
the University and UPMC. Serves as the first tier of the Cash Card distribution
network; is responsible for ordering Cash Cards from the current vendor,
Oberthur Card Services, through RBS WorldPay; and distributing the Cash Cards
to (or reclaiming cards from) Local CMs, ADMs, or BOMs.
Local CM – serves as the second tier of the Cash Card distribution network. The
Local CMs will physically pick up and electronically accept Cash Cards from
Primary CM. Local CMs will be created as appropriate in order to effectively
distribute Cash Cards within a particular school, department or geographic
Administrator (ADM) – a required role responsible for establishing or updating project
and study permissions, linking or unlinking Study Coordinator (SC) and Study Aide
(SA) to studies, distributing Cash Cards to other users, resolving participant name/
SSN conflicts and reconciliation of WePay activity to the University monthly level
reports all as described more fully in the WePay User Guide. This role cannot create
a subject nor can it load or activate a Cash Card.
Business Office Manager (BOM) – designed to accommodate the complexity of larger
departments, this role is not required and has all of the same functionalities as the
ADM except for creating projects.
- Payment-issuing roles:
Study Coordinator (SC) – a required role responsible for linking subjects to studies
then making payments using Cash Cards in accordance with permissions established by
the ADM. This role cannot create a project or study nor change any of its permissions.
Study Aide (SA) – designed to accommodate the complexity of larger departments,
this role is not required and has all of the same functionalities as the SC, except for
adding study access.
- Payment Processing functions:
Payment Processing is not a user role within the WePay system. However, it plays
an important function as the primary CM and in the administration and review of
electronic files as received from the WePay servers.
Payment Processing is responsible for such duties as managing and monitoring Cash
Card inventories, electronic file management, operational monitoring of Cash Card
usage, recording Cash Card usage in the University’s ledgers and associated tax
reporting and withholding, participating in system refinements and enhancements,
and assisting in WePay system audits. Specific tasks for which Payment Processing is
responsible are articulated in procedures such as the WePay Imports User Guide as
referenced in Section VI. herein.
Cash Card activity and inventory will be audited (1) regularly by ADMs and BOMs via
direct access to WePay reports available to them electronically and (2) on a periodic
basis by both the University’s Internal Audit and Payment Processing offices via direct
access to the universe of WePay reports. Both physical and electronic audits will be
conducted by the groups mentioned in (1) and (2) above.
These audits will monitor and evaluate various aspects of the WePay system such as
proper accounting and controls, regulatory and internal compliance, operational efficiency,
data and physical security, and system processing controls.
Cash Card Services
Research participants owning a Cash Card should contact RBS WorldPay via a toll-free
number (1-800-591-1110) and via the Internet at www.cashlynkmc.com, for problems
with a Cash Card after it has been issued. University personnel are not expected to
provide primary customer service support to cardholders once the Cash Card has been
A project is defined as the broadest scope of work available about the research awarded
as indicated by:
- Agency Notice of Grant Award or Cooperative Agreement
- Foundation Award Letter
- Industry Contract
- Internal Institutional Award Letter
Projects have at least one study. There are no limits to the number of studies under one
Projects must have a single source of funding. Additional sources of funding or change
in grant number (e.g., 1R01XXXX-XX), contract number (e.g., N00-XXX-XXX), or document
number require the establishment of a new project.
Project addendums and supplements to a project that do not change the contract number
do not require a new project.
All projects should have at least two WePay Administrators (ADM) assigned for each
Studies describe a specific scope of work within a defined project. Each scope of work
under a defined project should be defined as an individual study, as typically indicated by,
- Changes in payment schedule, or
- Requirement of a new IRB approval
Each study must have assigned at least one WePay Study Coordinator (SC) in order to
pay study participants. All ADMs assigned to the corresponding project will also by default
be assigned to all studies under that project.
The minimum Cash Card load amount permitted by MasterCard and the WePay system
is $10.00. Participant payments which are nominal in nature (defined as less than $10.00
in a single payment), such as “man on the street” interviews, will not be required to include
individual payment information by subject. Prior to implementing this type of payment,
review and approval of the process must be granted by the Office of Finance to ensure
proper WePay guidelines are followed. For these studies, the PI or his designate will
obtain funds in a lump sum via a single load to the Cash Card. The PI or his designate
will take the Cash Card to one of the two Citizens Bank branches in Oakland and withdraw
funds to pay subjects in the appropriate denominations. A separate record must be
maintained in sufficient detail to account for all payments (e.g., a subject receipt log
initialed by recipient can be maintained.) A Cash Card should not be reloaded until the
accounting for and reconciliation of all cash from the preceding load has taken place.
These records will be prepared and protected in accordance with HIPAA regulations and
maintained by the PI as necessary for audit purposes. Cash remaining after
disbursement of each Cash Card load during the study will be deposited to the
appropriate study account.
Studies in which research aims or study methods of the project require anonymous data
collection are exempt from the collection of personal data. For these exceptions, the PI
will produce the protocol which evidences the anonymous requirements and formal
written approval will be obtained from the Director of the IRB for any exceptions, prior to
any cash payments being made.
V. CONTACT SECTION
Payment Processing 412-624-4004
- Primary CM
- Electronic File Management
- Operational Monitoring of Cash Card Activity
Office of Finance 412-624-6620
- General WePay Information
- System Access Set-up
General Accounting 412-624-6290
- Help Desk 412-647-HELP
- Clinical Trials Office 412-647-4421
RBS WorldPay – Cash Card processor
- Interactive Voice Response 1-800-591-1110
- Web Site www.cashlynkmc.com
University of Pittsburgh policy 10-02-08, Use and Management of Social Security
Numbers and University Primary ID (“UPI”) Numbers located at
WePay User Guide, dated 2/18/2008, as subsequently amended
WePay Imports User Guide, dated 2/11/2008, as subsequently amended
Data Entry Guidelines
University’s HIPAA policy located at http://www.pitt.edu/hipaa
RBS Lynk Security Plan for MasterCard® Participant Incentive Payment Program, dated
November 2006, as subsequently amended
Participant Payment Fact Sheet, dated 10/01/2007, as subsequently amended