|Approved by:||The President|
|History:||Issued -- November 9, 2009|
|Revised -- October 15, 2013|
|Last Reviewed -- July 29, 2019|
|Related Policies:||Non Resident Aliens Payment Policy|
|Additional References:||Direct Payment Request|
|Responsible Official:||Senior Director, Accounting and Financial Reporting tel. (202) 319-5013|
I. Policy Statement
This policy is applicable to all honoraria payments to individuals from University funds, and sets forth University requirements for awarding and processing honoraria to ensure proper compliance with Internal Revenue Service (IRS), immigration, and other federal regulations.
A. Honoraria are payments that are to be used only in limited circumstances as a gesture of goodwill or appreciation to reward individuals, who are not University employees, for services for which custom forbids a price to be set or where no expectation exists for payment for services. Honoraria may only be paid to persons of scholarly or professional standing in conjunction with a one-time academic or ceremonial activity, or in other circumstances at the discretion of the President of the University. As a matter of tax law, honoraria payments may not be paid to University employees.
For any services where a price is negotiated with the individual an honorarium may not be used. For example, teaching a course or seminar for an entire semester or term represents continuous service rather than a one-time activity. In such a case the individual would be considered an employee with a regular job title (such as Lecturer) and would need to go through the normal University hiring processes in advance of the services being provided.
All honoraria payments require the pre-approval of the school and the Provost, or the head of the administrative division and cognizant vice president, as appropriate. This approval is subject to the University's mission, policies and procedures and should be obtained before the payment request is submitted to Accounts Payable.
Payment of honoraria is a collaborative process across different administrative units. In order to facilitate prompt payment, please contact the Director of Accounts Payable (tel. 202-319-5854) well in advance of the anticipated payment. The vendor must be set up in Cardinal Financials before Accounts Payable can process the payment.
1. U.S. Persons
The department proposing to pay the honorarium needs to fill out the Direct Payment Request form and attach proof of the activity for which the honoraria will be paid (e.g. a flier for the event, or correspondence with a dean or Provost/VP regarding the event.)
2. Persons on Non-Immigrant Visas
Honoraria will not be paid to individuals who are subject to U.S. economic or trade sanctions per the U.S. Office of Foreign Assets Control (OFAC). Individuals subject to such sanctions are listed on OFAC's Specially Designated Nationals List (SDN). Departments proposing to pay honoraria should check this list in advance of offering to pay honoraria.
Tax and immigration rules impose restrictions on paying honoraria to those persons in the U.S. on non-immigrant visas. Only those non-immigrants in the following categories may be paid honoraria:
- Anyone who holds a work permit that allows employment for any employer (such as a work authorization document).
- A J-1 Professor/Researcher with permission of his/her J-1 sponsor.
- Anyone in visitor's status (B-1, B-2, WB, WT) who engages in academic activity lasting nine days or less and who has not received honoraria from more than five academic institutions in the last six months.
- If the scholar is here on an employment visa (such as A-, G-4, H-1B, TN, O-1, R-1, etc.) and The Catholic University of America is not the sponsor, the University can only issue a check for payment of the honorarium payable to the individual's sponsoring institution, provided that the institution that sponsored his/her status authorizes the activity at the University.
All other visa types must be authorized by the Office of International Student and Scholar Services (ISSS) prior to offering compensation for services, honoraria and/or travel expenses, as there are visa types that the University cannot legally pay.
Non-resident aliens who do not have a social security number (SSN) must obtain a federal individual tax identification number (ITIN) from the IRS in order to receive an honorarium. Obtaining an ITIN can take up to several months. Accordingly, the department proposing to make the honorarium payment must allow adequate time for processing in advance of the desired payment date.
ISSS, the Payroll Office, and the Accounts Payable Office cannot offer tax advice or complete any individual tax forms. See the Non-Resident Aliens Payment Policy for details regarding payments to non-U.S. persons.
C. Payment from Sponsored Research Grant Funds
An honorarium should only be paid from sponsored research grant funds if it is specifically allowed under the terms of the grant agreement or award.
An honorarium, whether in the form of cash or a tangible asset, is considered taxable compensation. If the value of the honorarium exceeds the IRS's reporting threshold, the recipient will receive an IRS Form 1099 from the University at the beginning of the following calendar year. With respect to persons on non-immigrant visas, it will be necessary to withhold taxes when paying the honorarium unless there is a tax treaty with the non-immigrant's country, which will be reported on Form 1042-S.