An IG inspection of a large NPC turned up just one deficiency: NPC management was unaware that a clinical trial sponsor was giving NPC employees bonuses for outstanding work.

The IG did not object to the NPC employees' receiving bonuses. The IG did, however, feel that it was inappropriate for the pharmaceutical company to pay the bonuses directly to the employees without the NPC executive director's knowledge and without giving the NPC the opportunity to deduct appropriate taxes, or the information necessary to issue an IRS Form 1099.

As a result, the NPC has modified its donation acknowledgment letter, stipulating that all payments pertaining to a specific research study will be made to the NPC. A sample paragraph to this effect follows:

The study will be performed as part of the investigator's official duties and there will be no personal compensation to the investigator. Additionally, the study was approved with the provision that all funding associated with the project will be administered by (NPC). Accordingly, payment for the conduct of the study may be made only to (NPC). Under no circumstances will payment in any form (cash, travel, gifts, bonuses) be made directly to the principal investigator, to any of the investigator's study employees, or to any other organization or party without prior written approval from (NPC).