On the A/R tab at Accounting / Setup / Preferences, in the Payments section, select the Require Reference # for Checks preference, and choose Save.

With the Require Reference # for Checks preference turned on and Check selected as the Pay Method, a check number must be entered in the Ref # field on the Payment. Saving the Payment is stopped if Check is selected as the Pay Method, the Pay Amount is not equal to zero, and a Ref # is not present.

This preference affects Payments taken at Accounting / A/R / Payments, the Add a Payment on Account shortcut icon, the Receive Payment(s) on Account roll through payment window for Invoices and Bookings, and Quick Tickets.