308. Recruitment Incentives/Payment for Participation

Updated July 1, 2019

Volunteers are sometimes paid for participating in biomedical and behavioral research. Incentives/payments are usually monetary but other types of rewards or gifts may be offered. For example, classroom research may offer extra credit for students, although additional requirements apply to student credit for research participation. Payments may include reimbursement for costs for travel, babysitting, or other expenses resulting from or related to participation in the research.

Considerations in the Use of Recruitment Incentives or Payment for Participation

Regardless of the form of remuneration, considerations relating to incentivizing or paying for research participation remain the same. Researchers and the IRB must

  • consider whether participants in research are recruited fairly, informed adequately, and paid appropriately (i.e., payment amount is commensurate with the time and effort required for participation); and
  • ensure the rewards offered for participation in research do not constitute undue inducement.

Incentives/payments that may constitute undue inducement vary among research environments. Regardless, undue inducement is problematic. Offers that are excessive or overly attractive may

  • distort the perception of risks for participation in a study
  • impair a prospective participant's ability to exercise proper judgment; or
  • prompt prospective participants lie or conceal information that, if known, would make the ineligible to enroll in the research.

Assessing the appropriateness of an incentive or payment may require consideration of the prevailing payment practices within an institution or general locale, or among a particular research population.

For research that requires subjects to undergo only minor inconvenience or discomfort, a modest payment is generally acceptable.

Payment for participation in research that involves the assumption of risk or significant discomfort requires a more thorough assessment. The following questions may be useful for researchers and the IRB to assess the appropriateness of payment for greater than minimal risk research:

  1. Are the conditions for research participation consistent with standards for voluntary and informed consent?
  2. Are the incentives/payments offered reasonable given the subject population and the complexities, inconveniences, and risks of the study?
  3. How likely is it the incentives/payments may induce an individual to participate when she/he might otherwise not volunteer?
  4. Are there special standards the IRB ought to apply to the review of research in which volunteers are asked to assume significant risk?
  5. Should the IRB monitor subject recruitment or consent to evaluate whether the incentives/payments may be a disproportionate inducement to prospective participants?

Completion of a research activity may not be a criterion for payment. For studies involving multiple contacts or a lengthy time commitment, payment should accrue as the study progresses (as appropriate to the research). Participants who withdraw before completing the study would receive the amount earned according to time spent in the research. 

Payment for participation in studies is not a research benefit.

Researchers must describe the amount, and distribution schedule and processes for incentives/payments in the appropriate researcher form at the time of initial review, or in a protocol amendment if an inventive/payment is being added to an approved study. This requirement applies to all review levels: exempt, expedited, and full committee.

Requirements for Informing Prospective Participants about Incentives/Payments

The following information must be disclosed to prospective participants prior to enrollment:

  • amount of incentives or payments, including the approximate value of non-cash gifts;
  • payment schedule;
  • the odds of winning (if incentives/payments will be in the form of a drawing or raffle);
  • participant requirements to receive incentives/payments (including if receipts are required for reimbursable expenses);
  • conditions under which payment will be reduced (e.g., participant withdraws part way through the research); and
  • institutional requirements for the researchers to report participant information to disburse payment.

Additional Considerations for Cash Incentives and Gift Cards

When funds originate from University accounts, researchers planning to provide cash or gift cards are advised to contact the Controller's Office to determine the information that will be required to process disbursement requests.

If researchers must provide Protected Personally Identifiable Information (see IRB Policy Manual Definitions) from participants for the processing of disbursement requests, participants must be told what PPII will be collected, why it is being collected, and to whom it will be provided.

PIs must include information about ensuring the privacy of this information in the relevant sections of the applicable researcher form.

Additional Considerations for Course or Extra Credit for Student Participants

Research Credits through University SONA Systems

Investigators are advised to follow subject pool policies and procedures related to

  • student recruitment and enrollment,
  • schedule for amount of credit and anticipated time commitment for participation, and
  • notifying professors about their students' participation in a study.

Deviations from subject pool standard procedures must be specified in the applicable researcher form.

NOTE: It is understood that students enrolled through the University subject pools have alternative activities that are equivalent in time and effort to the research participation and that offer the same amount of credit.

Extra or Course Credit from Individual Professors

Students may not be required to participate in research for extra or course credit. If extra or course credit is offered for research participation, a comparable non-research alternative must also be offered. The alternative to participating in the research must be comparable to the research participation in time, effort, and amount of credit or fulfillment of course requirements.

At its discretion, the IRB may request documentation specifying the amount of extra credit, unit of time per credit, and alternatives to research participation that will be offered by all participating professors.

Providing Information about Extra or Course Credit in Recruitment and Consent Materials

  1. If extra or course credit is mentioned during recruitment, the recruitment materials should
  • specify the amount and "value" or type of credit that may be earned; and
  • state that students will be given equivalent, non-research alternatives to earn equal credit.
  1. Consent materials should
  • state alternative activities are available for students who decline to participate in the research;
  • specify the amount and types of credit offered, and required unit of time per credit for both the research participation and the alternative activity; and
  • describe the parameters for earning the credit whether for the research or the alternative activity; and
  • explain how professors will be notified of their students' research participation (when applicable).

Prohibition Against Incentives/Bonuses for Investigators or Others to Recruit Subjects

University and affiliate researchers and staff are prohibited from receiving or dispersing bonuses or incentives for recruitment, referral or enrollment.