308. Recruitment Incentives/Payment for Participation

Updated July 1, 2021

Participants 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. Payment for participation in research should be just and fair. The amount and schedule of all payments should be presented to the IRB at the time of initial review. The IRB should review both the amount of payment and the proposed method and timing of disbursement to assure that neither are coercive or present undue influence. While the entire payment should not be contingent upon completion of the entire study, payment of a small proportion as an incentive for completion of the study is acceptable to the IRB, providing that such incentive is not coercive. Researchers may provide a monetary or gift incentive, such as a gift card or t-shirt, to thank participants for their time and effort. 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. Payment for participation in studies is not a research benefit.

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);
ensure the rewards offered for participation in research do not constitute undue inducement;
ensure the amount paid as a bonus for completion is reasonable and not so large as to unduly induce participants to stay in the study when they would otherwise have withdrawn.

Payment that is excessive or inappropriate in relation to the research procedures is problematic for several reasons. It can induce individuals to participate against their better judgment. In addition, excessive incentives can encourage some individuals to lie or to withhold information to participate in the study when they do not meet the eligibility criteria. This impacts not only the integrity of the research and the validity of the data but can also compromise the safety of subjects. Inappropriate payment can also create coercive situations when given to third parties. For example, a parent may coerce or pressure their child into participating in a study when payment is significant. Thus, 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 to lie or conceal information that, if known, would make them ineligible to enroll in the research.

Incentives/payments that may constitute undue inducement vary among research environments. 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 example: A $100 incentive to physicians for a one-hour focus group during the work day may be considered an appropriate incentive. A $100 incentive to high school students to participate in the same focus group may not be appropriate.

Payment for participation in research that involves the assumption of risk or significant discomfort requires a 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:

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

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. Completion of a research activity may not be a criterion for payment, except for small, non-coercive bonuses added as an incentive to accrued payments.

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

Participants should be accurately informed through the consent process about any payment/incentive for participation. If or when questions or complaints arise regarding payment, the consent form becomes the source document for the information that was provided to participants. The information about incentives/payment should be clear, detailed, and consistent with the protocol. 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 Offering Lottery or Raffle

Nevada Statute, Chapter 462 defines “lottery” as “any scheme for the disposal or distribution of property, by chance, among persons who have paid or promised to pay any valuable consideration for the chance of obtaining that property, or a portion of it, or for any share or interest in that property upon any agreement, understanding or expectation that it is to be distributed or disposed of by lot or chance, whether called a lottery, raffle or gift enterprise, or by whatever name it may be known.”

Nevada law requires the operator of a qualified organization to register with the Chair of the Gaming Control Board.

Operation of charitable game without license. A qualified organization may operate a charitable game without obtaining a license pursuant to NRS 463.160 if:

The qualified organization is registered by the Chair to operate a charitable game pursuant to NRS 462.150; and
The total value of all the prizes offered in charitable games operated by the qualified organization during the same calendar year does not exceed $500,000. (Added to NRS by 2019, 957)

NRS 462.160 Registration of qualified organization: Application; fees; regulations; expenditure of application fees.

To register with the Chair to operate a charitable lottery or charitable game, a qualified organization must submit to the Chair:
1. A written application containing:
  1. The name, address and nature of the organization.
  2. Proof that the organization is a qualified organization.
  3. The names of the officers or principals of the organization, and of any person responsible for the management, administration or supervision of the organization’s charitable lotteries or charitable games and any activities related to those charitable lotteries or charitable games.
  4. A listing of vendors who will assist with each charitable lottery or charitable game operated by the organization and the services that will be provided.
  5. A description of all the prizes to be offered in each charitable lottery or charitable game operated by the organization.
  6. A summary of the anticipated expenses of conducting each charitable lottery or charitable game, including copies of any proposed agreements between the organization and any suppliers of material for the operation of each charitable lottery or charitable game.
  7. A description of the intended use of the net proceeds of each charitable lottery or charitable game operated by the organization.
  8. The address of the location where each charitable lottery or charitable game will be conducted by the organization.
  9. The operational controls for each charitable lottery or charitable game, including, without limitation:
    1. The methods proposed for ticket sales and, if proposing mobile, online or telephone sales, the procedures for such sales;
    2. The audit controls for all ticket sales in this State to ensure compliance with NRS 462.180;
    3. The rules which will be presented to the public for each charitable lottery or charitable game;
    4. The method of awarding all prizes and announcing all winners to the public; and
    5. The rules and time frames for the collection of all prizes.
  10. A statement verifying that all charitable lotteries or charitable games will be conducted in accordance with the standards of honesty and integrity applicable to licensed gambling games in this State and that any prizes that would be deemed illegal under state or federal law will not be offered.
  11. Any other information the Chair deems appropriate.
2. All applicable fees established by the Commission by regulation pursuant to subsection 3.
A qualified organization shall submit such additional information as necessary to correct or complete any information submitted pursuant to this section that becomes inaccurate or incomplete. The registration of a qualified organization is suspended during the period that any of the information is inaccurate or incomplete. The Chair may reinstate the registration of the organization only after all information has been corrected and completed.
The Commission, upon recommendation by the Board, shall adopt regulations establishing the fees that a qualified organization must submit to the Chair pursuant to this section.
The money collected pursuant to this section must be expended to administer and enforce the provisions of this chapter. (Added to NRS by 1991, 2259; A 2019, 960)

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. It is the responsibility of the Principal Investigator to maintain accurate payment records. When identifiable information is collected for accounting purposes, researchers are reminded to follow all appropriate standards to maintain the confidentiality of participant information. 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

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.
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 Participants

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