Principle of Incentive and Reimbursement
Principle of Reasonable Compensation
Compensation at Brown
Cash & Gift Cards/Certificates
Community & Culture
Method of Disbursement
Pro-rated payment and bonuses
No Discounts allowed
Compensation that is not allowed
Compensating research participants is not required. You may provide compensation, but the payment for participation is not considered a benefit but rather a recruitment incentive or reimbursement for time and effort. All payments to participants in research must be fair and equitable.
The IRB will review and determine that the amount is reasonable and not so large as to unduly induce participation. All information concerning payment, including the amount and schedule of payment, should be clearly stated in the application and reflected in the consent documents.
When the IRB evaluates the selection of participants, it considers the influence of payments to participants. While the Federal Regulations do not specifically state how much researchers should pay subjects or what that payment should look like, the IRB will apply a principle of reasonable compensation as it reviews participant payment for their time, effort and inconvenience.
The Brown University’s Controller’s Office is responsible for ensuring the proper stewardship of the University’s financial resources. The IRB relies on the Controller’s Office to determine which forms of compensation comply with federal and State laws, and University policy. Only these forms of compensation are available to investigators for human subjects research.
We strongly encourage you to design your study using one of the compensation methods approved by the Controller’s Office listed below. If you intend to use a method of compensation that is not approved, you will need to contact Accounts Payable for consultation and approval for its use before including the compensation in an IRB application.
Brown uses ClinCard to manage the reimbursement process for study participants. ClinCard is a participant payment system that makes it easier, faster and more secure to provide compensation to participants and to track payments through an online system. Studies that use the ClinCard as a means to provide monetary compensation to participants must include required language in the consent document as well as an IRB-approved FAQ document about the system. Study staff may also be required to attend a training on the use of the system. If study participants wish to cash out their ClinCard balance at a bank teller, as a means to get cash without incurring a fee, it is recommended that they take a copy of this form to the bank with them.
If you are interested in using the ClinCard in your study, please contact the Controller's Office. More information about the ClinCard can be found on the Controller's Office ClinCard page.
Cash payments and gift cards (plastic, paper, or electronic) are common ways to compensate participants. Please review Brown’s Gift Cards policy for any requirements that may apply to your study.
Even if you will not collect identifying information about your participants, you should establish a way to track the cash payments and/or gift cards given to participants for reporting purposes to the Controller’s Office.
For example, consider keeping an Excel sheet which links a unique identifying number from each gift card to an assigned study ID associated with a given participant.
The IRB will also take into account information from the community and culture as it evaluates the appropriateness of participant payment.
You should submit your payment plan when you submit the initial application for IRB review. The IRB will review both the amount of payment and the proposed method and timing of disbursement to assure that neither is coercive nor presents undue influence.
Your advertisement may state that participants will be paid, but should not emphasize the payment or the amount to be paid, by such means as font (i.e. large or bold type) or design enhancements (i.e. subject/tag lines in electronic communications).
Payment for participation in research should not be contingent upon the participant completing the entire study but rather be prorated as the study progresses to insure voluntary participation. 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 providing that such an incentive is not coercive. If a bonus is given at the completion of the study it should not be more than ½ of the total reimbursement.
Compensation for participation in a clinical trial offered by a sponsor may not include a coupon good for a discount on the purchase price of the product once it has been approved for marketing.
The Controller’s Office may determine that a compensation method does not meet Brown’s requirements for a number of reasons (i.e. it does not offer buyer or seller protection, there are no special authorizations, no offers of controls or reconciliation capability that would be acceptable to Brown, or no ease of payments for the user.)
The determination of which compensation options are available for human subjects research is not a decision that is made by or can be overturned by the IRB.
If you would like to request that the Controller’s Office consider a method of compensation that is not already approved by Brown for use in human subjects research, please contact Accounts Payable at [email protected] or (401) 863-2716.
At this time, the following compensation methods are specifically not allowed for human subjects research studies, as determined by the Controller’s Office:
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Venmo mobile payment service