The IRB/HRPP reviews the recruitment process before any recruitment strategies may begin - all recruitment materials, methods, procedures, and tools - used to recruit potential research participants. This review process is in place for all research protocols that require Brown IRB/HRPP approval in accordance with the Policy on the Recruitment of Human Subjects Research Participants.

The IRB/HRPP is charged by the federal regulations with ensuring that the selection of participants for research is equitable (45 CFR 46.111, 21 CFR 56.111). To meet this obligation, the IRB/HRPP will evaluate the purpose of the research and the setting in which the research will be conducted. The IRB/HRPP will assess the research to ensure that the recruitment process is appropriate, free from coercion and undue influence, and give special attention to research involving special or vulnerable populations to guarantee that additional protections are included to protect the rights and welfare of the participants.

Approval Requirements	Internet	Third-Party	Today@Brown
Crowdsourcing	Subject Pools	Not Allowed	FAQs

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Recruitment Material Approval Requirements

Recruitment Material Approval Requirements

The IRB reviews recruitment materials for all research protocols, including but not limited to, scripts, flyers, digital advertisements, video and audio, teaser ads, and landing pages. Recruitment materials must contain enough information to give potential participants a sense of the study and the ability to determine whether they may be eligible to participate.

Recruitment is part of participant selection, however a consent document is not recruitment material and cannot serve as a recruitment landing page. Complete recruitment process and materials must come before the consent process and document. 

Recruitment material(s) must include:

• “Brown University research study”
• The name and Brown contact information of research personnel knowledgeable about the research and procedures
  • First names are acceptable for added confidentiality
    • Ex: Contact Anna for more information!
  • Use a placeholder, indicated by brackets, for interchangeable information
    • Ex: Contact [name] at [401-863-XXXX] or [[email protected]] for more information!
• The study protocol number
  • Use a placeholder, indicated by brackets, for interchangeable information
• Any information needed for someone to determine their interest in and possible eligibility for participation. For example:
  • The condition under study or the purpose of the research
  • A brief list of participation benefits, if any (e.g., a no-cost health exam)
  • The time or other commitment required of the participants
  • Location of research activities

Recruitment material(s) cannot:

• State or imply a certainty of favorable outcome or other benefits beyond what is included in  the consent and protocol
  • Ex:  “This research study will change the course of HIV treatment.” or "This study will change Rhode Island policies for the better."
• State or imply that research procedures are known to be equivalent or superior to practices available to potential participants outside of the research context
• Describe research procedures as “new,” “safe,” or “effective” for the purpose under investigation
• Include exculpatory language through which a participant waives their legal rights, has their legal rights waived, or releases investigators, a study sponsor, or Brown from liability or negligence
• A promise of free medical treatment
• An emphasis on compensation, such as the use of font or design enhancements
  • Ex: Get PAID $300 to talk about yourself!

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Internet Recruitment

Electronic Recruitment Materials (social media sites, listservs, recruitment platforms, applications, newsletters, etc.) must comply with Brown recruitment requirements, as well as the policies of the specific location where the material is posted, whichever is more restrictive.

Materials must be clearly identified as recruitment for a voluntary research study and may not be located or posted in any way that could be easily mistaken for, or confused with, employment or paid work (e.g., Craigslist “Jobs” section). Private listservs or forums may only be used with the permission of the owner or administrator, including private or "invitation only" groups on social media platforms.

 

Teaser Ads

Teaser ads are used to raise people’s interest by including minimal content. These types of ads are helpful tools for researchers when platforms have content restrictions, such as word count or imagery, and the required recruitment elements cannot be included. These ads must link potential participants to a landing page that includes all required recruitment information. Per Brown’s recruitment policy, teaser ads do not meet the requirements for a complete recruitment process and may not transfer prospective participants directly to a consent process.

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Third-Party Recruiting

Third-Party recruitment occurs when a PI asks a personal contact, organization, or commercial entity outside of the research team, to recruit on behalf of the research team. Recruitment Material from a Third-Party recruiter must clearly reflect that the Third-Party is not involved in the research study and instruct potential participants to indicate their interest in the study by contacting the research team directly.

Example Third-Party Recruitment Methods:

• Have an organization forward an email from the Study PI to potential participants. 
• Have an organization share with potential eligible participants a study flier. 
• Use a Consent to Contact page to confidentially gather participant consent for the research team to contact them. 

Third-Party recruiters may not:

• Collect any research-related information from potential participants used to determine eligibility; and/or
• Provide information to a PI about potential participants that would breach the potential participants’ Confidentiality or Privacy; and/or
• Receive compensation for Recruitment, unless they are a commercial entity hired to recruit as a service and have no relationship with the potential participants.

Snowball Sampling

PIs may ask enrolled participants to recruit prospective participants (i.e. “snowball sampling”). The IRB/HRPP generally agrees that enrolled participants who do not receive rewards or compensation for referrals are unlikely to induce bias, or feel Undue Influence or Coercion. Appropriate measures must be taken by the PI and enrolled participants to ensure that the Confidentiality of prospective participants is not violated during this process.

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Today@Brown

Solicitations through Today@Brown for human subjects research recruitment are permitted for Brown research faculty if the study has ever been supported by sponsored funding and has Brown IRB/HRPP approval to use this recruitment procedure. Research under a reliance agreement (i.e., IRB Authorization Agreements [IAA]) in which Brown relinquishes IRB oversight is not eligible for recruitment using Today@Brown.

When requesting to use this recruitment process, researchers must adhere to the approval criteria laid out in the Policy on the Recruitment of Human Subjects Research Participants. The recruitment material must include the subject line that will be used in the Today@Brown posting as well as the full text to be used in the advertisement. The subject line may not feature or highlight any study compensation.

After approval by the IRB/HRPP, researchers who wish to use Today@Brown must:

• obtain a letter from the Brown HRPP affirming that the Brown IRB/HRPP has approved the use of Today@Brown as a recruitment tool for a specific study; and
• e-mail the approval letter to [email protected] on the same day as their submission to Today@Brown; and
• include the following copy in the Today@Brown submission message: “Use of Today@Brown for recruiting participants has been approved by Brown’s Human Research Protection Program.”

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Crowdsourcing 

Crowdsourcing is obtaining information by enlisting a large number of people, either paid or unpaid, typically via on digital platforms. Crowdsourcing is frequently used to recruit for human subjects research studies. All recruitment material used for crowdsourcing must follow Brown’s Policy on the Recruitment of Subjects Research Participants. If crowdsourcing does not allow the IRB/HRPP to review and approve recruitment material, it may not be used for human subjects research studies at Brown.

Crowdsourcing Frequently Asked Questions (FAQs)

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Research Subject Pools

A Research Subject Pool (“subject pool”) is a common recruitment method for researchers. Anyone can join a subject pool. By joining a “subject pool,” a person is showing their interest  to participate in research. Joining the subject pool does not mean they have consented to participate in a research study, since they have not yet been provided with sufficient information concerning the exact study in which they might participate. Until they go through a consent process, a member of a subject pool is not a participant in a research study. All subject pool members are free to decline participation in any research study at any time.

Subject Pool Frequently Asked Questions (FAQs)

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Recruitment Methods not allowed

At this time, the following recruitment methods or services are not allowed for human subjects research studies, as determined by the IRB:

Lucid survey sampling service – As part of their service, Lucid creates marketing material. However, the company does not share their material with the customer (the PI and Brown University) for review or approval before use with prospective participants. Since the IRB must review and approve all recruitment materials prior to their use, Lucid may not be used for recruitment of prospective participants in human subjects research studies at Brown.

For additional information regarding Brown’s recruitment requirements, please visit our IRB Guidance & Policies page and review our “Policy on the Recruitment of Research Participants.”

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Frequently Asked Questions (FAQs)

General FAQs | Crowdsourcing FAQs | Subject Pool FAQs

General Frequently Asked Questions (FAQs)

Can researchers compensate enrolled participants to recruit for a study?

No. Payment, compensation, reward, or bonuses in exchange for referrals of potential participants from others (known as “finder’s fees”) is not permitted unless the recruiter is a commercial entity hired to recruit as a service and has no relationship with the potential participants. Compensation of this kind may place prospective and enrolled participants at risk of Coercion or Undue Influence, or cause inequitable selection of participants.

What requirements are there for posting ads on Craigslist? 

Craigslist Ads have to be listed on the Volunteer page, and not under Jobs or otherwise imply that it is employment.

Can researchers hire social media "influencers" or “content creators” to post study ads? 

Yes, influencers or content creators can be a part of recruitment if they meet the criteria for Third-Party recruiters. These Third-Party recruiters must abide by the Third-Party recruitment section of the IRB Recruitment Policy.

Do recruitment images or graphics require IRB/HRPP approval?

IRB/HRPP does not need to approve recruitment images or graphics. However, they may be reviewed to ensure they are appropriate for the population and do not create a potential for risk or harm (i.e. undue influence or offensive content). If there are questions on whether an image is acceptable, reach out to University Communications for more information. 

What happens if I want to make a minor content change to my already approved recruitment material such as a change to the headline, compensation, or contact information?

All content changes require IRB/HRPP review through a Modification request, including for recruitment material. All changes must be approved by the IRB/HRPP prior to going live on a flier, email, or platform.

What if I don’t have a Brown phone number to use in my recruitment material or consent document? Can I use my personal phone number?

No, only Brown University contact information can be used on outward facing materials such as recruitment or consent documents. If you do not have a phone number you can reach out to the Office of Information Technology’s telephone service to receive one. You can also work with OIT to set up a study specific Brown University email.

What can I do if I have a special circumstance that won’t allow me to comply with the recruitment policy? 

Investigators can request an exception to an approved policy during an initial study or modification review. Submissions that include a policy exception request will be reviewed at a convened meeting by the Full Board. More information can be found on our Waivers and Exceptions webpage.

Crowdsourcing Frequently Asked Questions

Can I use crowdsourcing to collect data for my human subjects research studies at Brown?

Brown University’s Office of Information Technology (OIT) is responsible for determining which software and services are available for Brown human subjects research. 

We strongly encourage your crowdsourcing recruitment material to direct prospective participants to a Brown data collection platform, like Qualtrics, in order to consent participants and conduct human subjects research activities.

If it is an important part of your research design to collect participant information from a crowdsourcing platform that OIT has not yet vetted, the platform will require an Ancillary Review by OIT. This review will not delay IRB/HRPP review or approval of your research, but it may delay implementation of your IRB/HRPP-approved procedures.

**Please visit the OIT Software Catalog for more information.

Can I use crowdsourcing to compensate participants for my human subjects research studies at Brown?

The Brown University’s Controller’s Office is responsible for ensuring the proper stewardship of the University’s financial resources. The IRB/HRPP 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 you for human subjects research.

We strongly encourage you to design your study using one of the compensation methods approved by the Controller’s Office. If you intend to use a method of compensation that is not approved, you will need to contact Accounts Payable ([email protected] or (401) 863-2716) for consultation and approval for its use before including the compensation in your IRB/HRPP Application.

**Please visit the HRPP Compensation page for more information.

Are there confidentiality concerns or limitations to privacy with using crowdsourcing?

Yes. These concerns can vary depending on the type of crowdsourcing platform you use and/or research you conduct. 

Do I need to add special confidentiality language to my consent document when I use crowdsourcing to collect data?

Yes. Required consent language specific to IRB/HRPP-approved crowdsourcing is available in the Additional Consent Language Guidance documents on the HRPP website.

This language should be added to the confidentiality section of your consent document.

• Standard Consent Template: “7. How will my information be protected?”
• Bulleted Consent Template: “Confidentiality”

Subject Pool FAQs

Does Brown have a subject pool?

Yes. Many Brown departments and labs have chosen to set up subject pools.

Do human subjects research studies using subject pools need HRPP/IRB review?

Yes. All human subjects research studies must have HRPP/IRB approval to use subject pools for recruitment.

All recruitment material must meet the requirements for approval as described in the HRPP Policy on the Recruitment of Research Participants, and include:

• protocol number
• first name (at a minimum) of the PI or a member of the research team
• “(PAID)” OR “(CREDIT)” after the study title – REQUIRED ONLY for CLPS studies using the Research Participation System (“Sona System”)

Can any human subjects research study use a subject pool?

No. Research under a reliance agreement (IAA) in which Brown relinquishes IRB oversight cannot use subject pools for recruitment.

Can I use Today@Brown to recruit people for my study conducted through one of Brown’s subject pools?

Yes. Use of Today@Brown is allowed for Brown research faculty if the study is supported by sponsored funding (including Brown internal sponsored funding, e.g., Office of the Vice President for Research Seed and Salomon awards) and has Brown IRB/HRPP approval to use this recruitment procedure.

Student research and research under a reliance agreement (IAA) in which Brown relinquishes IRB oversight cannot use Today@Brown for recruitment.

Brown’s subject pool administrators should work with University Communications to advertise for volunteers. As long as the administrators are seeking volunteers to join the subject pool and not prospective participants for research studies, they do not need IRB/HRPP approval to use Today@Brown.

What type of compensation can I provide using a subject pool?

Compensation for study participation in the subject pool may be in the form of cash, gift cards, or Brown course credit.

Although you can use a variety of payment options through a subject pool, you may not combine them. You must decide whether compensation will be monetary or course credit, and this must be clearly reflected in your recruitment material.

Can professors require that students participate in research as part of their class or for a grade?

No. By federal law, research participation can only be voluntary. Federal regulations require that all human subjects research minimize the possibility of coercion and undue influence. Whenever research participation is a course requirement, or when extra credit or course credits are offered for participation, students must be informed of non-research alternatives involving comparable time and effort to fulfill the course requirements or obtain the credit in order for the possibility of undue influence to be minimized. Students cannot be penalized for refusing to participate in research.

Can extra credit and course credit constitute undue influence?

Yes, in certain circumstances. Non-monetary incentives can create undue influence on a person’s decision to enroll in research.

Researchers should ensure that non-financial incentives are not so great that they reduce a person’s voluntariness to consent to participation or their ability to appreciate the potential risks involved.

To avoid undue influence over students, when faculty offer extra credit or course credit through research, another non-research opportunity to earn that credit must be provided concurrently. Research participation may not be the only avenue for students to earn that credit in a course. So to, the non-research alternative must be comparable to the time and effort expected in the research study. It must be clear that choosing not to participate in research will not in any way adversely affect a student’s relationship with Brown, their professors, teaching assistants, or peers.

What options do professors have as an alternative to research participation for students to earn credit?

Faculty are encouraged to work directly with subject pool administrators to ensure that their non-research alternative options and research studies are equitable.

Examples of non-research alternatives that might take roughly the same amount of time and effort as research participation:

• reading journal articles or empirical papers and answering questions
• writing a 1-2 page paper about comparable research
• attending colloquia

What should I do if a participant withdraws or if I need to terminate the session without completing the study procedures?

Enrolling in a research study is voluntary. Every participant is allowed to withdraw from a study at any time during the research. So too, you might need to terminate a study session for reasons that have nothing to do with the research or if the participant is not following the terms of the study.

If a participant withdraws during a study procedure or if you terminate the study session, you must provide the participant with the full compensation (monetary or course credit) for that session, as listed in the compensation section of the consent document.

If the participant withdraws (i.e., cancels appointment or does not appear for the appointment), you do not need to compensate the participant for that session.

Can I use a subject pool if my human subjects research involves deception?

Yes, but you should use a debriefing process if appropriate for your study design. This debriefing process should occur within a reasonable amount of time after the participant has completed the study procedures or when the study is over. During this process, participants must be told about the nature of the deception and, if the data is identifiable, you should ask permission for continued use of the data. See the IRB/HRPP webpage on Deception and Incomplete Disclosures for more information on requirements.

What happens if my funding expired, but I still want to use Today@Brown?

PIs whose association with their sponsor ended within the last two years (or within the last two years of their no-cost extension), may continue to use Today@Brown to recruit for their previously-funded study. To do this, PIs must inform the IRB/HRPP that their intended advertisement on Today@Brown is consistent with the research that was funded by the sponsor.