Paying Participants

Payment incentives are often used by researchers to encourage human subjects to participate in research. This section discusses the ethical guidelines for issuing incentives and also provides information about tracking payments and other payment logistical issues. Before you decide to pay participants, it is important to understand the definition of a “payment,” weigh the benefits and risks of paying a participant, and understand how to deliver appropriate information to the participant.

What is a payment?

Any incentive given to a participant to encourage participation is considered a payment. This can include (but is not limited to): checks, cash, gift cards, event tickets, food items, computers, course credit, extra credit, materials used in the study that are not returned to the researcher, etc. Compensation given to cover a participant’s study expenses (i.e. travel, lodging) are not considered payment.

How much is too much?

The IRB does not regulate specific amounts for paying participants. Instead the Board evaluates the payment based on the risk in the study and the participants involved. If the payment entices a participant to take on risks they would not normally do then the Board considers the payment unethical. For example, paying a low-income participant a large sum to participate in a risky procedure would be considered unethical. Payment should not be the sole driving force for participating in the study.  

Please note that there are additional rules for payment documentation (created by the Procurement Services Office) that may affect the amount you pay participants.  Please see the "Special requirements for studies where payment is funded by UVA or State funds (including Grants)" section for more information.

What do I include in advertisements and/or in a consent form?

An advertisement can include information about a payment but the payment should not be the focus of the advertisement. The information about the payment should be upfront and clear without any use of marketing gimmicks.  The consent form will provide the participant with further information about payment details in the “Payment” section.  The “How to withdraw” section should also include information about what happens if a participant decides to withdraw from a study.  Generally the Board requests that a participant be either given the entire payment or that the payment be prorated according to amount of participation given.  Payment policy should not be such that it coerces or compels a participant to complete the study even though they may wish to withdraw. 

If you plan to collect social security numbers or tax identification numbers in order to issue payment through Oracle, you will need to inform participants that you will ask for this information. Use the following statement in the "Payment" section of the consent form (or modify it so that it fits your study): “We will ask for the following information in order to process payment to you for your participation in this study: name, address, phone, email, SSN/tax ID, etc. You are not required to provide this information but if you decide not to, we will not be able to compensate you.” For more information about this process, see the "Special Requirements for Studies Where Payment is Funded by UVA or State Funds (Including Grants)" section. 

How do I issue payment?

In your protocol, you will need to include a detailed explanation of how you will issue payments to the participants.  As part of your payment procedures, you need to address any issues that will prevent you from protecting your participant’s confidentiality or maintaining anonymity. For example, if you are conducting an anonymous survey but you want to pay the participants for their participation, you need to devise a method for collecting information for payment so that it is separate from the survey.  Where the money comes from and how it gets to a participant can affect the procedures for issuing payment as well as protecting participant confidentiality. In your protocol, you will need to describe how payment will be issued and what you will do to protect confidentiality and/or anonymity.  

Please note that if the funds you are using to issue payment come from U.Va. or state funds, there are additional rules regarding how payment should be made. For more information, please see Special requirements for studies where payment is funded by UVA or state funds (including Grants).

Special Requirements for Studies Where Payment is Funded by UVA or State Funds (Including Grants)

If you are paying participants using funds from a UVA or State funds (including individual, outside grants administered by UVA), the preferred method for paying participants is to issue a check using Oracle. In order for UVA to account for all payments made for tax purposes, UVA’s Procurement Services is charged with tracking payments. Tracking individual payments for the purpose of keeping accurate records for taxes is not generally a concern of the IRB-SBS.  For the Procurement Services office, it would be easier and cleaner if researchers would simply issue checks through Oracle for every payment made to participants. Procurement Services recognizes that this is not always possible and asked the IRB-SBS to review cases to determine if alternative payment methods are justifiable.  As a researcher using funds administered by UVA, you are required to document payments made. We hope that by assisting researchers and Procurement Services with this issue, we will be able to allow researchers the flexibility they need to protect participants while providing the documentation that Procurement Services needs.
The following studies are not subject to this requirement:

  • Participant payment or other compensation will come directly from sponsor of research trial (i.e. funds for participant payments will not go through U.Va.’s grants and contracts office).
  • Researcher is using their own personal funds (funds not administered by UVA) to compensate participants.
  • The participants do not reside in the United States and they do not have a social security number and/or tax identification number.
  • Compensation to participant is limited to reimbursement for travel, lodging, or other study related expenses.
  • Compensation will come from a U.Va. Foundation not subject to UVA's financial policies and procedures.

As mentioned above, Procurement Services recognizes that there may be instances in which using Oracle may not be appropriate for various study situations and populations.  For example, to process a payment in Oracle, you must provide the participant’s social security number. The participant’s name is also linked in the Oracle system with the participant’s study name. For studies where the loss of confidentiality may be a risk to the participant, it may not be appropriate to issue a check to a participant through Oracle.  For other studies, the payment offered to a participant may be too small to require attention from the IRS and the collection of personal information would hinder data collection.  For example, anonymous surveys often pay participants with a food item or petty cash. If you are not able to collect participant identification for processing Oracle payments, please keep the amount paid to an individual participant less than $100 over a twelve month period. Please read the Procurement Services' document and make sure you understand their policies regarding issuing payment.  

The "compensation" question in the iProtocol Participant Groups section is designed to help researchers describe this process. If you mark "Option E: other form of payment (i.e. cash, gift card, gift) for value greater than $100. IDs are not collected" you will need additional permission to proceed. Our staff will contact you with more information on how to proceed but know that permission is reserved for special cases and is not often allowed.