Incentive payments are payments or items given to individuals in order to encourage participation in research. Incentive payments may include small dollar items, such as cash, gift cards, gift certificates, or other tangible, small value items such as pens, mugs, or keychains. For example, a research participant may be given a CSU mug for participating in a survey, or they may be paid $25 (by cash or gift card/certificate) to participate in a computer simulation in a research lab.

Risk-Benefit Considerations

Paying research subjects in exchange for their participation is a common recruitment practice. The incentive should be reasonable in relationship to the anticipated benefits and should be provided to all participants, regardless of study completion. When determining incentive value for budgeting purposes, researchers should take into consideration participant time, inconvenience, and equity. The amount and schedule of all payments should be presented to the Institutional Review Board (IRB) for review and approval. The IRB will review the compensation plan and amount to ensure that payment does not present undue influence to participate.

IRB review is based on three primary ethical principles: Respect for Persons; Beneficence, and Justice. Incentive arrangements should be designed to ensure that participants are treated equitably and that the amount will not unduly influence someone’s decision to participate. Through a consent process, each participant should be fully informed of what information researchers will collect, for what purpose, and how it will be handled — including a clear overview of the incentive plan. 

As a best practice, the IRB suggests that research activities that will take place over multiple research visits incentives should be prorated. Some investigators offer a prize drawing instead of paying each participant a direct incentive. In this case, investigators should disclose the odds of winning up front. For example, 1 in 100 will win. 

Incentives on Sponsored Program Accounts

For those assisting with budget development, payments for incentives should be budgeted under ‘Other Direct Costs’ and should be justified in the budget narrative. In KR PD, select the budget category, ‘Other Direct Costs‘ with the description of ‘Participation costs – F&A applies.’ Do not budget under ‘Participant Support Costs.’

Incentives paid from sponsored programs (5-3) accounts must be allowable under the terms of the sponsored agreement. In accordance with Institutional policy, cash incentives should not exceed $100 per incentive or instance and should not exceed $599 during a calendar year. Costs associated with entertainment (e.g., tickets to shows or sporting events) are generally unallowable (2 CFR § 200.438). Charges to the award should be in-line with payments approved by the IRB and by the sponsor.

Financial Considerations

In addition to conforming to what is approved in the research project’s IRB protocol and to sponsor guidelines, incentive payments should be made in accordance with CSU’s financial procedure instructions on ‘Research, Survey and Other Related Incentives’ (FPI 2-10).

Because payments, except for expenses based on actual receipts (such as parking expenses), are taxable, CSU has an obligation to track payments to participants for the purpose of reporting to the IRS. Coding all incentive payments made by gift card/certificate and direct payments to the object code 6710 ‘Research/Study Incentive Payments’ allows for tracking of incentive payments. Additionally, the PI or person conducting the research is required to maintain a list that contains the study participant’s name, SS#, address, and signature acknowledging receipt of funds for tracking and reporting purposes. This list may need to be coded by the PI in order to maintain participant confidentiality as described below.

Confidentiality and Data Management Considerations

Human subject researchers are encouraged to collect the minimum amount of identifiable information needed during their research in support of protecting participants confidentiality.

Researchers have a responsibility to protect participant confidentiality. When collecting tax information for reporting requirements, researchers should have a comprehensive data management plan to collect and manage participants’ sensitive information. Plans may include details on how tax reporting data is kept separately from research responses.

In Conclusion

Providing incentives for research can be an effective way to reach participants with the right experience to answer the research question at hand. Utilizing this recruitment tool requires that researchers proactively plan for requirements related to IRB approvals, sponsor funding agreements and CSU tax reporting requirements. Luckily, there are resources at CSU to help researchers succeed.

For questions on providing incentive payments to research participants, consult FPI 2-10.  For questions on Human Subjects Research, contact the CSU IRB ([email protected]).