Compensating Research Participants

Summary

When compensating human research subjects/participants, there are certain guidelines that need to be followed. "Compensation" includes non-monetary rewards, such as course/extra credit.

Full Description

What counts as "compensation?"

Rewarding participants using monetary or non-monetary means can count as "compensation." Within the IRB application, all forms of compensation for participation need to be described. 

• Non-Monetary Example: Use of the SONA platform allows for researchers to "reward" students with course hours. If you offer extra credit or course hours for participation in a study, an alternative must be offered to earn the same amount of extra credit. 
  • Example Consent Language: You do not have to do this study. You can select a different study in SONA or ask your instructor for an alternative assignment for equal credit that takes the same amount of time and effort.
• Monetary Example: Participants will be given a $15 Amazon giftcard for completion of the entire study. 

Compensation Considerations

• Drawings: This is a "random" chance that a participant may receive compensation. In your IRB application and participant-facing documents, be sure to avoid "gambling" terms, such as "raffle," 
• Partial Credit/Compensation: If participants will receive "prorated" compensation based on length of participation, make sure to explain in the consent/protocol application the "rate" of compensation
  • Example: If you don't complete all three study visits, you will only receive compensation for the visits that were completed

Using Drawings as a Compensation Method

The W&M distinguishes IRB-approved research incentive drawings from lotteries or raffles regulated under Virginia law. When structured appropriately, drawings used for research compensation do not meet the legal definition of a lottery because they are not commercial gaming activities and do not involve “consideration” in the traditional sense.

Participation in research is not viewed as consideration for entry, and the drawing is treated as an incidental token of appreciation rather than a gambling or fundraising mechanism.

Because of this distinction, W&M generally does not apply the Virginia lottery disclosure requirements (including stating exact odds) to research incentive drawings. Instead, the IRB reviews these incentives under informed consent and undue influence standards, with an emphasis on transparency and non-coercive framing rather than statutory gaming disclosures.

As part of that approach, researchers must be careful about terminology. Researchers should avoid language commonly associated with gambling or lotteries (such as “win,” “won,” or “chance to win”) and instead use neutral, descriptive phrasing (e.g., “entered into a drawing” or “selected to receive”). This helps reinforce that the drawing is a research incentive rather than a gaming activity.

 As a result,  consent language typically:

• Clearly states that entry into the drawing is not guaranteed compensation
• Describes the nature and number of gift cards
• Explains how the drawing works (e.g., one entry per participant)
• Uses non-gaming language and avoids overstating the likelihood of receiving a gift card

 For example:

• “Participants will be entered into a drawing for one of seven $10 Amazon gift cards. Not all participants will receive a gift card. The gift card will be sent to the email provided if you are selected. Participants must complete the entire survey and pass all the attention checks to be eligible for the drawing. There is a limit to one entry per participant.”
• “Participants will be entered into a drawing for the chance to earn a W&M-branded water bottle. There are two water bottles available, and therefore, not all participants will receive one. Participants who are selected will be sent an email detailing the instructions for pick up. You will be asked to provide your email within the survey. Participants must complete the entire survey and pass all the attention checks to be eligible for the drawing. There is a limit to one entry per participant.”
• “As a token of appreciation, participants will be entered into a drawing for one of [number] [item(s)]. The odds of being selected are based on the total number of participants who complete the study. For example, if 100 participants complete the study, the odds of receiving a gift card would be approximately 1 in 100. The gift card will be sent to the email provided if you are selected. Participants must complete the entire survey and pass all the attention checks to be eligible for the drawing. There is a limit to one entry per participant”
• Alternatively, if there is a known maximum enrollment, researchers can use:
  • “Up to [maximum number] participants will be enrolled in this study. [Number] of gift cards will be awarded. If all slots are filled, the odds of receiving a [gift card] would be approximately 1 in [maximum number].”

Because the IRB do not treat these drawings as lotteries, researchers do not need to calculate or disclose exact odds, particularly when enrollment numbers are unknown at the time of consent.  This approach avoids odds calculations entirely, consistent with our interpretation that the gaming statute does not apply in this context. 

Monetary Compensation and Accounts Payable

Accounts payable lists policies related to paying human participants.

PIs and researchers are responsible for reviewing and following all applicable payment policies. 

ACCT. PAYABLE: HUMAN SUBJECT PAYMENTS

• Financial Operations Procedure for Paying Human participants
  • Click "Direct Payments" and scroll to "Human Subjects Payments"
• Compensation must be documented using a payment log: Human Subject Payments Logs.
  • There are logs available for: 
    • Payment Log for Payments $50 or less
    • Payment Log for Payments from $51 to $100
    • Payment Log for Payments $101 or greater

If you have questions or experience difficulties accessing the documents, please contact Accounts Payable for assistance.