Incentives and Finders Fees

Research sponsors may offer incentives to investigators and/or study personnel to encourage participant recruitment efforts and the timely or accelerated opening of research studies.  Incentives tied to the rate or timing of recruitment are prohibited.

Incentives may take the form of cash, office or medical supplies, gift certificates, trips, or other personal gifts. Such incentives may encourage, or appear to encourage, investigators and research personnel to put pressure on prospective subjects to enroll. However, this is prohibited.

Examples of prohibited bonuses: 

  • A sponsor announces that the highest enrolling site in the nation will receive a $10,000 bonus.
  • A sponsor offers to pay an additional $5,000 to any site that enrolls five participants within a week.
  • A sponsor offers to pay an additional $5,000 to any site that fulfills its recruitment target by the end of the month.
  • A sponsor offers to pay an additional $1,000 for any subject who agrees to enroll within one day of initial contact.

It is acceptable to receive fair compensation for recruitment and screening-related activities that are unrelated to whether the participant ultimately enrolls in or completes the research study (such as advertising, administrative, and personnel costs). Investigators should be sure to determine a reasonable budget amount that is directly related to the value of the services provided, and to document how that amount was determined. This amount should be reflected in the Clinical Trial Agreement budget.

For example, individuals could be paid on a flat hourly basis for the time spent recruiting and screening potential research participants (regardless of whether they are successful in recruiting those participants) and time sheets should be kept documenting this effort. Staff should not be paid a fee for every successful recruitment (e.g., $10 for every participant who signs the consent document to participate in the study).