Brown’s Human Research Protection Program (HRPP) team, along with the Institutional Review Board (IRB), reviews and determines whether compensation is reasonable and if it unduly influences participation. All information concerning compensation — including the method, amount and schedule of payment — should be clearly stated when submitting study materials for HRPP/IRB review. 

The HRPP team and IRB will take into account information from the community and culture as it evaluates the appropriateness of participant compensation.

Consent Forms for Research Participants

All payments and gifts to research participants are considered income by the Internal Revenue Service (IRS) and may be reportable to the IRS as taxable income. You are responsible for informing participants during the consent process that the payment they receive is taxable income and may be reportable to the IRS.

If a participant receives $600 or more from one or across a combination of research studies at Brown University within one calendar year, they will be taxed on this income. You are required to provide to Accounts Payable a participant’s legal name, address, Social Security number and the amount paid for participation. Brown uses this information to issue 1099 statements to study participants.

Accounts Payable Office

Reimbursement vs. Compensation

Reimbursement is not compensation for research participation. You may reimburse research participants (or their caregivers) for out-of-pocket expenses they have as a result of study enrollment, such as transportation, childcare, meals and similar expenses. Reimbursement payments are not reportable to the IRS as taxable income. 

Offering reimbursement is not required or expected.

The Brown University’s Controller’s Office is responsible for ensuring the proper stewardship of the University’s financial resources. The HRPP team and IRB rely 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 investigators for human subjects research.

You are strongly encouraged to design your study using one of the compensation methods approved by the Controller’s Office, listed below. If you intend to use a method of compensation that is not approved, you will need to contact Accounts Payable for consultation and approval for its use before including the compensation in your study materials submitted for HRPP/IRB review.

ClinCard

Brown uses ClinCard to manage the reimbursement process for study participants. ClinCard is a participant payment system that makes it easier, faster and more secure to provide compensation to participants and to track payments through an online system. Studies that use the ClinCard as a means to provide monetary compensation to participants must include required language in the consent document and provide participants with IRB-approved FAQs about the system. Study staff may also be required to attend training on the use of the system. 

If study participants wish to cash out their ClinCard balance at a bank teller, as a means to get cash without incurring a fee, it is recommended that they take a copy of the ClinCard Bank Instructions with them.

If you are interested in using the ClinCard in your study, please contact the Controller's Office. Additional guidance can be found on the office’s ClinCard page.

• Approved Language for ClinCard Consent
• ClinCard FAQs for Participants
• ClinCard Bank Instructions (PDF)
• Controller’s Office
• ClinCard Guidance

Cash and Gift Cards/Certificates

Cash payments and gift cards (plastic, paper or electronic) are common ways to compensate participants. Please review Brown’s Gift Card Policy for any requirements that may apply to your study.

Even if you will not collect identifying information about your participants, you should establish a way to track the cash payments and/or gift cards given to participants for reporting purposes to the Controller’s Office. For example, consider keeping a spreadsheet that links a unique identifying number from each gift card to an assigned study ID associated with a given participant.

Gift Card Policy

Unacceptable Compensation Methods

The Controller’s Office may determine that a compensation method does not meet Brown’s requirements for a number of reasons (i.e., it does not offer buyer or seller protection or there are no special authorizations, no offers of controls or reconciliation capability that would be acceptable to Brown or no ease of payments for the user). The determination of which compensation options are available for human subjects research is not a decision that is made by or can be overturned by either the HRPP team or the IRB.

If you would like to request that the Controller’s Office consider a method of compensation that is not already approved by Brown for use in human subjects research, please contact Accounts Payable at accounts_payable@brown.edu or 401-863-2716.

At this time, the following compensation methods are specifically not allowed for human subjects research studies, as determined by the Controller’s Office:

• PayPal mobile payment service
• Venmo mobile payment service

Advertising Compensation

Your advertisement may state that participants will be compensated but should not emphasize the compensation by font (i.e., large or bold type) or design enhancements (i.e., exclamation marks, stars, subject/tag lines in electronic communications).

Prorated Compensation and Bonuses

Compensation for participation in research should not be contingent upon the participant completing the entire study but rather be prorated as the study progresses to insure voluntary participation. However, compensation of a small proportion as an incentive for completion of the study is acceptable providing that such an incentive does not constitute undue influence.

If a bonus is given at the completion of the study it should not be more than half of the total study compensation.

Sponsor Discounts

Compensation for participation in a clinical trial offered by a sponsor may not include a coupon good for a discount on the purchase price of the product once it has been approved for marketing.