Incentives Review Protocol for NIJ-Funded Research

Use of incentives in NIJ-funded research requires review and approval by the NIJ Director or the Director’s designee. Grantees must submit any proposed use of incentives through the appropriate grant manager; the requests will be reviewed under the protocol outlined below. All communications with respect to this protocol will be managed with and through the appropriate grant manager. These reviews will take into consideration the best available evidence on the cost-benefit and value of incentives in conducting research involving human subjects with the understanding that such evidence is currently limited especially with respect to certain groups such as minors and victims of crime.

1. All payments to study subjects that are determined to be incentives and not stipends must be approved by NIJ leadership through this protocol before being put into practice. Stipends do not require approval of NIJ leadership but must meet the criteria stated below.
   • Stipends are defined as payments to participants in studies who are acting in their professional role (e.g. teachers filling out student assessments, nurses using screening protocols to obtain information for a study).
   • Stipends must be limited to time spent that is outside of the normal working hours of the professional contributing to the study effort as individuals cannot be paid double for working within their normal paid work day.
   • Stipends can also be applied to institutions such as schools to reimburse for costs associated with participation in studies such as space, staff time costs, supplies, etc.
   • Stipends can include reimbursement to study participants for expenses incurred with participation in studies such as travel, lost work time, etc.
   • Incentives are payments to study subjects to encourage them to participate in the study and/or remain in the study when there are multiple points of data collection. These payments would be above and beyond any payments that cover the costs incurred in the participation in the study.
   • Incentives need to be commensurate with the time and effort involved in participation in the study.
   • Evidence must be provided that the use of incentives is justified in order to recruit subjects to the study or to keep subjects involved in a study across multiple points of data collection. This evidence should be study-specific and relate directly to the grantee’s study.
2. A proposal for the use of research incentives should provide answers to the following questions.
   • What is the total amount of the stipend/ incentive?  Also show the breakdown by tasks if multiple payments are involved (e.g., several interviews/surveys over time)?
     What is the age of all participants receiving stipends/incentives (in particular, if students/youths are involved)?
   • Explain in detail what specific form the incentives will take (please note that food, beverages, raffles, entertainment and lotteries are not allowed in any form).
   • Discuss how you will eliminate or minimize the appearance of coercion rather than voluntary participation for study subjects.
   • Provide justification demonstrating that the amount of compensation is reasonable/nominal.
   • What specific evidence leads you to believe that participation is unlikely without incentives?
   • What is the estimated impact if incentives were not used?
   • How will incentives be distributed and tracked?
3. Each proposed use of incentives will be reviewed by the NIJ Principal Deputy in collaboration with the NIJ Human Subjects Protection Officer and relevant NIJ Office Directors. The Office Director will consult with and provide input from the relevant NIJ science staff. OJP Office of the General Counsel (OGC) will be consulted as well on an as needed basis. In all cases the relevant NIJ Office Director and Scientists will be cc’ed on all communications about the incentive/stipend request.
4. Special care will be taken in the review and consideration of incentives involving minors and other particularly vulnerable populations such as victims of crime, individuals in prison, individuals involved in illegal activities such as prostitution or drug use, etc. where the incentive may more likely be perceived as coercive. Use of incentives to recruit students in a school setting whether the study is taking place during school hours or after-hours are generally discouraged unless a particularly strong case can be made that such incentives are essential to the study in question (Note that there is currently little evidence to suggest that incentives are essential to engaging students in the school setting to participate in research studies and there are many studies being done in school settings that are successfully recruiting students without the use of incentives.).
5. Further clarification questions may be posed to the grantee as needed should the responses to the questions above not fully inform the decision process. Such follow-up questions will be communicated to the grantee through the grant manager who will then receive and pass on the responses to the NIJ leadership.
6. Approval for the use of incentives by the NIJ Director or the Director’s designee does not replace the need for IRB review of the study and the IRB’s acknowledgement and approval of the use of incentives.  IRB review and approval of incentives is particularly important where study subjects are drawn from vulnerable populations, or where incentives may be more likely to raise concerns about coercion to participate in the study.
7. The outcome of this review process can result in several possibilities:
   • Rejection of the request.
   • Approval of the request.
   • Approval with requested modifications which need to be addressed prior to final approval.
   • Rejection of the request with the option to resubmit based on certain specific qualifications such as inability to effectively recruit study subjects.
8. Review of the incentive approval will be reinstituted under the following circumstances:
   • Failure to receive IRB approval.
   • Failure to adequately comply with distribution and tracking requirements.
   • Proposed changes in the incentive plan or structure.
   • Evidence of misuse of incentives.
9. The review process for all incentive/stipend requests and all relevant information used in the review will be routinely and carefully documented in an email trail which will become a part of the permanent record of the grant.
10. Once the request for incentives has been accepted, it is the responsibility of the GM to assure that all rules guiding the use of incentives are followed and met including such things as the use of unallowed incentives such as food, proper maintenance of the tracking and monitoring system, appropriate spending reports related to incentives, etc.