Lotteries and “Random Awards” as Incentives for Research Participation
Researchers with limited funds for compensating participants often ask whether they can offer a random drawing for monetary or other awards as incentive for enrolling or continuing in their study.
Such random drawings (whether physical or virtual) in research projects, according to UF’s General Counsel, constitutes a lottery under Florida law, and the state “prohibits any person in the state to conduct any lottery drawing for the distribution of a prize or prizes by lot or chance, or advertise any such lottery scheme or device.” Although certain charitable and nonprofit organizations may conduct lotteries, even they may not “require an entry fee, donation, substantial consideration, payment, proof of purchase, or contribution as a condition of entering the drawing or of being selected to win a prize.” (Florida Statutes 849.0935(4)(b)).
So the General Counsel’s Office has determined that a random drawing cannot be used as incentive for enrolling or continuing to participate in research, which would be a “substantial consideration” for entering the “drawing.”
However, there are several other ways that a researcher could offer an award to only a subset of participants without it involving a “random drawing of lots.” The following are all legitimate and may be used by researchers:
- Providing awards to the first N (number of) participants to enroll (say, by tracking completions of online surveys).
- One variation of this that would be helpful for studies with more extended periods of recruitment is to offer awards to the first and last N participants.
- Another variation is to offer awards to the first N participants during defined periods, beginning say each day or each week.
- Providing awards to every Nth participant; e.g., the 20th, 40th, and 60th could receive the award.
- Making the awards based on some aspect of performance during participation, either integrated as part of the study, or as an add-on task where some score could be obtained, and awards made at the end of the study to the highest N performers.
In each of these cases, the awards mechanisms should be described in the consent script.
Alternatively, one could announce a random drawing at the end of the study for thanking participants, since there’s no “consideration” you’re asking for that would enter them into the drawing. In this case, no mention of the drawing should be made in the consent or during participation.
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