Definitions

A finder’s fee is a payment from the sponsor (or investigator) made to research personnel in exchange for referrals of a research participant.

Bonus payments are payments designed to accelerate recruitment that are tied to the rate or timing of enrollment.

Guidance

The American Medical Association[1] Council on Ethical and Judicial Affairs states it is unethical for physicians to accept payment solely for referring patients to research studies. The University of Utah Institutional Review Board (IRB) does not allow the use of finder’s fees or bonus payments made specifically to physicians, including investigators and study staff who are conducting the research. Exceptions must be reviewed by the IRB in order to determine that the use of such methods does not create coercion or undue influence.

It is acceptable to receive 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 to the study, and to document how that amount was determined.  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. Physicians and research 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).

This policy is not intended to prohibit renegotiation of contract fees when recruitment is progressing much more slowly than anticipated such that additional time and effort are required for recruitment activities than initially anticipated.

Footnotes

[1] American Medical Association Code of Medical Ethics, Council on Ethical and Judicial Affairs, Opinion 6.03