On the issue of payment to research subjects, what should be done if people drop out of the study? FDA guidance recommends the following for IRBs:1

• Payment should not be contingent on completing the study and should accrue throughout the course of the study.

• Payment can be made at the end of the study to subjects who withdraw from the study.

• While such bonuses should not be undue inducements, a small proportion of payments can be offered as an incentive for subjects to complete a study.

• The IRB should determine whether a completion bonus is reasonable and not so great as to influence subjects who otherwise would have withdrawn.


1. FDA. Payment and Reimbursement to Research Subjects - Information Sheet. Guidance for Institutional Review Boards and Clinical Investigators. Jan. 25, 2018. Available at: https://bit.ly/2slP3Ao.