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The university recognizes the importance of encouraging individuals to participate in research as human subjects and the value of the time, effort and risk subjects contribute to university research efforts.
Payment may be made, or other consideration provided, to subjects to compensate them for these contributions under the criteria outlined in the HRPP Operations Manual, Part 7, Section III and SPG 501.7, Research Subject Incentives. If U-M researchers wish to conduct a lottery, raffle, or sweepstakes as a form of incentive payment, or as a part of research with human subjects, they must comply with federal policy and State of Michigan Act 382 of 1972.
"If you are charging people or requiring them to donate or provide something of value to participate in a drawing where a prize will be awarded, then you are conducting a raffle" ~ State of Michigan Charitable Gaming Division Raffle Guide
A research lottery or raffle (interchangeable terms) is one in which participants are offered a chance to win a prize or something of value in return for their participation in a research activity, such as a survey or experiment. Per SOM Act 382, Section 432.105d the University of Michigan is a " Qualified Organization" and is excused from obtaining a license under specific criteria, which a U-M IRB will check for upon their review of the proposed study and incentive activity.
IRB Review Criteria
- Total cash value of prizes (cash, gift certificates/cards, merchandise) awarded on any day cannot exceed $100.
- There are no second chance drawings, meaning that individuals cannot be entered into a pool for a prize more than one time. This limit meets SOM "single gathering" criteria.
- There is no pre-sale of raffle/lottery tickets
- The informed consent document must include a description of the lottery/raffle process
A study team has $300 to offer as incentives and plans to hold three drawings for $100 total distribution on three days, awarding four $25 prizes on each day. The team's plan meets IRB criteria if:
- They do not exceed the $100/day limit
- They enter three distinct pools of research participants for each drawing (e.g., Subjects 1-25 on day 1; Subjects 26-50 on day 2; Subjects 51-75 on day 3)
U-M researchers occasionally ask if they can offer a chance for a prize valued at more than $100. This is permissible but the incentive activity must meet the SOM requirements for a sweepstakes or gaming promotions under the Michigan Penal Code Act 328 of 1931.
IRB Review Criteria:
- Subjects are not required to offer something of value (their participation in the research) in order to be entered into the drawing. This means everyone invited to participate in the research is entered into the drawing.
- The informed consent document must disclose:
- The date and location that the drawing will take place
- The odds of winning
- How winners will be notified
Sample consent language
You will be entered into a sweepstakes to be conducted on June 15, 2016, for an iPad valued at $499. The drawing will be conducted by the University of Michigan Department of Psychology in Ann Arbor, MI. The chance of winning a prize is approximately 1 in 300. The winner will be notified immediately by email and provided with information on where to pick up the prize.