An institutional review board (IRB) is a committee that reviews research involving people before it starts, to protect the rights and welfare of the participants. It can approve a study, require changes before it approves it, or turn it down.
Before anyone moves into a new building, an inspector reads the plans. The inspector isn’t judging the architecture. They’re asking whether the people who will live there will be safe. An IRB does the same job for research: it reads the plan before the first participant is recruited, and it can send the plan back.
You may be here because a grant form, a journal or a university asked for “IRB approval” and nobody explained it. Or because you run studies at a company, want to thank participants with a gift card, and someone asked whether your IRB has signed off. This guide covers what an IRB is, who sits on one, what it reviews and how it treats the incentive you send. It isn’t legal advice, so your own IRB office has the final word.
It protects the people who take part in research. FDA regulations define an IRB as “any board, committee, or other group formally designated by an institution to review, to approve the initiation of, and to conduct periodic review of, biomedical research involving human subjects”, and say the primary purpose of that review is “to assure the protection of the rights and welfare of the human subjects.”
Two sets of U.S. federal rules shape how IRBs work: FDA’s rules in 21 CFR Part 56, and the HHS policy in 45 CFR Part 46, known as the Common Rule. Under the Common Rule, an IRB has the authority to approve, require modifications in (to secure approval), or disapprove research. It has to tell the investigator in writing, and a disapproval has to come with reasons and a chance to respond.
A mix of people, on purpose. The Common Rule sets minimum membership in 45 CFR 46.107:
| Requirement | What the rule says |
|---|---|
| Size and mix | At least five members, with varying backgrounds to promote complete and adequate review of the research the institution commonly conducts |
| Scientific and nonscientific | At least one member whose primary concerns are in scientific areas and at least one whose primary concerns are in nonscientific areas |
| An outsider | At least one member who is not otherwise affiliated with the institution and is not part of the immediate family of someone who is |
| Conflicts of interest | No member takes part in the review of a project in which they have a conflicting interest, except to provide information the IRB requests |
The point of that mix is easy to see. A scientist can judge whether the design holds up, a nonscientist can ask whether a participant would understand the consent form, and an outside member has no stake in how the institution looks.
To approve research under the Common Rule, the IRB has to find that all of these requirements are met:
That last item is where incentives enter the picture, because a payment can push on someone’s decision to take part.
Not every survey does. The Common Rule defines research as a systematic investigation “designed to develop or contribute to generalizable knowledge”.
Say your support team sends a quarterly satisfaction survey to improve its own service. That’s an internal quality check, not an attempt to produce generalizable knowledge, so it likely falls outside the definition. Now say a university lab surveys 300 of those customers to publish a paper on loyalty. That’s research, and the IRB conversation starts.
Some survey research can be exempt, for example when the information is recorded so that participants’ identities can’t readily be ascertained. But exempt isn’t the same as unreviewed: some exemptions still require limited IRB review. Whether your project counts, and whether it’s exempt, is a call to make with your IRB office before you recruit anyone.
It reviews them like any other part of the study. FDA’s information sheet on payment to research subjects (January 2018) says payment for participation should be “just and fair.” It’s written for FDA-regulated research, so check what your own IRB asks for. Here’s what it says and what it means for your plan:
| What the guidance says | What it means for you |
|---|---|
| Payment is “a recruitment incentive,” not a benefit to weigh against risk | Don’t describe the gift card as a benefit of taking part |
| The amount and schedule of all payments go to the IRB at initial review | Put the payment plan in your first submission |
| The IRB reviews the amount and the method and timing of disbursement for coercion or undue influence | Be ready to explain why this amount, sent this way, doesn’t pressure anyone |
| Credit for payment accrues as the study progresses and isn’t contingent on finishing the entire study | Pay per session or task instead of holding everything until the end |
| A completion bonus must be reasonable and not so large that people stay in when they’d otherwise have withdrawn | Keep any bonus modest and justify it |
| All payment information, including amount and schedule, goes in the consent document | Write the amount, timing and how participants claim it into the consent form |
Let’s run the numbers for one hypothetical study. Say Priya, a UX researcher, runs a four-week diary study with 40 participants, paying $10 per weekly entry plus a $10 bonus for finishing all four weeks. A participant who completes everything earns $50, the bonus is 20% of that, and the budget is $2,000 if all 40 finish. Is 20% reasonable? That’s the IRB’s call, and the study team is better off bringing the arithmetic to the review than having it asked for.
They fit well when your protocol spells out how rewards are delivered, what amount is sent, what fees apply and how long participants have to claim. We’re not an IRB, and we can’t tell you what yours will accept, but here are the details to write down:
The fee is the one that surprises people, because it works against the amount in your consent form. Here’s what it takes from a few hypothetical rewards when the participant chooses a Payout Option and the recipient covers the fee:
On a $5 reward, the $1 minimum takes 20%. On $10 it takes 10%, and at $20 the 6% rate applies instead, which is $1.20. If your consent form promises $10, tell participants that choosing cash can cost them $1, or cover the fee yourself, or offer gift cards only. Our post on paying research participants digitally covers the logistics, and the survey incentives guide covers what to offer.
Back to the inspector. Nobody resents one who reads the plans before the walls go up. The trouble starts when the inspector shows up after the building is finished.
So send your IRB the study plan and the payment plan together, before you recruit. Start with one question: does your IRB have its own guidance on participant payment? Then write down four things: the amount, the schedule, how participants receive the reward and how long they have to claim it. That’s most of what a reviewer will ask about.
It’s a committee that reads a research plan before the study starts and decides whether the people taking part are adequately protected. Under the Common Rule it can approve a study, require changes or disapprove it.
At least five, with varying backgrounds. Under the Common Rule, at least one member must work mainly in scientific areas, at least one mainly in nonscientific areas, and at least one must have no affiliation with the institution and no immediate family who do.
Not always, but you shouldn’t decide that alone. The Common Rule applies to research, meaning a systematic investigation designed to develop or contribute to generalizable knowledge, and some survey research is exempt under certain conditions. Some exemptions still involve limited IRB review, so ask your IRB office before you recruit.
Yes. Under the Common Rule an IRB can approve a study, require modifications to secure approval, or disapprove it. A disapproval comes with written reasons, and the investigator gets an opportunity to respond in person or in writing.
It depends on the rules your study falls under. FDA guidance says the amount and schedule of all payments should be presented to the IRB at initial review, and that the IRB should review the amount and the method and timing of disbursement for coercion or undue influence. That guidance covers FDA-regulated research, so follow your own IRB’s instructions for other studies, and include your payment plan in your first submission either way.
Yes, survey and research incentives are one of the ways businesses use Giftronaut. You can send a Choice Card, where each participant picks a reward in their own country from 4,300+ brands across 225 countries, or a branded card. Whether your IRB accepts gift cards as payment is its decision, so put the delivery method, amount and claim deadline in your submission.
Yes, with reward links. Once your account rep or support enables the Download Reward Links feature, you can order links that don’t require recipient details at order time and send them through your own channels. Each link is one reward, and the first person to redeem it uses it up.