Heterogeneity in IRB Policies with Regard to Disclosures About Payment for Participation in Recruitment Materials

Abstract

Scholars have documented variation in the way local Institutional Review Boards differently adjudicate identical research proposals. It is unclear whether such heterogeneity is due to variation in positive policies, or variation in human processes of interpretation and enforcement. A particularly interesting question relates to whether investigators are allowed to provide truthful information about research opportunities to potential participants, which some IRBs seem to forbid. We investigated local IRB policies on disclosing the amount of compensation in recruitment materials by conducting a census of the top 100 institutions by receipt of NIH funding in 2012. We downloaded the relevant policies and redundantly coded them as to whether they require, encourage, permit, discourage, or prohibit such truthful information at the recruitment stage. We found wide heterogeneity – with significant numbers of institutions proscribing exactly what others require – and conclude by recommending a uniform national policy permitting such disclosures.

Keywords: human subjects, recruitment, informed consent, disclosure, Common Rule, paternalism