Lotteries and “Random Awards” as Incentives for Research Participation

Researchers with limited funds for compensating participants often ask whether they can offer a random drawing for monetary or other awards as incentive for enrolling or continuing in their study.

According to UF’s Office of General Counsel, such random drawings (whether physical or virtual) in research projects constitute a lottery under Florida law, and the state “prohibits any person in the state to conduct any lottery drawing for the distribution of a prize or prizes by lot or chance, or advertise any such lottery scheme or device.” Although certain charitable and nonprofit organizations may conduct lotteries, even they may not “require an entry fee, donation, substantial consideration, payment, proof of purchase, or contribution as a condition of entering the drawing or of being selected to win a prize.” (Florida Statutes 849.0935(4)(b)). Therefore, the Office of General Counsel has determined that a random drawing cannot be used as incentive to enroll research subjects or to continue their participation, which would be a “substantial consideration” for entering the “drawing.”

If you have questions about any other compensation arrangement for subjects, other than direct compensation, please contact the IRB-01/IRB-02 Office at 352-273-9600.