Our blog series continues following the webinar co-hosted by Mural Health and WCG called “Demystifying Participant Payment Myths,” where we provided insights, shared advice, and answered user-submitted questions about clinical trial payments. This topic brings with it a fair amount of complexity, which has been reflected in the volume of questions we’ve received since the webinar. This four-part series has attempted to provide answers and clarity. So far, we’ve covered:

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Part I: The Ethics of Clinical Trial Payments (and Non-Payments) which highlights the best practices for navigating fair and transparent management of payments while avoiding both undue influence and exploitation. 

Part II: A Deep Dive Into Clinical Trial Payment Types, Methods, and Amounts sheds light on details like what expenses to cover, how much to pay participants, and what payment methods to offer.

Part III: The Tax Implications of Clinical Trial Payments addresses which methods are taxed, how can you minimize tax exposure, and why this matters for recruitment and retention. 

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In Part IV, we’re diving even further into a topic we began to tackle in Part II: payment methods. But this time, we’re answering the questions that may help you better understand the impact of certain methods and why you should weigh participant preferences.

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Clinical Trial Participant Payment Methods — Considerations & Key Principles

When your participants make the decision to engage in your clinical trial, they’re accepting a certain level of risk. The cost to them may be physical, it may be emotional. Your job as the clinical research organizer is to mitigate any financial cost, at the very least. We’ve stressed the importance of making participants “financially whole” which can be done with full reimbursement and fair pay. Fair pay means carefully considering the payment method (or methods) offered to your participants. 

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When selecting a trial payment method, it’s important to prioritize these three considerations: 

1. Optionality: Offer different methods to accommodate preferences and regional limitations 
2. Timeliness: Ensure your participants are paid as quickly as possible — don’t lag
3. No fees: Don’t use methods that impose fees on your participants 

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Payment methods like prepaid cards may enable timely payment, but often come with excessive or undisclosed fees that chip away at the amount participants can actually access, which calls into question their fairness. They are also likely to cause user error, which creates a negative participant experience and an increase in support calls for sites. Thoughtfully consider all of your options — and not just their administrative impact on your site, but their impact on your participants.  

To offer further guidance on fair and transparent compensation, we’ve developed a payment model that balances ethical considerations, financial realities, and regulatory compliance.

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A Deeper Dive — Q&A

How do most entities pay clinical trial participants? Is there a “best” way?

The payment options offered by clinical trial institutions vary significantly. Some only offer checks, some offer a wide range of payment options — usually through a payments vendor or participant management solution. Options may include: 

• Prepaid debit cards
• Direct bank deposits
• Checks
• Digital payments (e.g., Venmo, Paypal, Zelle, Revolut)
• Direct payments (through a trial management platform) 
• Gift cards (for specific retailers or general use)

As it relates to the optimal offering, the best payment type will depend on what’s best for both your institution and your participants. We believe transparency of fees and payment time, as well as optionality, are key.

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This means research institutions should:

• Understand what’s important to your organization. For example, many sponsors have clear goals for sustainability. Pre-ordering and storing physical prepaid cards or gift cards might hinder the ability to deliver against these goals. There are other ways to achieve these goals (such as virtual cards, or the issuance of a card to the participant directly), which you can explore once your goals are clearly defined.  

• Be knowledgeable about the terms and conditions of all payment methods. For example, many research institutions are unaware of the fees associated with the prepaid cards they use, which take funds from participants’ pockets. We encourage institutions to request to see the card terms and conditions — if there are fees in them, that means your participants are paying those fees.  

• Offer several payment options that are appropriate for the study type and participant population. For example, a research institution looking to recruit in a low socioeconomic area cannot offer only checks, which typically take weeks to get to participants.  

• Clearly present this information to participants by sharing a list of payment options, the required participant information to receive each, and the time it will take to receive their funds.  

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One option that can help you achieve your goals easily is to partner with a participant management platform that offers a variety of payment options your participants can choose from, including direct payments, which ensure timely compensation without fees.

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What key factors should be considered if choosing between reloadable debit cards and gift cards for participant payments?

Always be thoughtful about the payment methods offered within your clinical study. Provide options that are flexible and convenient to your participants. Both reloadable debit cards and gift cards may appear to be administratively convenient options for sites, but they can also put participants at a disadvantage compared to other options like direct payments. 

For example, if your study requires multiple site visits and you choose to pay participants at each of their visits, a reloadable debit card may seem like the more efficient option for recurring payments. But remember, while reloadable debit cards may be convenient to the payor, their fees become an inconvenience to participants.

For participants who cannot or choose not to supply personally identifiable information needed to issue some debit cards, gift cards may be perceived as the better option. The biggest drawback with gift cards is that they’re often tied to a specific retailer which limits participant flexibility. They can also involve other administrative challenges, such as a limited ability to detect fraud. 

Again, it’s important to offer clinical participants optionality so they can select the payment type that best suits their needs.

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If paying participants with gift cards, is there a recommended amount to give?

If gift cards are being issued to cover reimbursement or other compensation, they should be tailored to cover all expenses incurred by participants and provide complete payment for the time and effort required of them. The necessary amounts will vary widely from study to study, so a fixed amount can’t be recommended. What’s most important is to prioritize making every participant “financially whole.” That means taking the steps to ensure they’re fairly and fully compensated for their engagement in your clinical trials. 

Avoid labeling any payment (including gift cards) as a stipend, as this is considered taxable income that participants must report. For gift cards, that requires following the process to substantiate each expense after the payment is made. These additional steps may create extra burden for sites, in which case, offering more modern options like digital payments (e.g., Venmo, Zelle) or direct payments through a participant management platform becomes a more efficient and participant-centric approach. 

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Are there fees imposed on participants who receive prepaid debit cards as payment?

Many times, yes. Fees come in different forms, typically tied to these actions: 

• Monthly maintenance: these are recurring charges imposed on participants for just holding and using the prepaid card, and can reach up to around $10 per month 
• Inactivity: these typically range from $2–$5 per month and are charged after a specified period of inactivity (often three to twelve months) — if a participant does not use the card for an extended period, fees will accumulate until the card’s balance reaches $0
• ATM withdrawals: these are deducted from the balance of the card each time they’re used for cash withdrawals, and generally range from $1–$3 
• Balance inquiries: if a participant needs to check on the remaining balance of their card, there may be a fee for that, too (typically $0.50) 

While program managers who offer cards with these fees may claim they are unavoidable and bank-imposed, that’s misleading. These fees are imposed by card administrators (also known as program managers) to generate business revenue, which is unfortunately done at the expense of participants receiving the card payments. Inactivity fees in particular can drain a card with monthly charges that reduce the balance if not used in a specified timeframe, until there’s nothing left. Every fee charged diminishes the amount participants can actually use, which raises fairness and ethics concerns. But this is absolutely avoidable. Mural Health’s prepaid card has no associated fees for participants — none of the fees mentioned above exist for this card. 

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Is it necessary to disclose the method of payment to participants in the informed consent form (ICF)?

Absolutely. While there is no specific regulatory requirement to disclose the method, there is certainly an ethical one. Regulations and ethics guidelines do require that participants  be made aware of any costs they will incur, reimbursements they will receive (if applicable), and how disbursements will be managed. Not only should payment methods be disclosed to participants, but also any associated fees and the expected time to receive the payment. This gives participants the information they need to make decisions about their engagement and how they choose to receive their payments (assuming optionality is provided).

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Can you pay a participant more than the amount stated in the ICF?

Yes. If your institution feels that a participant should be paid beyond the amount or terms stated in the ICF, you are certainly encouraged to ensure they’re fairly compensated and made “financially whole.” Before implementing the change, you do need to notify the IRB of the deviation to your payment plan and have it approved.

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Are there IRB concerns if an organization chooses to use a third party to issue payments to participants?

No — using a third party to issue participant compensation is actually common practice and can help sites manage the administrative burden of providing reimbursement and payments. A participant management platform like Mural Health can offer a wide variety of payment options that span continents, delivering convenience to both participants and payors. If your trial does engage a third party, it should be disclosed in the ICF.

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Final Thoughts

Participant compensation is a complex aspect of clinical research, but it’s an essential one to get right. The bottom line is this: treat your participants fairly. Take the steps you can to provide optionality, convenience, and flexibility. Be informed. And be transparent. Whatever payment methods may be offered as part of your research program, tell your participants upfront so they know what to expect and how to make their best decisions. Do this and you can help optimize the engagement with your study and the outcomes of your research.   

For now, this blog is the last in the series, but the conversation doesn’t end here. Please send us your thoughts and any questions about clinical trial participant compensation here.