Payments for Referring or Enrolling Subjects in Clinical Research

Date: July 1, 2025
Number: 2.200
Status: Final

Contact Office:
Assistant Dean for Research
School of Medicine, Dean’s Office
PO Box 800712
Charlottesville, VA 22908
Phone: 434-243-0323

Oversight Executive:
Senior Associate Dean for Research
School of Medicine, Dean’s Office
PO Box 800419
Charlottesville, VA 22980
Phone: 434-243-7088

Applies to:
Any University of Virginia School of Medicine employee, student, volunteer, or other individual who has an affiliation with the institution.

Reason for Policy:
The University of Virginia School of Medicine is committed to upholding its reputation and the public’s trust in the integrity of its health care services and research programs. To protect participants in clinical studies, the school seeks to prevent financial conflicts of interest among investigators. Specifically, the policy addresses concerns that incentives for referrals or enrollments could lead investigators or administrators to not adhere to enrollment criteria, misrepresent information to potential participants, or unduly influence individuals to participate.

Definition of Terms:
Clinical study – includes any study involving human subjects, regardless of where that study is being conducted.

Covered Person- A University of Virginia School of Medicine employee, student, volunteer or other individual with an affiliation with the institution.

Policy Statement:
No covered person may offer or accept incentives for referring or enrolling subjects in any clinical study. Prohibited incentives include, but are not limited to, gift certificates, books, conference attendance, travel expense payments, finder’s fees paid to or by investigators, or bonus payments tied to subject accrual for investigators or study staff. Such incentives may not be provided directly to covered persons or through grants or contracts supporting clinical studies.

Related Policy:
Research Misconduct RES:004 Research Misconduct

References

• American College of Physicians. (2019). Ethics Manual: Seventh Edition. Annals of Internal Medicine, 170 (2_Supplement), S1–S32. https://doi.org/10.7326/M18-2160
• American Medical Association. Fee splitting: Referrals to clinical research. In Code of Medical Ethics. https://code-medical-ethics.ama-assn.org/ethics-opinions/fee-splitting
• Institute of Medicine. (2004). The Future of Drug Safety: Promoting and Protecting the Health of the Public. National Academies Press. https://doi.org/10.17226/11750
• Food and Drug Administration. (2007). The Future of Drug Safety: Promoting and Protecting the Health of the Public. https://www.fda.gov/files/drugs/published/The-Future-of-Drug-Safety—Promoting-and-Protecting-the-Health-of-the-Public.pdf

Next Scheduled Review:

Revision history: Implemented 9/1/2001; revised 10/8/10; 7/1/25 revised

Approved:
Melina Kibbe
Dean