Should Student Participants be Penalized for Failing to Show Up for an Experiment?

By Sangeeta Panicker, PhD

According to the federal Office for Human Research Protections (OHRP), the answer is an unqualified No. OHRP announced in January that penalizing students who sign up for a research study as part of a course requirement and then fail to show up for the appointment without cancelling in advance is in violation of regulations for the protection of human research participants. OHRP, a unit of the U.S. Department of Health and Human Services (HHS), oversees participant protections in all HHS-supported research, and many U.S. institutions apply its policies broadly to all human research no matter what the source of funding. The announcement and background information have been posted on the OHRP website.

The question of whether students who fail to show up can be penalized had not previously been addressed by OHRP. The impetus for the announcement was an inquiry made by an individual regarding a feature of a widely used web-based subject pool management system produced by Sona Systems. This feature automatically assessed penalty credits if a student who had signed up for a study failed to keep an appointment. OHRP consulted with Sona Systems before releasing its announcement.

The announcement has received mixed reactions from researchers. Many investigators and departments had not previously imposed penalties and so do not have to change their procedures. However, some others who have been imposing penalties are now concerned about their ability to conduct research efficiently using students who receive course credit for participation. Missed appointments mean wasted time, effort, and resources. Some have also expressed the view that penalties help instill in students a sense of responsibility and respect for the scientific enterprise.

OHRP has long emphasized that consent to participate in research must be voluntary and devoid of any undue influence. Regarding penalties, it now states:

Under the provisions of 45 CFR 46.116(a)(8), students must be free to choose not to participate in research that they have signed up for at anytime prior to the start of their involvement in the research. Furthermore, students must be free to communicate their decisions not to participate in research in whatever way they choose, including by simply not showing up for the research.

The OHRP statement still allows for research participation to be used as a means for fulfilling a course requirement, but it does not permit penalties to be imposed on students for not showing up that go beyond their not receiving credit for participation. The statement also repeats previous OHRP policies that students should be given options for alternative non-research activities. Underlying OHRP’s approach is the view that students should not be under any stronger constraints to participate in research than non-students.

The APA Research Ethics Office is currently working to assess the basis and impact of OHRP’s announcement. It is expected that the newly established APA Committee on Human Research will also consider the policy. Issues under consideration include:

  • How frequently do students fail to show up without giving advance notice?
  • How frequently do students who do show up not complete the session or not follow instructions, resulting in unusable data?
  • Do no-shows have a greater effect on the conduct of certain forms of research than others?
  • What is the effectiveness of penalties in preventing no-shows?
  • What alternative methods can be used to increase students’ showing up (e.g., reminders, rewards)?

Researchers are encouraged to share their views on these and other questions related to human research participant protections with APA by email.

Comments on the announcement can also be submitted to OHRP. Send email to, with “January 8, 2010 letter regarding student subject pools” in the subject line. Comments to OHRP may also be copied to APA.