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How to Use Incentives: A Guide for ACL CDSME and Falls Prevention Grantees

Incentives such as gift cards, vouchers, giveaways, or prize items can motivate someone to take action when they may not have otherwise. In fact, studies have shown that for projects that involve evaluation and/or research activities, even small incentives—of as little as $2 in value—can increase participation and survey response rates.1

The purpose of this resource is to provide ACL Older Americans Act Title IIID, Chronic Disease Self-Management Program, and Falls Prevention Program grantees (referred to as evidence-based program grantees) with a basic understanding of the most common types of incentives and how to use them effectively within their programs.  

Please note that this guidance is not intended to supersede local and state policies. Although this resource is focused on the use of incentives in evidence-based programs, this information may be useful to other ACL grant programs that currently use or are considering the use of incentives.

General guidance about incentives

As a general rule, incentives that motivate participants and volunteers to engage in grant-supported services, programs, health care, or other services are allowable if they are within the scope of an approved project.

Evidence-based program grantees may use incentives if their use meets the intents and requirements of disease prevention and health promotion services, which include improving health and well-being and reducing disease and injury.

Within the aging network, incentives are a useful tool. When used thoughtfully, they can increase the success of programs, including evidence-based programs.

Evidence-based programs may use incentives to:

  • Promote awareness of programs and services within the community
  • Increase participation in programs and services
  • Show appreciation to volunteers and staff
  • Increase participation in research or evaluation projects that show the value of the programs

All incentive handling requires policies and procedures, which may be very similar to policies that programs should have in place for money handling. Program administrators should seek legal and/or financial counsel when developing incentive-handling policies and procedures.

While there is no specific dollar amount limit for an incentive, the amount must remain allocable and reasonable. Policies and procedures should be developed to ensure adherence to 45 CFR 75 and other applicable laws and regulations. A policy related to the maximum amount of an incentive should be included in the policies and procedures developed.

Types of incentives

There are many types of incentives, all with their own strengths and limitations. The following sections describe the three most common types of incentives.

Note: Cash cannot be used as an incentive.

TypeGift cards and gift certificates
Definition

A card, electronic, or paper certificate with a set cash value that can be exchanged for goods or services from a specific business. Examples include a $5 gift card for a chain grocery store or a $10 gift certificate for a local yoga studio.

GuidanceGift card incentives are not and should not be portrayed as an endorsement by HHS or ACL of any company (or its goods, services, or policies) associated or affiliated with the incentive. For example, if an incentive is funded by grant funds, a general purpose pre-paid gift card (e.g., one issued by a credit card network brand) would more clearly separate the incentive from appearing to be an endorsement versus a card to be used only at a specific store or with a specific company. To the extent practicable given the proposed incentive, such non-endorsement should be clearly articulated.
Recommended Policies and Procedures
  • Determine quantity and frequency of gift card distribution
  • Identify and assess individuals who will receive gift cards
  • Track and document gift card use 
  • Ensure equitable distribution (e.g., avoid means testing, open to all eligible applicants, avoid favoritism)

 

TypeVouchers
DefinitionA payment mechanism (card, paper, or electronic notice) for a service. A voucher is a document that shows a service has been bought or rendered, and authorizes payment (discounted, free, and/or at no additional charge). Examples include a coupon for a 10% discount on any item purchased at a local farmers market or a meal voucher for a free meal at a participating restaurant.
GuidanceVoucher or voucher-like programs have been used by evidence-based program providers. For example, some programs have participated in distribution of the USDA Senior Farmers’ Market Nutrition Program vouchers, which allow low-income older adults to purchase fresh fruits, vegetables, and other items at their local farmers markets.
Recommended Policies and Procedures
  • Determine quantity and frequency of vouchers
  • Identify and assess individuals who will receive vouchers
  • Track and document vouchers
  • Ensure equitable distribution (e.g., avoid means testing, open to all eligible applicants, avoid favoritism)

 

TypeGift items, giveaways, and prizes
Definition

A tangible item (sometimes also called a “tchotchke” or “swag”) that is given for free in order to motivate or encourage an individual to do something. Sometimes the item is given prior to the desired action being taken, such as a community event where free pens are offered to visitors regardless of whether they sign up for an evidence-based program. Other times the item is given afterwards, such as providing a t-shirt to participants who complete all sessions of an evidence-based physical fitness program. Examples include keychains, stress balls, water bottles, or other small items.

In some cases, the incentives are given to all participants (e.g., offering giveaways at an Expo event), and in other cases incentives may be done via a raffle or drawing.

Note: Raffles/drawings may not be allowable in some jurisdictions.

Guidance

Gift items, giveaways, and prizes may be used in limited circumstances to meet programmatic goals. For example, when offering Bingocize®, the program requires the awarding of small prizes as a part of the evidence-based curriculum. Similarly, some programs may provide giveaways, such as small weights to help participants participate in program exercises, as well as enable them to continue the exercises beyond the end of the program.

Note: There are clear and long-standing policies prohibiting using federal funds to procure food for meetings or trainings. This aligns with HHS policies: HHS Policy on the Use of Appropriated Funds for Food.

Key implementation questions about incentives

OAA Title IIID and PPHF discretionary grantees who are considering the use of incentives, regardless of type, should take time to review and consider the following questions before implementing an incentive program.

QuestionAction
What do you want to accomplish by using incentives?Determine how incentives will help you meet your program’s goals, objectives and/or intents.
What type of incentive will you use?
  • Find out what your participants are most likely to be motivated by. If you don’t know, ask them.
  • Consider the cost of each incentive, including the cost of purchasing, distributing, and tracking.
How will you evaluate the use of incentives by your program?Establish metrics up front that will help you understand if your incentives are making a difference (e.g., improving participation, increased recognition of your programs and services).
How does the use of incentives meet the requirements of your grant or other funding sources?
  • Ensure that all costs of your incentive program meet Federal Cost Principles when purchased with grant funds (i.e., costs are reasonable, allowable, and allocable). A policy on the maximum cost of an incentive should be included in your program’s policies and procedures.
  • Remember you must adhere to all Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards found at 45 CFR 75 and other applicable federal laws and regulations.
  • It is important to note that state and local policies, procedures, and requirements may be more restrictive than federal laws, regulations, and policies, and these state and local restrictions must be adhered to. 
Will the use of incentives by your program be sustainable?
  • Remember: grant expenditures should be developed with sustainability in mind, so make sure to plan for this wherever possible.
  • Consider partnering with businesses, explore the use of state or local funding, and look for other creative means to purchase incentives outside of evidence-based program grant funds.

 

This resource was modeled after the National Resource Center on Nutrition and Aging's Use of Incentives for Older Americans Act Grantees

This project was supported, in part by grant number 90CSSG0048  and 90FPSG0051 from the U.S. Administration for Community Living, Department of Health and Human Services, Washington, D.C. 20201. Grantees undertaking projects under government sponsorship are encouraged to express freely their findings and conclusions. Points of view or opinions do not, therefore, necessarily represent official Administration for Community Living policy.

Sources

1. Michael G. Smith, et al. Effectiveness of incentives and follow-up on increasing survey response rates and participation in field studies. BMC Medical Research Methodology. December 2019. Found on the internet at  https://bmcmedresmethodol.biomedcentral.com/articles/10.1186/s12874-019-0868-8

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