From Scott Goodman, Campus Signatory Official for the Institutional Review Board for the Protection of Human Subjects, and Jill Norvilitis, Chair of the Institutional Review Board for the Protection of Human Subjects
The Institutional Review Board (IRB) continues to recommend that in-person human subjects research be avoided if at all possible and that alternate means of data collection be used; however, if researchers must conduct in-person studies, they are expected to follow campus COVID-19 or other health guidelines.
If a researcher intends to host participants on campus, they must review and strictly adhere to the recommendations made here.
It is college policy to ensure that the rights and welfare of human subjects are adequately protected in research conducted under its auspices. In addition, federal and state laws and regulations require these protections. In order for the college to fulfill its responsibility and to comply with the law and regulations, all human subjects research conducted under college auspices must receive appropriate review and approval.
Before the review process, researchers must be sure that their project is, in fact, human subjects research as defined by the federal government. In order to qualify as human subjects research, the following must be true:
The participants must be living. Use of records is still considered research with human participants, although oral history and journalism are specifically excluded.
The project is a systematic investigation; that is, it is designed to be a study. For example, instances in classrooms where teachers ask students' opinions on the material to gauge progress are not research; however, if that same teacher designs a study to evaluate two different methods of teaching the material to see which is more effective, this would be research if the third criterion is met.
The project is designed to contribute to the generalized knowledge. To qualify as research, the person conducting the project must intend it to be for dissemination at some level. On our campus, we also review student projects that may not be disseminated but that meet the first two criteria so that our students will learn the process of human subjects research and because we have contracted with the federal government to do so.
Following the regulations and guidance of the federal Office of Human Research Protections, certain public health surveillance activities are deemed to not be research and not require the IRB review process. However, according to the Secretary’s Advisory Committee on Human Research Protections (SACHRP), such work still requires outside review to determine that it is, in fact, Public Health Surveillance. Therefore, anyone planning to conduct public health surveillance activities should complete the Public Health Surveillance Activities Form and upload it and any relevant supporting documents to SUNY PACS IRB.
Certain student research projects do not have to be submitted for Institutional Review Board approval but should be reviewed at the department level. Projects that may be reviewed at the department level include laboratory projects, educational exercises and class projects, and action research within a classroom with performance or grades as the sole outcome measure. Each department is to designate one representative to the IRB to serve as the reviewer for department level protocols. In order to qualify for department level review, the research must be disseminated only within the BSC campus; for example, research presented at the Student Research and Creativity Celebration or theses bound and filed in the library may be reviewed departmentally, but any research that will be presented at regional or national conferences or published in journals should be reviewed at Level 2, 3, or 4. All faculty research, all research that may be risky or on a sensitive topic, or that includes children, except as noted for action research, must be reviewed at Level 2, 3, or 4.
If your protocol falls under this level of review, contact your department's IRB representative.
The federal government uses the term "Exempt" to indicate that a protocol is exempt from the higher levels of review because of its low risk for harm. This does not mean that the project is exempt from oversight. Exempt projects simply require less paperwork. Projects that qualify for Exempt or Limited Review include, but are not limited to:
Action research in the classroom with syllabus-related outcomes, including syllabus-related attitude questions. This does not include the administration of personality measures; that is, "What was your opinion of the unit on World War II?" is acceptable, but a survey on introversion/extraversion would require expedited review.
Surveys on innocuous topics completed by adults.
Anonymous surveys (even on more controversial topics) completed by adults.
Research using existing data or documents if the sources are publicly available or the individual source of the data cannot be identified.
Research on individual or group behavior of normal adults where there is no psychological intervention, physiological intervention or deception.
Interviews and interactive surveys on non-sensitive topics.
Benign behavioral interventions (subject to limited IRB review)
Some identifiable and sensitive research (subject to limited IRB review)
Projects that are more intrusive than exempt projects or that require the participation of children (aside from action research as noted in Levels 1 and 2), may qualify for Expedited Review. In this case, the protocol is similar to that of the Full-Board Review, but the project is reviewed by one designated member of the IRB. The designee may approve the project, request additional information, or submit the proposal to the IRB for Full-Board Review and approval. Some examples of Expedited Review projects include, but are not limited to:
Educational research that involves separating the child for individualized field testing.
Continuations and/or modifications of proposals initially approved under the Full-Board Review process, if they present no additional risks to participants.
Interviews or surveys on sensitive topics where the subject can be identified.
Full-Board Review is the highest level of review for human subjects protocols and is designed for projects that are sensitive in nature. The review is conducted at the next scheduled meeting of the IRB. Some examples of Full-Board Review projects include, but are not limited to:
Research that might put participants at risk, such as research on domestic violence or illegal drug use.
Research involving psychological or physiological intervention.
Non-curricular, interactive research in schools.
Research involving deception.
Unapproved protocols at the Expedited level.
All faculty members conducting human subjects research or supervising student research need to complete ethics training, as specified by the federal regulations. All students conducting human subjects research also need to complete this training. Although researchers may complete other federally-approved training programs to satisfy this requirement, we encourage researchers to complete the CITI program, for which the campus has a site license. To access this training, visit the CITI website https://www.citiprogram.org/.
When payments to subjects are involved, the IRB is responsible for determining the appropriateness and timing of payments consistent with protection of subject confidentially. Payments to human research subjects are considered "other" income and, as such, are subject to Internal Revenue Service (IRS) requirements for reporting.
Researchers who are not faculty members, staff members, or students at Buffalo State must request approval from the Buffalo State IRB by submitting the Application for Human Subjects Approval for Off-Campus Researchers and a copy of the approved protocol from your home institution.
Guidelines for Faculty Research Mentors
Federal Regulations Revised by the Office of Human Research Protections
An Investigator's Guide to Research with Human Participants
Investigator's Checklist for Human Participants Compliance
Miscellaneous Categories of Research
Policy Manual for Research Activities Involving Human Participants
Policy for Research Involving Minors
Review Board Members -2021-2022
Socially Sensitive Research
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