Education Research Guidance

Guidance on Research in Educational Setting

1. Is Education Research Eligible for Exempt Review?
2. Research in K-12 Setting
3. Research in Higher Education Setting

Research in educational settings is an important area of study as it has the potential to improve learning for students and advance pedagogical knowledge.  Federal Regulations pertaining to research in educational settings and research with children, outline specific guidelines and policies that must be in place in order to protect participants.  What follow below are 1) Information to determine whether a study is exempt, 2) Requirements and guidelines for conducting research in a K-12 setting, and 3) Guidelines for conducting research in a university classroom.

1. Is Education Research eligible for Exempt Review?

Federal regulations allow specific categories of human subjects research to be exempt from continuing IRB review (45 CFR 46.101(b)). Category 1 applies to research conducted in schools and other education settings:

Category 1: Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as:

i. research on regular and special education instructional strategies, or

ii. research on the effectiveness of or the comparison among instructional techniques, , or classroom management methods.

Please note that survey research involving children is not exempt, nor is observation of a minor’s public behavior unless the investigator does not participate in the activities being observed.

Research exempted as normal educational practice is often conducted in public school settings which may demand that specific steps be followed in order to comply with additional state and federal laws. Although the definition in the regulations is fairly straightforward, it can create a conflict with other regulations that the IRB is obligated to follow, such as Subpart D of 45 CFR 46, FERPA(Family Educational Rights and Privacy Act), and PPRA(Protection of Pupil Rights Amendment). Subpart D specifically deals with children as a vulnerable population and most protocols that qualify for normal educational practice deal with children. If the IRB determines that a research study does not qualify for exempt status, then the extra protections for minors under Subpart D apply. Additionally, FERPA restricts researchers’ access to student records without written permission from parents. However, within FERPA [20 U.S.C. 1232g(b)(1)(F)], there are conditions under which student records can be disclosed without parental consent: “Organizations conducting certain studies for or on behalf of the school”. Investigators must contact each institution and follow that institution’s FERPA policy, in addition to the requirements of UMass IRB. Finally, PPRA outlines 8 categories of protected information for survey responses (for more information on FERPA and PPRA, see related links).

2. Research in K-12 Setting

Research in educational settings require special conditions be put in place to ensure the safety and welfare of student participants.  Issues particular to students in grades K-12 include gaining access to school sites and obtaining parental consent and child assent for students under the age of majority at the study location (in most instances this will be 18 years of age but this can differ based on local and state regulations and interpretation).

Gaining Access to Setting

All research conducted in or in cooperation with schools or school districts requires approval from the district or school prior to the initiation of the study. Typically, district or school approval is a site letter (on institutional letter head) signed by the administrator in charge of making such decisions at the school site.  A copy of this letter should be included with the submission of the protocol to the IRB.

Parental Consent / Child Assent

For research conducted with participants who are under the age of majority, parental consent is required in addition to the child’s assent.  Parental consent should be done in a manner that actively engages parents in the consent agreement.  Passive consent is when an individual does not actively consent but also does not object to participation. Passive consent is not acceptable for research with children.  Both parental consent forms and child assent forms (or waivers if applicable) should be included in the IRB submission.  For more information on research with children, parental consent, and child assent please see our Assent Guidanceand Assent Template.

Things to Consider When Formulating Your IRB Submission

When submitting a protocol for research in an educational setting, the following information should be considered and addressed in the submission:

◦Undue influence is difficult to avoid in a classroom setting in which activities are determined and implemented by adults. Research designs should include strategies to reduce this risk. For instance, clear procedures should be in place for handling students who are not participating in the study in order to minimize interruption to the typical school day. Although students are generally obligated to participate in activity designed for the whole class, activities specifically implemented for the research need to be clearly explained and alternatives be provided for those choosing not to participate. Appropriate alternatives should be provided for those who opt out, and must be described in the protocol as well as the consent form.

◦Clearly describe the difference(s) between what would typically occur in class and what will occur related to the research (i.e., will all students be involved in the same activities or will there be individual students singled out within a classroom?);

◦The risks and inconveniences should be assessed and clearly described in the protocol and consent. For instance, in studies involving examination of classroom management techniques, will individual students be singled out for use of specific techniques? If so, what risks does that present to that child and to the other students (e.g., possibility of increasing in disruptive behaviors)?

◦Describe how privacy and confidentiality of all participants (i.e., student, teacher) will be maintained. For example, will study results be shared back with the school on an individual level or in aggregate? Will information about teacher performance be shared with school administration? What risks to participants are presented given how data will be both managed and shared?

◦When research activities are not part of the required class activities, the instructor should arrange to have the data collected by an independent third party, so that the instructor does not know who participated and does not have access to the identifiable data or identity of participants for any purpose until grades have been assigned and entered.  

◦Researchers should not mandate that an entire class of students participate, unless implementation of the intervention is a part of the course curriculum and researchers are only seeking to collect de-identified data of previously outlined course activities.

◦Describe the plan for handling a student who wants to withdraw from the study after consent/assent has been obtained;

◦Benefits or compensation for participation should extend to the entire class, regardless of how many children agreed to participate. This prevents scrutiny or peer pressure on the students who decline to participate.

◦When research activities involve the use of video and audio recording it is incumbent on the researchers to ensure that only those participants who have consented to participate in the study and agreed to be video/audio recorded are included in the recording.  If a parent/participant has not agreed to be video recorded, then the researchers must make sure that these participants are out of the video shot range and/or that these persons are deleted from any video recordings collected during the research process.  Subsequent use of video recordings must exclude participants who did not agree to be video or audio recorded.            

3. Research in Higher Education Setting

Research in college and university classrooms is a common occurrence.  Care should be taken with regards to issues of undue influence, recruitment, and confidentiality among other things.  Some of the issues outlined below will be similar to research in K-12 educational settings.  Additionally, as with K-12 students, FERPA restricts researchers’ access to college student records without written permission from students.

Things to Consider When Formulating Your IRB Submission

When submitting a protocol for research in a college or university setting, the following information should be considered and addressed in the submission:

◦Undue influence is difficult to avoid in a college or university classroom setting. Clear procedures should be in place for handling students who are not participating in the study. Although students are generally obligated to participate in activity designed for the whole class, activities specifically implemented for research need to be clearly explained and alternatives be provided for those choosing not to participate. Appropriate alternatives should be provided for those who opt out, and must be described in the protocol as well as the consent form.

◦Clearly describe the difference(s) between what would typically occur in class and what will occur related to the research (i.e., will all students be involved in the same activities or will there be individual students singled out within a classroom?);

◦Describe how privacy and confidentiality will be maintained.  Will course instructors know who has participated in the study (what risks might this pose for students)?   What risks to participants are presented given how data will be both managed and shared?

◦When research activities are not part of the required class activities, the instructor should arrange to have the data collected by an independent third party, so that the instructor does not know who participated and does not have access to the identifiable data or identity of participants for any purpose until grades have been assigned and entered.  

◦To alleviate any sense of repercussion from participating in research, researchers should include a statement indicating that participation or non-participation will in no way effect a students’ standing in the course.

◦Researchers should not mandate that an entire class of students participate, unless implementation of the intervention is a part of the course curriculum and researchers are only seeking to collect de-identified data of previously outlined course activities.

◦When course credit or extra credit is used as compensation, it is important to provide alternate means of earning course credit or extra credit for those students who choose not to participate in research.

◦As research volunteers, it is important to ensure student participants be allowed to withdraw from the study at any time. Describe the way compensation will be allocated in the event of early withdrawal.  For compensation in the form of extra credit, it may be necessary to provide full credit in a situation of early withdrawal.

Related Links

Federal Regulations Pertaining to Exemptions (45 CFR 46.101(b))

Federal Regulations Pertaining to Children as Vulnerable Population (45 CFR 46 subpart D)

FERPA Information

PPRA Information

Assent Form Guidance

Assent Form Template

Source material for this policy guidance was provided by the University of Connecticut IRB and from Banker & Amdur (2006).  The UMass IRB gratefully acknowledges this support.