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 follows below is information to determine whether a study is exempt. If you have any questions about whether a study is exempt, please contact the HRPO at 413-545-3428.
There is guidance specific to Research in K-12 Settings and Research in Higher Education Settings as well.
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:
- Research on regular and special education instructional strategies
- 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.
FERPA
The Family Educational Rights and Privacy Act (FERPA), outlines what is required when students’ graded assignments are used in research that will be disseminated beyond the classroom or school system from which it originated. FERPA applies to all graded assignments, even if names are removed. FERPA does not apply to end-of-the-year course feedback forms, as these are provided de-identified to professors, nor does it apply to aggregated grades (i.e., reporting in a publication how midterm averages changed from one semester to another after a change in pedagogy). It does not apply to in-class activities that are entirely ungraded (including such activities’ impact on participation grades), but these activities may still be considered “human subjects research” and, if completed for extra credit, our extra credit guidance would apply.
FERPA conditions should be met by a research consent form. These conditions are:
- The purpose of using graded assignments as research data
- Which assignments will be used; this can be particular (such as “midterms and final exams”) or general (“all quizzes and all discussion board posts”) but should list every distinct type of assignment that will be utilized for data collection
- Who will view the data, and in what form (i.e., with names still on it or deidentified)
- How long it will be maintained, and in what form (i.e., with names or deidentified)
- A signature from the student (if an adult) or the student and parent (if the student is a minor)
Any FERPA issues that are not related to a research project should be directed to the University Registrar’s Office.