Education Research Settings
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.
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 (link is external), FERPA (link is external) (Family Educational Rights and Privacy Act), and PPRA (link is external) (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).