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Union Institute & University may authorize or support formal and informal internal assessment studies that directly or indirectly involve human participants. The most likely forms of such studies are focus groups, interviews, pilot tests, questionnaires, and surveys.
The term “internal assessment” is used to describe a wide range of information and data gathering efforts conducted by a college, center, administrative unit, committee, or individual. Assessment activities that do not require IRB approval include:
If, however, any of the above-mentioned items occur with the intent to publish findings outside the university, IRB approval will be required.
IRB approval is required for data collection / information gathering on behalf of the institution through processes that involve interactions with students, employees of the university, external employers, etc., through such mechanisms as focus groups, interviews, pilot studies, questionnaires, and surveys. In most cases, such activities are expected to pose little or no risk, with participant safety ensured by processes to ensure confidentiality such as limited access to data and reporting of results in aggregate. IRB approval is required for all such activities conducted by UI&U faculty and staff. The Associate Vice President for Institutional Effectiveness must be informed of all assessment activities in all programs in all locations.
If a college or department is engaged in such an activity and has not previously obtained IRB review and approval, the activity must be halted until IRB approval can be secured. To determine whether an activity requires IRB approval, contact the IRB Director.
An IRB application and research proposal must be submitted to the IRB for internal assessment activities involving research and subsequent publication, unless waived in writing. The written proposal must be submitted to the IRB Director and follow the format described in “Template for IRB Research Proposals.” The IRB requires all applications to first be reviewed and approved by the appropriate supervisor (dean, director, vice president) and reviewed by the Associate Vice President for Institutional Effectiveness.
In preparing an application to the IRB, a single individual should be designated as the IRB contact. The application should include a description of the project that follows the “Template for IRB Research Proposals,” plus any related documentation such as surveys, interview scripts, cover letters, recruitment e-mail messages, informed consent forms, etc. Proposals to conduct online assessment studies must include a description of how confidentiality and participant identity will be protected. (See “Application Preparation Requirements.”)
Because internal assessment often makes use of longitudinal studies (research projects extending over periods greater than a year), the IRB may approve such studies for up to 24 months.
Requests for continuation of IRB approval beyond the original expiration date should be submitted to the IRB Director at least two months before IRB approval will expire. If the project has not changed substantively, the IRB Director has the authority to approve a continuation of IRB approval. (See Continuing IRB Review / Request to Renew IRB Approval form.)
Anyone who wishes to make substantive changes to a previously approved internal assessment research project is required to obtain IRB approval before implementing the proposed changes. Follow the guidelines in “Modifications to Previously Approved Research” and submit the Modification Request form to the IRB. Be sure to include the reasons for the changes and attach any supporting documents such as a revised survey instrument or consent form.
The IRB has the authority and the obligation to suspend or terminate IRB approval of any internal assessment research with human subjects for any one of the reasons listed below. This authority extends to ongoing research (i.e., research for which IRB approval was not obtained). Reasons for suspension or termination of approval are the same as for other research involving human subjects, as outlined in “Suspension or Termination of IRB Approval.”
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