DePaul University Research Services > Research Protections > Institutional Review Board (IRB) > FAQs
IRB review is an important component of the commitment of the university community to conduct all human subject research activities within the bounds of the most rigorous ethical and methodological standards. The IRB links the researcher and the research subject via the use of appropriate procedures for obtaining the informed consent or agreement of subjects before they participate in research. IRB review and approval of the research assures the subject that the researcher has adopted appropriate procedures for conducting the investigation, for protecting the subject’s rights and welfare, and for protecting the confidentiality of the data.
Also, IRB approval assures compliance with federal rules and regulations governing the treatment of research subjects, as well as DePaul policies and procedures and state laws.
All research at the University that involves human subjects, as defined by the Federal regulations, requires IRB review. This is true regardless of its funding source or area of research.
Late in 2003, the Oral History Association and the American Historical Association announced that the Office of Human Research Protections (OHRP) had concurred that most oral history projects are not research as defined by the HHS regulations governing human subjects research. In December 2003, OHRP’s Associate Director for Regulatory Affairs, Michael Carome, issued the following, more specific, guidance: OHRP Oral History Guidance.
In short, Carome’s guidance maintains that so long as oral history activities meet the federal definition of research according to 45 CFR 46.102(d), then they are still subject to IRB review.
The revised regulations, which went into effect on January 21, 2019 indicate that the following activities are not deemed to be research: Scholarly and journalistic activities (e.g., oral history, journalism, biography, literary criticism, legal research, and historical scholarship), including the collection and use of information, that focus directly on the specific individuals about whom the information is collected.
This is not a change in thinking, but codifies how the IRB has always looked at oral history projects. If the oral history project collects stories and the goal is to report the stories as a collection of stories or some similar goal, the project does not involve research and does not require IRB review and approval. However, if the project has a research goal that is not focusing on individual stories, but rather collects the stories for the purpose of coming to conclusions, proving a hypothesis, or developing genralizable principles, then oral history techniques are more likely being used to conduct research and then the project does require IRB review and approval.
It is the IRB’s experience that some DePaul oral history activities are either:
Carome’s guidance cites these two types of oral history activities as ones that continue to require IRB review and approval. Accordingly, DePaul continues to assess the appropriateness of IRB review of oral history projects on a case by case basis.
It is important to note that under the revised regulations, some research projects involving the use of oral history techniques or the establishment of a research archive may now be exempt.
IRB review of classroom-related activities or projects is not required at DePaul when the collection of information from people is exclusively for the purpose of class discussion, for the purpose of training in research or research methods, or will be used just for a class paper, grade, or to complete an assignment. This is because the activity does not meet the generalizable portion of the definition of research. Instructors who believe that their students’ classroom-related activity does not require IRB review may choose to submit a summary of the classroom activities to the Office of Research Services (ORS) for confirmation that the activity does not involve research or human subjects.
Even when IRB review is not required, activities designed to collect information from people should protect the rights of these people and the confidentiality of the information, especially if it might be deemed sensitive. In such cases, the instructor remains responsible for educating students about human subject research and why the current activity is not human subject research, and providing ethical guidance for all student project activities. It is important that the students and instructors do not use the word research when contacting or talking to people and do not suggest that classroom projects or activities are IRB reviewed and approved. Both instructors and students are advised to use a consent-like process to obtain the agreement of the person to be part of the activity, but the consent process should call the activity a classroom project and not research.
Please Note: Data collected for a class project may not be used for publication or presentation, unless the project was reviewed and approved by the IRB prior to recruitment and data collection. Should there be any possibility of or intent to publish, present, or otherwise disseminate research data or findings outside the course in the future (e.g., for a Senior Paper, a Master’s Thesis, by the instructor), thereby making the data generalizable and meeting the definition of research, an application must be submitted for review and approval by the IRB prior to the start of recruitment and data collection.
DePaul University is committed to the protection of the rights of human subjects in any and all research that is conducted by persons officially affiliated with the University. Therefore, all acticities that meet the definition of researach involving human subjects conducted by DePaul faculty, staff, or students must have IRB review and approval before any research-related activities, including recruitment, begins.
The following decision algorithm should help you determine whether you need to submit an application to the IRB. The IRB uses this decision-making process for each protocol.
Human Subject means a living individual about whom an investigator (whether professional or student) conducting research:
Please Note: Use of data about deceased individuals does not need IRB approval. However, the HIPAA Privacy Rule may apply to the use of some information about deceased persons. In addition, some types of research with publicly available archival data does not require IRB review.
There are eight categories of exemption (see Levels of Review -exempt). Exempt research follows the general rationale that the research involves little to no risk to the research subject and that disclosure of the subjects' identity would not place them at risk of criminal/civil liability or damage to their financial standing, employability, or reputation or the research activity itself will not cause physical or emotional harm.
Minimal risk means that the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests. Research that involves minimal risk may be reviewed through the expedited review process.
You should submit your IRB application and all supporting materials via email to email@example.com. Hard copies of signed forms are no longer required because all the IRB forms have been converted to fillable PDF formats, which allow for electronic signatures.
Once you have submitted your application to the IRB, you should receive formal notification of the IRB review within 7-10 business days (does not include weekends or holidays). During certain time periods, a response may take up to 14 business days. If the IRB requests revisions, then additional time is needed, because the IRB awaits your response to the requested revisions, and then reviews your submitted revisions.
Researchers should maintain a file of all documents relevant to the IRB review of the research project in question. The principal investigator's records should be a mirror image of the IRB's records, meaning that all documents submitted by the researcher to the IRB and all correspondence between the IRB and the researcher should be kept on file by the researcher.
The documents that researchers should have on file include, but are not limited to:
Please Note: In cases of exempt review, the researcher is responsible for retaining the only copy of some important documents including:
Documents certifying that the researcher has met school district requirements when conducting research in educational settings (e.g., a letter of collaboration from the school principal; documentation from the school board or Chicago Public School RRB approval).
Once your project has been approved, you must comply with any requirements included in your approval memo and with the following PI Responsibilities, which includes submitting timely continuing review reports, when applicable, and obtaining approval for changes via an amendment before changes are implemented.
The revised regulations, which became effective on January 21, 2019, elimianted the need for continuing review for most expedited level research protocols. However, the IRB can make the decision that a particular expedited protocol requires continuing review. All protocols requiring convened review still require continuing review.
A project will receive the same level of review at the time of continuing review, or when an amendment is reviewed, as it received originally, unless:
Once the IRB has classified a project as exempt or approved a project, the project must be conducted as approved. For research projects granted an exemption determinations, all changes
such as changes in the design or focus of the research project,
revisions to the consent/information sheet for subjects, addition of new
measures or instruments, and any change to the research that might
alter the exemption status (either add additional exemption categories
or make the research no longer eligible for an exemption determination)
would require submission to the IRB for approval prior to initiation in
the research. If you have questions about whether an item requires
submission to the IRB, please contact the Office of Research Services-Research Protections staff.
For research projects reviewed under expedited review or convened review, changes in subject population or number, recruitment plans, research procedures, study instruments, study sites, to the consent/parent/legal guardian permission/assent or major research personnel must be approved by the IRB via an amendment.
Please Note: Proposed changes should not be implemented until approved by the IRB.
All research projects involving of human subjects must be reviewed and approved before data collection or data analysis may begin. The IRB may:
The IRB seldom disapproves research activities. Instead, the IRB strives to work with the researcher to assure excellent research design with minimized risk and maximized benefits to the subjects or society.
The Local Review Baords were committees set up in departments, colleges, and schools, which most frequently submitted protocols to the IRB. The pupose of the LRB was to provide a scientific review of the field-specific methodology and research design. The LRB also conducted a pre-review for adherence to DePaul policy and templates. In August 2016, the IRB decided it was time to discontinue the LRB process at DePaul. You no longer need to submit your IRB protocol materials to the LRB first, but rather you submit all protocols materials directly to the IRB through ORS.
Although the IRB has always had a mandate to review the scientific design of the research in order to ensure the risks to the subjects are minimized, the elimination of the LRB process means the IRB will be the sole scientific review process at DePaul.
Unanticipated problems involving risks to subjects or others (UPIRSOs) whose nature, severity, and frequency were not described in the information provided to and approved by the IRB or provided to subjects in the consent document must be reported to the IRB within 72 hours. Examples include unexpected medical complications with a subject, missteps in the consent documentation, or breaches of confidentiality.
Sometimes a study must be suspended to ensure subject safety. The report of the event should include:
These reports usually receive expedited review, but in some cases the full IRB is involved.
Research benefits and burdens should be distributed fairly. If an individual or group is denied access to a clinical trial that might be beneficial or if some people are singled out to bear the burden of risks associated with a study, the requirement for fairness is not met. In accordance with the policies of the National Institutes of Health, the IRB requires researchers applying for federal funds to give breakdowns of their subject populations by gender and minority group.
Studies with the potential to address issues relevant to both sexes must recruit both genders, and minority populations should be included in a study population wherever feasible. Researchers must justify the exclusion of women or minorities. The IRB makes exceptions only if there is adequate scientific justification for exclusion, such as when a disease predominates in one gender.
Yes. However, in addition to avoiding all obvious forms of coercion and undue influence, researchers must take precautions not to unintentionally or subliminally coerce anyone into studies. Subtle coercion often occurs when a potential research subject is also a student, employee, colleague, or subordinate. For this reason, researchers should avoid using their own students or employees as research subjects.
If there is a good scientific reason for including students, researchers should:
If the research involves greater than minimal risk, children can be included in the study population only if the research projects meets specific criteria under the federal regulations [45 CFR 46 Sub Part D]. These regulations apply to research in both the health sciences and the social sciences. A research protocol in either field that involves anything more than minimal risk and that does not offer a direct benefit, the indirect benefit of offering knowledge to be gained about the child’s disease or condition, or the opportunity to understand, prevent, or alleviate a serious problem affecting the health or welfare of children cannot involve children.
Researchers proposing projects that include Chicago Public School District (CPS) students or their school records should consult the CPS Guidelines for research and IRB Guidance for Conducting Research with School Children: CPS Research Guidelines.
Researchers may pay research subjects for their participation, but payment arrangements must be disclosed to the IRB and are subject to a stringent review. Payment arrangements affect the fairness of recruitment plans, the balance of risks and benefits, and the adequacy of informed consent. Although there are no fixed formulas for determining whether payment plans are acceptable, the IRB prohibits payment arrangements that appear to be coercive. Payment should not encourage subjects to participate or continue to participate against their better judgment.
The amount paid to subjects must correspond to the burdens of participation. For example, payment might defray parking charges or transportation costs. Payments may also be scaled to the time that subjects spend in a study or to the biological materials they donate. The minimum wage provides a ready baseline for hourly rates for participation, and the Blood Bank's payment scale for plasma and other blood products offers a guideline for compensating subjects for biological materials.
Departmental or college policy may not allow researchers to pay cash, so researchers may offer gift certificates or cards or grocery vouchers. When children and adolescents are the subjects, researchers sometimes reimburse parents for parking or transportation and give a token payment or gift certificate to the subject. Lotteries and raffles are subject to the laws and regulations governing games of chance and this terminologymust not be used. The term drawing can be used.
Subjects should generally receive at least partial payment if they withdraw from a study early or do not fully complete all the research visits or tasks. This is called proration of payment. Withholding all payment until participation is complete is coercive, so if possible payments should be prorated and made after each research visit or group of visits for long-term research projects. A modest lump sum can be paid after the subjects's participation is complete if the arrangement is thoroughly documented in the consent form.
Also, payments may be weighted such tha the final time point pays the subject more money than the other time points to incentivize the subject to complete all taks. However, the weighted payment cannot be overly large such that it coerces the subject to continue participation against their better judgement.
Yes. Researchers engaged in cross-cultural research should give particular attention to the use of culturally appropriate assessment instruments and procedures, the language(s) used in the conduct of the research and consent process, and the language preference and language variability of the research participants. Researchers developing studies involving members of an unfamiliar racial, ethnic, cultural, linguistic, gender or sexuality group should develop a reasonable level of familiarity with, but would not be limited to, the language, behavior, social mores, customs and traditions of that group. A researcher should consider consulting social and behavioral scientists and others who are more knowledgeable of, and experienced with, the intended study group before constructing a protocol.
The application must specify the number of study subjects to be recruited and tested, grouped by age, gender, and population diversity. This assures a representative research sample, statistically adequate results, and prevents aggressive over recruitment. Additionally, the IRB can assess the scientific validity of the data that may reasonably result from the research protocol. Exceeding the recruitment limits agreed to by the IRB is a protocol violation or non-compliance unless the IRB gives written permission (approval of an amendment increasing the subject number).
If it is difficult to predict how many subjects will be eligible or be attracted to a study, the optimum number should be specified, for example if you plan to send out 200 emails then 200 should be specified. Responses such as "don't know" or "as many as we can recruit" to questions about the number of subjects are not acceptable. A discussion of the problems faced in recruiting subjects should be included.
Multicenter studies, in which data will be pooled and the ecruitment processes may vary, present a special problem for investigators. The application should provide information about the total picture, including both the number of subjects to be studied at the University or by University researchers and information on overall recruiting at all sites (expectations for local recruitment and study-wide recruitment).
Advertisements are part of the informed consent and subject selection process. Samples of all advertisements, such as flyers, newspaper ads, radio and television announcements, bulletin board tear-offs, social media positings, and posters, along with an explanation of other methods of recruiting subjects, must be submitted to the IRB.
Advertisements should be submitted with the application or as soon as the investigator decides to use them. The content of advertisements should be limited to:
Advertisements should not claim, explicitly or implicitly, that the research is treatment or is superior to any current practice. Extravagant attention-getting devices such as extremely large, bold typefaces and dollar signs for payment information are prohibited. Advertisements should not pressure readers into participating.
Snowball recruitment – Often times researchers have an initial pool of contacts and they hope those people will "nominate" other qualified potential subjects. This kind of sampling is commonplace in case study and qualitative psychological, sociological, and anthropological research. However, it may be used also in genetic studies where it is necessary to recruit relatives of the initial subject for direct interviews and/or tissue sampling, etc. This recruitment procedure is sometimes inappropriately labeled "cold calling". The following excerpt from the Belmont Report regarding voluntariness compels IRBs to pay close attention to snowball recruitment procedures:
"Unjustifiable pressures usually occur when persons in positions of authority or commanding influence---especially where possible sanctions are involved--- urge a course of action for a subject. A continuum of such influencing factors exists, however, and it is impossible to state precisely where justifiable persuasion ends and undue influence begins."
For example, what if a highly respected individual in the community (say a local elected official, teacher, member of the clergy, or tribal elder) provided the name of a potential contact. When the nominee is contacted, the person might be unduly influenced to participate in the project because of the stature of the nominator. Consideration of minimal risk is likely to play an important role in IRB review of snowball recruitment procedures. For example, it would make a big difference whether the research involved extramarital affairs or substance use as opposed to family meal time routines or leisure activities. To "cold call" someone on sensitive topic issues places him or her in a potentially embarrassing situation, which should be avoided. Moreover, the original subject is being placed in the position of being asked to disclose information about a third party without that party's consent.
Snowball recruitment where the researcher obtains names and contact information from one individual for another one, particularly for research involving sensitive topics, is generally not considered appropriate by the DePaul IRB. Using such a method could result in the researcher obtaining information about an individual that is sensitive and private without their permission. Alternatively, the researcher should ask other subjects to pass along flyers, emails, information sheets, etc. that contain contact information for the researcher to prevent a breach in confidentiality of sensitive information or an invasion of privacy. In instances where the research subject is not sensitive (i.e.,opinions on politics, consumer opinions), a snowball recruitment method where one person provides the name and contact information for another person may be acceptable, but doing so must be justified.
One means of reducing the risks in snowball recruitment is for the researcher to gently ask subjects whether they would be willing to pass some information about the study they just completed to other potential subjects. The researcher may give the original subject an information sheet or flyer that they can give to people they think might be interested and qualified. Then these potential subjects can contact the researcher if they are interested. The researcher must provide the IRB with a copy of the recruitment item (which must include all of the same information that is in the initial recruitment script) he/she will give to the initial contacts to distributeto others. If the potential subjects were interested in study participation, they would be free to contact the researcher.
The IRB recommends the following safeguard procedures if snowball recruitment is to be used:
Yes. In general, it is important to remember that the recruitment process is an extension of the consent process. The IRB must review and approve all recruitment materials and processes to ensure that the information provided to subjects is accurate and not coercive. The language in recruitment materials should be targeted to the subject population and be at a similar reading level as the consent process, usually the 6th -8th grade reading level for adults.
Required content includes:
Please refer to our guidance document on recruitment materials and content for additional information.
Department of Health and Human Services regulations for the protection of human subjects require that informed consent information be presented "in language understandable to the subject" and, in most situations, that informed consent be documented in writing. The written consent document should embody, in language understandable to the subject, all the elements necessary for legally effective informed consent. Whenever possible, subjects who do not speak English should be presented with a fully translated consent document written in a language understandable to them. In addition, someone who speaks the language of the subject must be present to answer any questions that the subject might have at the time of consent and during the course of the research. This person could be the researcher, a certified translator, etc.
A second method of obtaining consent for persons who are non-English speaking involves the use of a “short form” consent document and process. When using the “short form” process, informed consent information is presented entirely verbally in the language of the subject using an information sheet or research summary (which can be the approved English consent document) and a verbal translation process. Then a “short form” that has been translated into the subject’s language is reviewed with the subject. The “short form” is a document stating that the elements of consent have been verbally presented to the subject or their legally authorized representative. There should be a witness to the entire consent process (presentation of the information sheet/research summary and the “short form”). The subject (or their legally authorized representative) and the witness must sign the short form. The person conducting the consent process and the witness to the consent process must sign the information sheet or summary of the research. The subject must be given copies of the information sheet or research summary and the signed “short form”.
The IRB must receive all foreign language versions of the consent document as a condition of approval. It is important to have the translated documents independently back-translated into English to assure that the translation has not distorted the intention of the English version. If using the short form process, the IRB must specifically approve the short form consent process (must be explained in the application), the information sheet/research summary, and the translated short form that will be used in the research. If more than one group of non-English speaking persons will be recruited, then all potential versions of the short form must be approved for use by the IRB.
Example: The approved consent form is in English and needs to be translated into Spanish.
Additional Federal regulations may apply to your research if your research involves recombinant or synthetic nucleic acid molecules, Infectious agents, Select agents, toxins, or other biohazardous agents. In order to access the risks related to research (and teaching activities) involving these materials and to ensure that the proper safety precautions and procedures are in place, protocols utilizing these materials must be reviewed and approved by the DePaul University Institutional Biosafety Committee (IBC). Research projects may be submitted to the IRB and the IBC simultaneously. However, the IRB review and final approval for the research project cannot be finalized until final IBC approval has been received. The most common type of protocol at DePaul University requiring IBC review and approval is one drawing blood and utilizing the blood for the research, such laboratory testing or manipulations.