When can I submit subject recruitment materials?

With the exception of UVA Health Clinical trials website ads, ALL recruitment material must be submitted with the INITIAL prereview submission to the IRB HSR.  This is relevant for full board, expedited and exempt applications. 

After review and approval by the UVA IRB HSR, all revisions to recruitment material are to be submitted to the IRB via IRB PRO-SUBMIT DOCUMENTS-Modifications.  You will be required to include a Modification request form with your submission. 

To submit a UVA Health Clinical Trials Website ad: 

1. Complete the UVA HS Clinical Trials Website template
2. Go to www.uvahealth.com/clinicaltrials and submit using the Submit a Trial for Advertisement link
3. Be sure to choose the keywords and categories and upload the completed web ad.

A note about sponsor produced recruitment materials: Review all documents provided by the sponsor before submitting to the IRB-HSR. Sponsor produced ads are often missing locally required elements such as HIPAA language and UVA site contact information. If the site will be using these materials, insert this information before submitting to the IRB-HSR.

For print material that is not editable, contact information can be included by affixing a sticker label (“stickie” template above) to the document at the time of distribution. 

All ads are approved with no expiration date.

How to submit advertising if the UVA IRB-HSR is not the IRB of record for your study

The IRB-HSR does not review or approve recruitment material for protocols that are reviewed and approved by a Non-UVA IRB. Follow the IRB of record’s procedures to obtain approval of the recruitment material.

To request an ad to be posted on the UVA Health Clinical Trials website:

• Submit the approved ad with ad approval from the IRB of Record through www.uvahealth.com/clinicaltrials using the Submit a Trial for Advertisement link. This option provides the dropdown fields to choose keywords and categories.

The UVA IRB-HSR will post the submitted ad and will provide documentation of receipt.

UVA Health Strategic Relations and Marketing (Marketing) Review

The use of UVA Health brand templates and downloadable materials (available at www.uvahealthbrand.com) is recommended to ensure the appropriate use of the UVA logo and related branding guidelines. Marketing staff also aid in creating custom documents.

Marketing approval is required in addition to IRB-HSR approval for all print ads*, some online postings, radio and television ads, social media ads, and videos that use the name of UVA, UVA Health, and/or logo. This includes the use in contact information. Recruitment materials that require professional printing or result in a cost to the study team in order to produce the materials require Marketing approval.

*Ads printed in a publication, i.e. magazine, newspaper. Excludes Cville Weekly ads.

Radio/Television/Video

Radio, television and video scripts and actual recordings require approval by the IRB-HSR and Marketing. Scripts should be submitted for approval PRIOR to recording.

Final versions of recordings should be submitted for approval PRIOR to going live.

Social Media (Facebook, Twitter)

All social media postings must be approved by IRB-HSR.

Social media ads created by Marketing should be submitted to the IRB-HSR for approval. Additional Marketing approval is not required.

Social media accounts created for studies or research centers must be approved by the IRB-HSR and Marketing. Study teams should contact Marketing for assistance in developing the account. Once created, the study team should submit a Management Plan to the IRB-HSR for approval prior to going live (see template section). 

Non-Monetary Gifts and Retention Incentives

Non-Monetary Gifts and Incentives require IRB-HSR approval.

Submit the list of items to IRB PRO-Submit Documents- Choose, Modification. The list of items should contain a picture and/or description of the retention items (see template section). Include with your submission a completed Modification request form.

The IRB-HSR will review the items to verify if the use of these items appears to be exert undue influence. The convened board may be asked to review the retention incentives to make this determination. Full Board review will always be requested for any item valued over $25.00 for items given to children and over $50.00 for items given to adults.  If the board deems any item is inappropriate for use at UVA, the study team will be notified in writing of the board’s determination.

Recruitment of Children

The ethical requirement of respect for persons, as outlined in the Belmont Report, applies to children as well as adults. Children, however, are in a dependent relationship to adults and easily manipulated in an academic or clinical setting. A child's dependent relationship entitles them to extra protections and are thus considered a "vulnerable subject population". Investigators should take every precaution to ensure that a child's decision to participate in research is both voluntary and free from coercion. A child's refusal to participate should not be met with a negative response or punishment. The IRB strongly recommends that investigators address the following when submitting applications that include the recruitment of children: 

• Investigators should acknowledge and create a mechanism for addressing and minimizing the coercion implicit in requests to participate from parents, teachers, or other adult authorities. 
• Investigators should make provisions to minimize the fear of ridicule, social pressure, or peer pressure to participate. 
• Incentives or rewards for participation may be used but should not be so valuable, within the value system of the parent or the child, as to sway the child's legitimate reluctance to participate. 

Permission of the School 

School officials and/or teachers do not have the authority to give consent for the participation of children in research. Only a parent or guardian may allow a child, with the child's assent, to participate in research. The IRB requires submission of proof of approval of the school district prior to allowing investigators to contact, recruit, or enroll children into a study. Investigators should contact school district officials regarding the appropriate procedures for obtaining permission to conduct the research in individual schools.  
The No Child Left Behind Act of 2001(Public Law 107-110) amended the Protection of Pupil Rights Amendment (PPRA), which concerns surveys of students, in two ways: 

• First, it added an eighth category to the categories of protected information in surveys of children that were already covered by PPRA. 
• Second, it gave parents new rights with regard to the surveying of students who are children, the collection, disclosure, or use of information from students for marketing purposes, and certain non-emergency medical examinations. 

PPRA, as amended, has two sets of requirements for surveys: 

• Requirements that apply to "protected information" surveys that are funded in whole or in part by the U.S. Department of Education. 
• Requirements that apply to "protected information" surveys that are funded by sources other than the U.S. Department of Education and that are administered or distributed by education institutions that receive funds from any Department of Education program (i.e. public elementary and secondary schools and some private schools). 

PPRA lists 8 categories of protected information for survey responses: 

• political affiliations of student or student's parent; 
• mental or psychological problems of student or student's family; 
• sex behavior or attitudes; 
• illegal, anti-social, self-incriminating or demeaning behavior; 
• critical appraisals of others with whom students have close family relationships; 
• legally recognized privileged or analogous relationships; 
• religious practices, affiliations or beliefs of student or student's parent; 
• income. 

PPRA has implications for IRBs in applying the Common Rule criteria for waiving informed consent (in section 116(d) of the Common Rule). Specifically the second IRB criterion: "research does not adversely affect the rights and welfare of subjects" is impacted because of the "rights" that PPRA gives parents. 

Practical Implications in Applying the Common Rule Waiver Requirement pertaining to rights and welfare:  
First Set of Requirements: US Department of Education Funded Protected Information Surveys 

• Does the research involve "protected information" surveys? 
• Are the surveys U.S. Department of Education- funded in whole or part? 
• Are the surveys "required"? 

If the answer is yes to the three questions, PPRA affords parents the right to provide written informed consent.

Payment for Recruitment

Finder's fees and other financial incentives paid by a sponsor or by an investigator to others related to the recruitment of research subjects are prohibited. No one may receive any incentive for the purpose of encouraging individuals to participate in research. 
All payments by sponsors for research conducted under the auspices of the University of Virginia must be made directly to the University of Virginia and will be managed by the University. Payments should never go directly to investigators, key personnel, or subjects without first going through the University.