"Normal educational practice" is an exemption category that often applies to educational studies but there are other categories that may apply as well. For more information, see Exemption.
According to CFR 45 part 46.104.d(1) exemption can be applied to the following: “Research, conducted in established or commonly accepted educational settings, that specifically involves normal educational practices that are not likely to adversely impact students' opportunity to learn required educational content or the assessment of educators who provide instruction. This includes most research on regular and special education instructional strategies, and research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods.” In order to qualify for exemption under normal educational practice, the study must demonstrate that it is conducted in an “educational setting,” that the topic of the study is within the realm of education research, and the study won’t impact students and/or educators.
For exempt educational studies, the Board can allow more flexibility in regards to consent requirements; a typical study may require that you notify parents of the study activities in the classroom but you are not required to document parent consent and student assent. For more information see Consent (link to info about parent notification).
Please note that this exemption category cannot be applied to individuals who are incarcerated (i.e. prisoners).
While normal educational practice studies typically occur in public or private school settings, normal educational settings are not necessarily limited to a formal school setting. The IRB-SBS defines an educational setting as any setting where one would go in order to have an educational experience. For example, a public school would certainly qualify, as would an after-school club or program, a Boy or Girl Scout meeting, or even a professional development seminar for school district personnel.
Many educational settings require researchers to obtain permission to conduct a study in that location. Make sure to connect with the site’s administration to obtain permission to conduct the study prior to starting the study (and if possible, before you submit your protocol as we need to have the permission documentation as part of your iProtocol).
Research conducted in public school settings must comply with state and federal laws such as FERPA and PPRA. In addition, research involving minors must follow additional IRB regulations specified in Subpart D of CFR 45 part 46; studies that include minors can still be considered exempt under normal educational practice.
The participants should include those involved in the educational experience: teachers, students, and possibly the administration and/or parents. Participants that are indirectly involved in the educational experience may be included in the study, but they may not be exempt under normal educational practice, thus requiring additional consent procedures, etc. Participants can include populations with special educational needs, though the Board will expect you to demonstrate your ability to sensitively work with these populations.
The Board recognizes that there are a variety of activities that normally occur in the classroom. Also, a researcher might propose classroom activities that involve new methodologies but still fit within the realm of “best practice” where the addition of these practices in a classroom may benefit the students. The Board considers educational time a valuable commodity and requests that you carefully develop your intervention so that it will not waste a student’s educational time and may even benefit their educational experience. Listed below are some of the types of studies that may qualify for exemption as normal educational practice:
- Test development
- Experimentation with instructional methods
- Evaluation of classroom or school activities which may include pre and post testing, surveys, interviews or observations.
- Collecting affective data, specifically attitudes toward learning.
- Data collection using videotape, audiotape, photography, and/or student samples. Please justify the necessity for using these methods for collecting data and specify what will be collected. If the information collected can identify an individual student, it may be necessary to document consent using a consent form. If the materials will be used in a presentation or publication, it may be necessary to use a Materials Release form. For more information about using recording devices, please see Recording Devices.
There are studies that may take place in an educational setting that the Board would not consider normal educational practice. The Board can still approve these studies, but they would require documentation of consent and possible review at a full board meeting. Examples of such studies include:
- Studies that may involve normal educational practice but have the potential to impact student educational experience.
- Studies that involve normal educational practice but have the potential to impact the assessment of the instructor.
- Interviews, observations, and surveys where the questions and subject matter goes beyond the scope of the educational activity being studied.
- Collecting privileged information such as socio-economic status, sexual information, abuse, etc.
- Educational activities involving procedures that are rarely used and are not considered “best practice” in the field.
The Board generally requests that parents are at least notified about the study via a notification letter. For more information, please see Recruitment and Informed Consent in an Educational Setting.