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Normal Educational Practices Considered Exempt from Committee Review
Federal Exemption #1: Educational Practices
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, curricula, or classroom management methods.
In Special Education, normal educational practices correspond to the Individualized Educational Program (IEP), which is tailored to each student with an identified disability and may be implemented in diverse settings (e.g., school, home, work, community).
A “normal educational setting" means preschool, elementary, secondary, and higher educational facilities, and after-school programs (if the project relates to tutoring, or homework help).
Commonly accepted educational settings include but are not limited to schools and universities, workplace educational programs and sites; libraries (adult learning classes), and other sites where educational activities regularly occur, including some nontraditional settings (e.g., nutrition class at a grocery store). Normal educational practices are not restricted to traditional settings and can include a variety of acceptable educational practices.
The reviewer has to consider whether the proposed activities constitute normal educational practice and if the setting is a commonly accepted educational setting. For example, a study to develop an innovative method for teaching math in the second grade would be eligible under this exemption provided the curriculum development methods reflected normal educational practices. Typically, the educational setting would be a classroom. However, teaching students to drive in a driver’s education class or teaching children or adults to cook in a formal cooking class could be also considered a normal educational setting.
This category does not apply to Food and Drug Administration (FDA) regulated research.
Kinds of Data
- students' curriculum-related written work, test scores, grades, artwork and other work samples produced by children
- students' curriculum-related oral and non-verbal communicative responses individually, such as in an interview, in small groups and with the whole class
- students' responses (written, oral or behavioral) to curriculum-related activities
- students' level of active participation in curriculum-related activities
- videotapes and photographs of curriculum-related classroom activities
audio tapes of teacher-student and student-student discourse related to the assignment
- teacher's non-participant observation of curriculum-related activity of individual children or groups of children, noting what will be observed and how it will be analyzed, or whether it will be used as anecdotal evidence in the study
- teacher's commentary on students' curriculum-related written work, artwork and other artifacts produced by children
- student journals and communication books related to the curriculum
- student grades and test scores
- teacher journals, notes and reflective comments on student responses and participation in curriculum-related activities
- questionnaires or interviews with students, parents and family members, teachers and administrators
- non-participant classroom observations by colleagues, with the class teacher's permission, stating what will be observed and how it will be used (i.e. how data will be analyzed or whether it will be used as anecdotal evidence).
Examples of Research Exempt under Federal Exemption #1:
- A study evaluating the effectiveness of a commonly accepted science curriculum. For the study, researchers will observe classroom instruction and collect quizzes and class evaluations that are part of the curriculum and classroom practices.
- A study comparing two curricula that are currently being implemented (or one that is current but recently replaced an older version). Researchers will observe classrooms as well as interview instructors about their experiences implementing the instructional materials and collect class evaluations.
- A study comparing driver's education curricula offered by area driving schools. The researcher will observe classes and compare driving test scores at the end of the courses.
- A study involving interviews of third grade teachers regarding their experiences and techniques with implementing new math standards. Researchers will obtain lesson plans and ask the teachers to provide reflective journals for one week.
Examples of Research NOT Exempt under Federal Exemption #1:
- Research that falls under the Protection of Pupil Rights Amendment (PPRA).
- Research involving “high-stakes” research models that will affect the participant (e.g., testing methods to determine if children should be held back) or the school (e.g., analysis of data to determine success or failure of schools that could be used to determine school closings).
- A study evaluating homework stress by interviewing eighth grade students on the amount of homework they receive and surveying their parents about their perceived stress level and sleep habits of their children. No questions of sensitive nature.
- Researchers are interested in developing a new assessment for math skills that involve both scoring of written prompts as well as responses involving use of manipulatives. It is expected that a new standard, norm-referenced product will result. According to the school, the planned assessment is aligned with current curriculum and will not require students to respond to questions that would be unfamiliar; however, the development process entails having students respond to more assessment items than would be expected. In addition, in order to validate the new assessment, additional tests not currently used in the school will be administered for comparison, thus extending total testing time and number of items beyond what would be considered normal educational practice.
What if I am a teacher who wants to do research with my own students?
In‐service PreK-12 teachers conducting research may reasonably want to analyze data already collected from their students (homework, test scores, class projects, writing samples, portfolios, etc.). Provided no intervention takes place, such research may be approved under federal exemption #4, analysis of data collected for another purpose. Under this exemption, parental consent and minor assent are NOT required, as long as all data is de‐identified when it is reported.
In-service PreK-12 teachers conducting research may want to analyze the teaching methods they are already using. Much of this work falls under federal exemption #1, research involving normal educational practices.
In order to meet the exempt requirement, ask yourself if the project meets the following criteria:
- The proposed activity/intervention is one I am free to assign in my role as instructor.
- The entire class can engage in the proposed activity/intervention, even if I only want to analyze data from a smaller subset of my students.
- The proposed activity/intervention does not require participation outside the classroom or outside normal class hours (except for homework assignments).
- Data can be de‐identified in any report or publication.
If your project meets the above criteria and your principal signs a letter stating s/he has read your proposal and agrees with your assessment (Form H) you may submit your application for an exempt review as above.
In all cases, the IRB still suggests that a letter or statement explaining the research to be shared with all stakeholders.
Any other research proposing interventions with your own students--especially if it takes place after school or during breaks, or requires separation of a student or group of students from their classmates during class time—requires expedited or full board review by the IRB.
In addition, the following links to the OHRP decision flowcharts can help you determine whether your research is considered exempt:
PLEASE NOTE: For studies that require recruiting participants, teachers and university faculty members may not directly recruit their own students or their students' parents/guardians. Recruitment must be handled by a CITI-certified co-investigator or research assistant.
Teachers can hand out consent forms to students to take them home (or put the forms into the students’ cubbies or take-home folders, if appropriate) but can only offer a very brief, neutral statement such as “Please take this home to your parents." Providing the forms in an envelope or otherwise closed manner (folded, folded and stapled, etc.) is also a best practice precaution that the IRB suggests but does not mandate.
Options for university instructors to recruit their own students (age 18 and over) include the following:
- Distributing in class by a CITI-certified research assistant or colleague. (The researcher would have to be absent at the time of distribution to reduce any perception of coercion).
- Posting in a place where potential subjects will see it.
- Distributing via a class e-mail listserv (not using individual student names). If this option is employed, the use of the e-mail listserv should be "at arm's length." In other words, the listserv should either list students in the class of a third party or, if the listserv lists students in the researcher's own class, the recruitment e-mail should be sent by a third party.
What if my research involves student surveys or interviews?
For PreK-12 students, a survey of minors may be permissible within the constraints of an exempt-level review if a teacher-researcher is surveying students as part of the regular curriculum regarding the normal educational practice being studied. For example, if a teacher-researcher was evaluating the reading curriculum and wanted to survey all minor students about the books they read, this may fit into the evaluation of the normal educational practice. However, if the research only involved a subset of students and was not part of the regular curriculum, the study would require an expedited or full board review.
For university faculty members working with students 18 and over, the guidelines are slightly different, as surveys and interviews with adults may fit the exempt category depending on the level of risk.
What if my research involves video/audio recording classroom lessons or observing teacher/student interactions?
These activities are permissible in an exempt study, as long as the research will
be taking place in a commonly accepted educational setting and will be examining normal
educational practices. Your application should address the treatment of the recordings.
Consent documents must include specific permissions to audio/video record participants.
Anything else I should know if I'm doing research in a classroom setting?
Yes. If you are obtaining identifiable student records, then Family Educational Rights and Privacy Act (FERPA) regulations apply, as may the Protection of Pupils Rights Amendment (PPRA). For the use of identifiable student records (e.g., grades, scores, homework, evaluations, scanned student work), you must either obtain the direct, written permission of the student (if 18 or over) or student’s parent (if minors), or you must obtain an exception from the local educational agency (LEA) who holds the records.
The responsibility for FERPA and PPRA lie with school districts and other LEAs, rather than with the IRB. More information can be found here:
In most cases, Consent Form A is the appropriate document to use to obtain permission for the use of student records.
More information about research with children can be found at Special Population Requirements.