Overview

There are some common ways to collect or use information from people that are “exempt” from some of the bureaucratic processes, but still do require you to inform the IRB and receive confirmation that your plans are indeed “exempt” from further review.

The two most common categories that are “exempt” are when you get information from people as a “journalist” or as a “product tester” but not as a “scientist.” Here are examples to make this clearer:

• Exempt “journalist” activity, as it might be described in an undergraduate capstone: “To gain more understanding about the resources available for people learning a new language, and how they could be improved, I spoke with a software engineer at Duolingo. As she describes…and therefore in my app I decided to…”
• Exempt “product tester” activity: “To iterate on the design of my app, I asked 5 people in my target audience to use it and report which parts of the design would be most confusing for people trying to learn a new language. Based on their feedback, I made the following changes to my app…”
• Non-exempt “scientist” activity: “I asked a sample of 20 people to fill out a survey about which features they would find most attractive in a language-learning app. Based on their results, I concluded that people generally like apps that… and therefore designed my app to…”

The difference between the exempt and non-exempt examples is fundamental and important, even if they seem similar at first glance. As a “journalist” you are asking experts to share what they already know, and as a “product tester” you are actually doing something very similar (as members of your target audience, the people you ask are experts, and you are interviewing them about the product and NOT themselves). In contrast, as a “scientist” you are attempting to make new claims about humans (i.e., discover new things no one has ever known), and then you apply these general claims to your specific case.

Note that, for exempt projects, your questions need to be phrased as being about the TOPIC rather than about the person you are asking. For example, “Which parts of the app design would be most confusing for people trying to learn a new language?” is fine in an exempt project, but “Which parts of the app design did you find most confusing” makes it about the person you are asking, and so likely NOT exempt.

Given that “journalist” and “product testing” projects are not about the people you are asking, you will need to justify any information you collect about your informants. For example, “I made sure to ask both novice and intermediate language-learners to get a variety of perspectives” is fine, but “I found that novice language-learners are more likely than intermediate-learners to find feature X confusing” is making a general claim about humans, and so not allowable in an exempt project (it would require one of the below categories of review).

If you think your project will be exempt, you will answer a series of questions so the IRB can confirm your project’s exempt status. Appendix B of this document has the list of the questions you will be asked, along with sample answers. Please draft your answers carefully before copying them into the form you submit to the IRB. In other words, please put time and thought into composing your answers, and do not just type “stream-of-consciousness” into the form. Here is a link to the form. We try to process these as quickly as we can (typically within 5 business days).

Finally, please note that “exempt from further review” still allows you to chat with the IRB if and when you want further review or consultation. We welcome Minerva affiliates contacting us to chat about best practices during the design and implementation of projects with people–we likely won’t be experts on the specific topic you are investigating, but can be a resource to discuss #ethicalconsiderations, data protection, etc.

Before you pursue expedited or full review, you should look at Appendix A: Are You SURE Human Subjects Research is the Best Use of Your Time?

Notably, once you enter the world of having a “reviewed protocol” you will need to do lots of additional work. For example, before you receive approval you will need to:

• complete online training about the protection of human subjects (we will tell you where to go to do this),
• develop a process by which your participants learn about the project and document informed consent to participate, and
• develop a robust plan for handling participant data that meets various requirements.

Then, over time, you will need to provide official updates to the IRB about the progress of your project, including some summary information after it ends (most notably, how many participants you ended up collecting data from).

There are two types of review: full, and expedited. To be eligible for expedited review, a project needs to be a low-risk social science investigation, likely involving self-report measures (e.g., a standard questionnaire for measuring extraversion) and/or behavioral measures that involve behaviors that could be part of everyday life (e.g., a task in which someone decides how to donate ten euros to different charities). It cannot involve vulnerable populations (for example, children or prisoners), deception, or different compensation for different participants.

Compared to Full Review, the biggest advantage of expedited review is that it can be done by just one of the IRB members, rather than requiring all of the members to discuss the project. Thus, it is usually the case that expedited review can happen more quickly than full review, usually within 10 business days.

At this time, we have not yet implemented web forms to collect information for expedited review. If you think your project may need expedited review, send an email with a brief description of your project to hsr@minerva.edu (though we expect to implement online forms soon – so you can also just wait a couple of weeks for the web forms).

Full review means that your planned project is likely the sort of thing the MU IRB can review and potentially approve, but that doing so will require that the entire IRB meet to discuss it first. Given that the MU IRB only reviews and potentially approves relatively low-risk social science protocols, we expect only a small percent of projects to fall under full review: most will be either exempt, expedited, or not possible to review.

Here are the sort of things that we can potentially approve, but that will likely require full committee review:

• projects with people under age 18
• projects that offer different compensation for different participants (e.g., a study on motivation in which participants are told "if you score in the top 10% of this measure, we will double your compensation for participating!")
• projects that involve deception (e.g., "Thanks for participating in this study! I know we told you that it was about art preference, but actually we were interested in where you chose to sit in the room to look at different pieces of art. There were people in the room of different races, with different accents and languages, and of different genders. We are not assuming anything about you based on where you sat, but by combining your information with 99 other participants, we can see if there are patterns about where people generally sit. So we were interested in this social question, and not actually your art preferences, but we couldn't tell you that or it would have messed up the study.")

Because full review requires the entire IRB to review your plans and discuss them, it is possible that full review will take more than a month. If you think your plans might need full review, it will be useful to let the IRB know as soon as possible, so that we can schedule a meeting to discuss your plans (i.e., let us know even before you are ready to submit your plans).

At this time, we have not yet implemented web forms to collect information for expedited review. If you think your project may need full review, send an email with a brief description of your project to hsr@minerva.edu (though we expect to implement online forms soon – so you can also just wait a couple of weeks for the web forms).

There are some projects that we know we cannot approve, even with full review. For example, let’s say that you have an excellent idea for an experiment in which you will give people either cocaine or a placebo, and then measure their pain sensitivity to electric shocks. It is possible that a medical school would have an Institutional Review Board with expertise to evaluate and potentially approve your study, but we at the MU IRB do not have that expertise. We are set up to evaluate and potentially approve only relatively low-risk social science protocols.

Thus, there are types of research you are NOT allowed to pursue as a Minerva affiliate (though you might be able to work with other institutions to do research we cannot review… you just wouldn’t be doing so as a Minerva affiliate, but rather as an affiliate of whatever other organization you affiliate with for this goal).