Teacher Action Research

Exemption Category 1 Research

DEFINITION OF EXEMPTION CATEGORY 1 RESEARCH

“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.”  (45 CFR 46.104  2018)

TIPS FOR DESCRIBING EXEMPTION CATEGORY 1 RESEARCH

The key to writing a successful Exemption Category 1 IRB application is understanding and explaining the distinction between what is the teaching intervention and what are the research activities. 

Teaching intervention activities are NOT the research as long as they are REQUIRED OF ALL STUDENTS as part of their regular class experience. These frequently include pre and post tests and class satisfaction surveys that would be used by an instructor for regular evaluation of course or module efficacy.

The research is the evaluation of the teaching (or classroom management) technique. Research activities are VOLUNTARY, such as

  • Using the results of pre and post activity tests
  • Using class satisfaction surveys
  • Using grades, tests, and other course products like journals or other assignments.
  • Observing individual behavior in class.
  • Asking students to complete optional activities/surveys. Note: equivalent educational activities must be available to students who are not participating in optional research activities.  These must be discussed in the Methodology section of the application.

IRB APPLICATION SECTIONS AND UPLOADS

Methods and Procedures

Copy and paste the following questions into the Methods and Procedures application section.

For help in writing this section refer to the language in the Parental Permission - Exemption Category 1 for pre-K-12 research or the Adult Consent - Education Research - Exemption Category 1 for college courses or other educational research.

  1. Address who is the classroom instructor and the educational setting.
  2. Provide a brief description of the mandatory classroom intervention (activities)and pre and post tests. This classroom activity is not the research but provides context.
  3. List and explain the research activities or class products/activities that will be used for your research. Remember, the use of these data and/or participation in these activities must be optional (voluntary).
  4. Explain if your research requires that data be matched for individual students.
  5. If there are activities that are not required of all students, explain
    1. How you are avoiding undue influence or coercion if you are the classroom teacher. Students or their parents may feel that they have to participate in order to maintain a good relationship with you or maintain good grades.
    2. What the students will be doing who do not have parental permission
  6. If you are observing the students, describe the behaviors you are looking for and upload a copy of the rubric, and note that the observations will not interfere with student learning.
  7. If you are using pre-existing data, (i.e., from past semesters or classes) explain how you have access to that data (e.g., you are the class instructor), what data you are using, and specify that you will be de-identifying the data prior to use in your research.

Expected Time Commitment

Class time and time spent on required class activities do not count as research participant time. You will be using course products as the data.

Are you collecting data anonymously?

  • If you are the classroom instructor, the answer to this is “no” unless you are only using anonymous surveys for your data collection. 
  • If you are not the classroom instructor,
    • The instructor de-identifies the data prior to giving it to you, then this is “yes.” Strongly recommended.
    • The classroom instructor gives you the data with personal identifiers, the answer is “no.” Explain why you need to have personal identifiers.

Will the participants be identifiable in the database used for the research?

See the IRB Standard Operating Procedures on Data Security.

  • It is strongly recommended that you de-identify the data before storing it as your final research dataset. There are very few reasons to keep identifiable data (an example would be a longitudinal study where participants need to be contacted at a later date).
  • Digital research data must be kept in secure cloud storage, not on any personal device, flash drive, or non-College of Charleston computer. If the data or consent forms are paper copies, they must be securely stored in a College of Charleston Department Office. Teachers should not store research data in their schools.

Recruitment through another institution?  This means an institution other than the College of Charleston.

  • PreK-12 - check with the school regarding requirements. Public School Districts often require District approval rather than just the Principal (e.g., CCSD: https://www.ccsdschools.com/Page/1238). Requirements at Private Schools vary depending on their structure.
  • Colleges and Universities – check with the IRB Coordinator concerning whether a Reliance Agreement may be appropriate.
  • Other Educational Activities – you will need to secure a letter of cooperation from the organization’s administration.

Informed Consent - Minors

NOTE: The IRB does not allow passive permission.  This is assumed parental permission where a parent receives only an informational letter or is told to notify the researcher if permission is not granted (i.e., opt-out).  There is no way to know if the parent has even received the information, let alone agrees to their child’s participation.  If getting parental permission is not practicable (inconvenience will not be accepted as a reason), apply for a Waiver of Informed Consent.

  • If there are research activities that are not required class activities, you must get parental permission.
  • If your research involves only using class products, check with the school or school district (CCSD prefers signed parental permission) to see if parental permission is required to use test results or other class materials for your research project. These must be de-identified prior to being used for your research.  If permission is required, upload a parental permission form following the Parental Permission - Exemption Category 1 template and the age appropriate Student Assent template (elementary age or middle/high school age.)
  • If parental permission is not required
    • State this clearly in the methodology section of the IRB application and be sure that the principal/school district letter includes that information.
    • For the consent upload, include a document stating that parental permission is not required by the school.

Informed Consent – Adult Students

Use the Adult Consent- Education Research (Exemption Category 1) template.

Informed Consent - Pre-existing Data

No consent is required if the data are de-identified.

Waivers of Informed Consent Section

  • Oral/Verbal informed consent/parental permission is preferred to signed consent when dealing with a sensitive population such as undocumented immigrants or when working in a foreign country where the population is suspicious of signed documents or where those documents could place them at risk.
  • Waiver of Informed Consent
    • A strong case for a requested waiver of consent or parental permission is needed. The IRB will not accept “inconvenience” as a reason.

Required Uploads

  • DO upload:
    • Tests, surveys, observation rubrics, and assignments that are not part of regular course work.
    • All required consent forms as appropriate to your research.
  • DO NOT upload:
    • Tests, surveys, or assignments that are part of the regular course work.
    • Research proposal descriptions, except for external (not CofC funded) grant applications.

Questions?

If you have any questions, contact the IRB Coordinator at compliance@cofc.edu.

Created: January 18, 2015

Revised: March 30, 2023