Determining Whether Classroom Activities Require IRB Oversight

Activities taking place at Rice University include not only world-class research but also a range of educational activities. Some of these activities qualify as research with human participants or data and, per Rice Policy 326, require IRB oversight. Other activities do not qualify as research and hence do not require oversight. Many instructors have expressed some uncertainty about whether their classroom activities qualify as research.

To address this gap and to help instructors make this decision, the IRB Chair and the IRB Administrators have developed additional guidance and a self-serve form that can be used for each of their classes. The IRB Oversight Determination Form can be accessed here. Additionally, IRB Administrators are happy to help any instructors who would like assistance making this determination. They can be reached by email or by phone at 713-348-4820.

Basis for Determination

Classroom activities are considered to be research (and hence require IRB oversight) on the basis of definitions found in Rice Policy 326 and federal IRB regulations if the intention is to conduct research. There are two criteria for this determination, and both must be met.

First, the goal of the activity is for the students to generate new, generalizable knowledge.

Second, the activity must involve obtaining information or biospecimens through interactions or interventions with human participants or private identifiable information or biospecimens.

If, and only if, both conditions are met, IRB oversight is required and an IRB protocol must be filed. If either criterion is not met, then oversight is not required. Additional clarifying information for making this determination can be found on the IRB Oversight Determination Form.

Recommendations for Instructors Determining Their Activities are Not Research

The IRB makes two recommendations for any instructor who has determined that their class activities include students collecting data from human participants and/or using private, identifiable data but makes the determination that their classroom activities are not research.

• Include a statement in your course syllabus that students' data and conclusions cannot be used or presented outside of the course, whether in publicly available senior theses, websites, blogs, social media, conference presentations, or journal articles. Such a presentation is more characteristic of the provision of information to the pool of human knowledge, which is the intention of research.

• Students using private, identifiable information, or who are interacting with members of the public outside of their class, should receive appropriate training through CITI. Although this training is not formally required for non-IRB activities, taking this training will prepare students for the responsibilities associated with human participants and confidential data.