The Regulatory Citation and How It Applies:
“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.” (§46.101(b)(1))
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 considered a “normal educational setting”.
This category does not apply to Food and Drug Administration (FDA) regulated research.
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.
Examples of Research Exempt under Category 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 3rd 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.
- A study evaluating homework stress by interviewing 8th 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.
- A study that randomizes students into two different class sessions that will utilize different teaching strategies.
Examples of Research NOT Exempt under Category 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).
- Research involving pharmaceutical interventions or unusual medical tests (e.g., genetic testing of students reporting high math anxiety levels, MRI studies in individuals learning to read).
- 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.
FAQs Regarding Category 1 Exemption
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. For the use of identifiable student records (e.g., grades, scores, homework, evaluations), you must either obtain the direct, written permission of the student (if adults) or student’s parent (if minors), or you must obtain an exception from the local educational agency who holds the records. For UMKC education records, contact the UMKC registrar at firstname.lastname@example.org for information regarding the applicability of FERPA or to obtain an exception to obtain permission. In all cases, include the approval from the appropriate registrar in your application to the IRB.
What if my research involves student surveys?
A survey of minors may be permissible within the constraints of a Category 1 exemption if a researcher was surveying students regarding the normal educational practice being studied. For example, if a researcher was evaluating the reading curriculum and wanted to survey 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 survey of students’ fitness and after-school behavior, then it would not be permissible under Category 1 exemption.
What if my research involves video/audio recording classroom lessons or observing teacher/student interactions?
The exemption criteria say nothing specific about video/audio recordings or teacher/student observations. These activities are permissible in a Category 1 exemption, so 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 minimization of data collection on the minors and address the final disposition of the recordings.
Consent documents must include permission to audio/video record participants, even if the school has obtained approval from parents for videotaping or audiotaping children.