Frequently Asked Questions
The IRB is authorized to review, approve,
require modifications in, or disapprove human subjects research activities
conducted by or through the College. The following is a list of answers to common questions, however please keep in mind that these responses are general in nature, and each potential research activity has unique features that could impact the answer shown.
Q: How do I know if I should submit an application to the Valencia IRB?
A: You should thoroughly read and understand the Valencia IRB process, including the Federal IRB regulations, particularly focusing on whether the proposed project meets the Federal definition of research. The Federal definition of research is: a systematic investigation which is intended to develop or contribute to generalizable knowledge. If your activity meets this defintion, then an IRB application should be submitted.
Q: What are some examples of intending "to develop or contribute to generalizable knowledge"?
A: Valencia interprets this to be when you intend to use the outcomes of your activity to contribute to an action that is broad in scope. Examples include: submitting an article for publication (including dissertations), developing and delivering a conference or workshop presentation, or contributing to a process that ultimately would impact a decision made by Valencia regarding major programs and services. It does not include routine classroom assignments or the performance of regular job duties.
Q: Who decides whether an IRB application should be submitted?
A: The individual self-determines whether to submit an application to Valencia's IRB based on his/her understanding of IRB regulations and the Valencia IRB process. The IRB Chair and the IRB members may offer guidance, but the individual makes the final decision to submit an application.
Q: If I determine that I don't need to submit an IRB application, may I submit one anyway?
A: Yes. Even if their current intent does not involve contributing to generalizable knowledge, sometimes individuals elect to submit applications so that they receive an official IRB determination "just in case" they decide in the future that they would like to include their activities and data in a project that meets the Federal definition of research.
Q: Do my students need to submit IRB applications if I assign them to do research projects as part of my class?
A: Yes, but only if the projects meet the Federal definition of research.
Q: I think my research
qualifies for “exempt” status – do
I still need to submit an IRB application?
A: Yes. Only the Valencia IRB can officially issue an “exempt” determination.
Q: I don’t know how to answer some of the questions on the
IRB application but I am in a hurry to get started – can I submit
it anyway to begin the process and take care of the details later?
A: No. The application is designed to ensure that the IRB has
sufficient information to make a judgment regarding compliance with
Federal HRP regulations. Investigators who submit incomplete applications
will be informed that their applications will not be reviewed until
all the information is received. Investigators are encouraged to build
sufficient time for IRB review into their research timetable.
Q: May I start on my research before receiving an official IRB determination?
A: Yes, there are certain steps in the research process that you may complete prior to submitting an application to the Valencia IRB, but you cannot begin recruiting participants or collecting data until you receive the official IRB determination for your application.
Q: Do all survey projects have to be submitted to the IRB for review?
A: No. Whether an IRB application needs to be submitted is based on whether the proposed project meets the Federal definition of research; it is not based on the research process.
Q: Must I submit an IRB application if my survey will be anonymous or if the data I'm collecting will be aggregated?
A: Not necessarily. Whether an IRB application needs to be submitted is based on whether the proposed project meets the Federal definition of research; it is not based on the research process.
Q: What happens if I submit my application but the IRB requests changes?
A: The IRB chair, on behalf of the IRB, conducts an initial review
of all applications to determine if the application: (1) is complete;
(2) is eligible for exemption; (3) is eligible for expedited review;
or (4) must receive full IRB review. Based on the Federal regulations,
changes to the application may be requested in any of these situations.
If changes are needed to meet compliance requirements, a detailed
explanation is provided; a determination cannot be issued until the
investigator submits additional information and/or materials that satisfy the changes requested.
Q: Does receiving an “exempt” determination
mean that I do not have to worry about informed consent?
A: No. All research projects that receive a determination of “exempt” or “approval” (expedited
or full) must still comply with informed consent requirements. Projects
that do not fall under the Federal definition of research involving
human subjects are not required to comply with Federal informed consent
regulations, although compliance is encouraged.
Q: What is a waiver of informed consent?
A: A waiver of documentation of informed consent may be requested at
the time of application if the research project meets certain conditions
(see Section 2 of the Informed Consent section of the IRB application
package). However, this waiver only means that the participant’s
signature is not required on the informed
consent form – informed consent is still required.
Q: How long is IRB approval good for?
A: When you submit your application, you can request any period of
time up to 10 years. Based on Federal regulations, projects longer
than 12 months that receive approval under the expedited or full
review process will be required to submit periodic reports (minimum:
annually) as a condition of approval. Q: Someone has asked me to participate in his/her research. How do
I know it has been through IRB review?
A: IRB review is documented by a stamp placed on informed
consent forms submitted at the time of application. The stamp contains the IRB application number assigned to the project and the determination given. If no stamp is evident on the informed consent document that you receive, you can send an email to irb@valenciacc.edu
and ask if an IRB application has been submitted for the project in
question.
Q: Who should complete IRB training?
A: Regulations require that investigators administering research that
has been approved via either expedited or full review must complete
training in a timely manner as a condition of the approved research.
However, individuals may complete training even if no research is
currently planned.
Q: What will I learn in Valencia’s
IRB training?
A: HRP/IRB training is being offered through Leadership Valencia. Part
I (2 hours) provides an overview of human research protection and
how our IRB works with an aim to be as unintrusive as possible while
complying with Federal regulations (completion of this workshop satisfies
the IRB training requirement for investigators of approved Valencia
projects). Part II (1 hour) walks through the Valencia IRB application
process (Part I is a recommended prerequisite).
Q: Do I have to take Valencia’s
IRB training if I completed IRB training elsewhere?
A: Federal regulations indicate that other formal IRB training may
satisfy the training requirement imposed on investigators of approved
research protocols as long as the training was completed within the
past three years. Q: What happens if my application is disapproved?
A: Before a determination is issued, the IRB strives to communicate with PIs to request or suggest modifications that will bring the application into compliance as needed. Should an application be subject to full review by the IRB, and the Board issues a disapproval, the determination cannot be overidden based on Federal regulations. Based on the pre-determination communication process with PIs, Valencia's IRB does not have an appeals process.
Q: Can I still do my research if my application is disapproved?
A: Technically, yes, but not without consequences. The IRB process
is designed to place the burden on the investigator – just
as with any regulation or policy, ultimately it is the individual’s
responsibility to comply. Investigators are expected to submit an
IRB application, to comply with the regulations when the application
is approved, or to not proceed if the application is disapproved.
Receiving a disapproval from the IRB cannot physically stop an investigator
from moving forward if he/she so chooses; the IRB can only exempt,
approve, disapprove, or terminate IRB approval. However, it is important
to be aware that a disapproval or the absence of a formal IRB determination
from Valencia’s IRB means that the researcher will not be protected
from any individual risk or liability that IRB approval provides.
In addition, the investigator will be at risk for not having their
study accepted for publication or presentation. Also, by having a
process whereby a summary of IRB applications and determinations
is shared, the Valencia community is informed and thus may take any
action that they believe is appropriate separate from the IRB application
process. Q: I have agreed to serve as a project director on a Valencia grant.
Do I need to submit an IRB application?
A: IRB review of research conducted as part of institutional grant
proposals is now integrated into the final review process before grants
are submitted to the 17 Federal agencies that have agreed to follow
the Common Rule regarding Human Research Protection. As a result, project
directors should follow the direction given to them by the Office of
Resource Development.
Q: How long does it take to receive a determination after I submit my application?
A: We request that applications be submitted at least 3 weeks prior to the start date indicated in the application. The timing of the determination will vary based upon the completeness of the application, current workload, whether the application is subject to full board review, and other factors. PIs should not begin the participant recruitment process until they receive their official IRB determination, but they may work on other aspects of their research while waiting.
Q: Does Leadership Valencia IRB training count towards the Professional Development component of the faculty compensation plan?
A: Yes. The faculty member must obtain proof of attendance/completion from Leadership Valencia. Full-time faculty must upload that evidence into their online Professional Development planner under Faculty Tools in Atlas. Part-time faculty must send the proof to Patrick Nellis, Director of Faculty Development, at Mailcode 3-30. |