General Questions

Questions Regarding IRB/HSRB

Questions Regarding Recruitment

Question Regarding Consent/Assent Materials

Questions Regarding Proposal Submission

Questions Regarding Notification and Access

General Questions - Answers

How many research proposals will MMSD approve per year?

MMSD receives a large volume of research requests and while there is no official cap on approvals, the district’s capacity to accommodate all proposals is limited. Because research facilitation and administration requires a great deal of effort and resources, MMSD will use its discretion in determining which research activities will be approved.

How long does the ERC review process typically take from proposal submission to final approval?

Processing time varies depending on the complexity of the proposal, initial outcome of the review process, and the speed with which researchers respond to requests for revision or further information. MMSD makes every attempt to notify researchers as soon as possible after the committee review date; this typically occurs 10 days after the committee meeting date. Estimated notification dates are posted on the ERC website. Once conditional approval is received, research staff must then undergo criminal record checks and sign confidentiality and mandatory reporting statements. This process cannot be completed until applications for all team members AND the processing payment are submitted. As an overall estimate, projects that require minimal modifications and where research staff move quickly to submit documentation can move through the approval process and begin research around six weeks after the proposal submission date.

IRB/HSRB Questions - Answers

Why do I need both IRB/HSRB and ERC review?

IRB/HSRB and ERC review serve different, but complementary purposes. IRB/HSRB review is undertaken by the sponsoring institution; as such, it is approval from the researcher’s institution to conduct the project. ERC review, on the other hand, is undertaken by the research site; as such, it is approval by MMSD to conduct the project at our location(s). IRB/HSRB review focuses primarily on issues regarding human subjects and risk. While the ERC's process safeguards the rights of staff, students, and other stakeholders in the district, it also considers the quality of the research design and benefit to the district of participating in the project. ERC requires IRB/HSRB review prior to submission to ensure that studies are in compliance with ethical standards and federal guidelines for research conduct before MMSD considers the project.

May I apply for ERC review with the condition that I will apply to the IRB/HSRB if approved?

Please note that the ERC is NOT an Institutional Review Board (IRB) or Human Subjects Review Board (HSRB) and will not review proposals without documented IRB/HSRB approval, unless IRB/HSRB approval will not be required for the project. 

ERC review occurs after review by an IRB or HSRB, as appropriate. While many IRBs/HSRBs cannot grant final approval before the researchers obtain site approval, they can accommodate review by reviewing the work and issuing a conditional approval (placing an administrative hold on the final approval until site approval has occurred). This type of conditional approval is enough to allow ERC review, although final IRB/HSRB approval must be submitted prior to the commencement of research activity at MMSD sites. Please check with your individual IRB/HSRB for their policies. 

Do I need ERC approval for a research study done for a graduate or undergraduate class, even if I am not required to go through the IRB/HSRB process?

In general, researchers should obtain ERC approval whenever the project involves the collection of data from or about our students, staff, and families that is not publicly available. The ERC review process allows the district to identify the potential risks of the work,  weigh whether the benefits of the work justify the time spent and potential risk, and determine whether there is time, capacity, and interest to properly support the researcher in this project. For class projects that do not require IRB/HSRB approval, researchers should still submit a proposal to ERC and specify the institution, course name and number, supervising faculty, and any description of the assignment that could help ERC members better understand the scope of the project.  

Is there anything I should know regarding ERC and conducting action research as part of a degree program?

Any proposed action research study that is required by an outside institution as part of a degree program must meet the following criteria in order to be conducted in MMSD:

  • The study benefits MMSD and study results are shared with school colleagues and central office.
  • The study reflects high quality action/teacher research practices such as: context-specific research questions, a focus on improving the teacher-researcher’s pedagogical understanding and/or instructional practice, logical and coherent connections between all elements of the study (context, question, data collection and analysis methods, conclusions, and next steps).
  • The proposal and study are supervised by a knowledgeable, qualified mentor from the sponsoring institution who guides the researcher in meeting procedural and ethical criteria for quality action/teacher research as well as district expectations.
  • The proposal is reviewed, edited, and approved by the mentor from the sponsoring institution before it is submitted to ERC.
  • Active or informed consent letters must be sent to all involved stakeholders per MMSD guidelines.
  • The rights and identities of all involved – researcher, other staff, children, schools, and families – are appropriately protected.

If my research is certified by the IRB as not being human subjects research, do I still need to prepare consent/assent materials for the ERC?

Yes, you still need to prepare consent/assent materials in order to be compliant with MMSD policy, but you should not use the standard template of an IRB. For example, you should not refer to your project as "research" and do not provide IRB contact information. You should describe your project, explain what participation involves, identify any anticipated risks or benefits, explain how confidentiality will be protected, and provide contact information for the researcher to answer questions. Participants still need to actively consent to participate in a project, even if it is certified as non-human subjects research.

Recruitment Questions - Answers

May I reach out to MMSD principals and/or teachers to gauge interest in a project before applying for ERC review? 

To ensure MMSD oversight and centralization of project management, researchers should not contact individual principals, teachers, staff, etc. about research planning or coordination. Researchers should not contact building staff prior to submitting a research request to the ERC. If you have preferences about where or with whom you want to work, please state this in your proposal.

Do I need to submit to ERC if I want to conduct a research project at the school where I work and the principal is already aware?

All research projects must undergo ERC review, even those conducted by MMSD staff, to ensure district resources are being used strategically and that the district is aware and able to support the work of all staff.

Do I need to go through ERC review if I am recruiting participants from MMSD, but the research will take place outside of school hours and not involve class activities?

MMSD requires review of all projects that target MMSD staff, students, and families for recruitment, even if the study is not related to education or does not take place during school hours. Because researchers are identifying these people as members of MMSD, ERC needs to review the proposals. If a researcher were looking to the general public – which includes MMSD staff, students, and parents – it would not be an issue, but targeted recruitment requires review.

Do I need to go through ERC approval if I plan to use publicly-available MMSD email addresses to recruit participants in my study?

MMSD requires review of all projects that want to recruit MMSD staff and students using their MMSD emails. Because MMSD is a public entity and public dollars fund the email system, that email is considered property of the district. Therefore, targeted recruitment using MMSD email addresses requires review.

I want to recruit MMSD staff to participate in my research project outside of contract hours.  Since the project will happen outside that time, do I need to go through ERC review?

MMSD requires review of all projects that want to recruit MMSD staff participation, even if that participation is outside of contract hours. As MMSD employees, these people are representatives of the district, and projects that recruit them because they are employed with MMSD must be reviewed.

May I target recruitment materials to specific student populations?

ERC allows for targeted distribution of student recruitment materials by grade, school, and class. For example, a researcher can choose to distribute recruitment materials to ninth grade students at La Follette High School in fourth-hour English/Language Arts classes. ERC does not allow targeted recruitment of specific student subgroups, such as targeted recruitment by race/ethnicity, free/reduced lunch status, gender, special education status/specific disability, or English Language Learner status. For example, a study that requires participants to be African-American students can choose to send recruitment materials via backpack mail to the ten schools with the highest percentage of African-American students. In their recruitment materials (e.g., consent form, informational letter), they would specify that they are looking for students who are African American to participate in the study, and ask students and parents to contact the study team if they believe their child fits this description. In other words, you can include inclusion criteria in your recruitment materials.

May MMSD staff help with the recruitment process by identifying potential participants, distributing and/or collecting consent forms, or providing contact information for students and/or families for targeted follow up?

In general, MMSD staff may not help with the recruitment process for approved external research projects. External research projects are considered activities outside of MMSD; as such, MMSD staff should not take an active role similar to that of a research team member. The exception to this rule is the distribution of recruitment materials via backpack mail, where MMSD staff can distribute recruitment materials to all students within a particular school, grade, or class. When submitting an ERC proposal, researchers should specify a recruitment plan that does not involve MMSD staff in the identification of potential participants, distribution and/or collection of consent forms, or compilation of contact information for targeted follow up. For example, a study can choose to distribute recruitment materials to all students via backpack mail. In those materials, they would ask interested students and families to contact the research team directly via email, phone, or by mailing the consent materials back in an already addressed, stamped envelope.

Consent/Assent Materials Question - Answer

Unless otherwise authorized by the ERC, researchers at a minimum, shall provide the following information to each participant:

  1. A statement that the study involves research, an explanation of the purposes of the research, estimation of the expected duration of the participant's research activity, a description of the procedures to be followed, and identification of any procedures that are experimental;
  2. A clear description of any reasonably foreseeable risks or discomforts to the participant;
  3. A clear description of any benefits to the participant or to others that may be reasonably be expected from the research;
  4. A statement describing the extent, if any, to which confidentiality of records identifying the participant will be maintained;
  5. A statement that participation is voluntary, refusal to participate will involve no penalty or loss of benefits to which the participant is otherwise entitled, and the participant may discontinue participation at any time without penalty or loss of benefits to which the participant is otherwise entitled.
  6. If applicable, a statement informing parents that video and/or audio taping of students will take place and a place on the consent form for parents to give active consent to the recordings.  Typically this is done with a check box or boxes and relevant language contained in the consent form signed by the parent.  (The consent letter must also clearly state what measures will be taken by the researcher if the image or voice of a student without consent is captured by a recording device.)
  7. If the research protocol includes a survey instrument administered to students, consent forms must clearly state that parents have the right to preview the survey before they provide consent.  The consent form must also state how the parent may preview the survey. Providing the preview is the responsibility of the researcher; MMSD will not provide copies of these surveys to parents.
  8. The name, address, phone number and institutional affiliation of the researcher, including the principal investigator's contact information if the researcher is a student; and,
  9. A statement indicating IRB contact information.

When research involves more than minimal risk, an explanation about whether there is compensation available and an explanation about whether any medical treatments are available if injury occurs and, if so, what they consist of, or where further information may be obtained must be included.

Proposal Submission Questions - Answers

May I pay MMSD staff to participate in my study?

Projects cannot compensate MMSD staff for work done during contract hours.  Projects may choose to compensate MMSD staff for participation if it is for work done outside of contract hours. If projects would like to compensate MMSD for time allowed to complete research-related activities during contract hours, they may choose to provide a donation to the schools. It is important the researcher clearly indicates in consent and research materials if research will be conducted during or outside of contracted hours.

Will the district approve proposals that include free/reduced lunch status as part of requested administrative data?

Reflecting state and federal regulations, MMSD cannot freely disclose who receives free and reduced price lunches. 

To obtain this information, consent forms must explicitly state a researcher’s intent to obtain this information, that the information will be used only for the research indicated and will not be re-disclosed, and that failure to sign the consent will not affect the student’s ability to participate in the school lunch program. The signed consent form must also specifically request that MMSD provide the lunch status information to the researcher. Free/reduced lunch status may be shared only for students who return signed consent forms if and only if all of these conditions are met.

Will MMSD approve a study that uses instructional time to conduct research activities (e.g., implementing a science video game during science class, pulling a student from class to complete a survey, etc.)?

No instructional time can be used for research activities. All research interventions planned to take place during regular instructional time must be approved by MMSD as standard curriculum. If it is not approved curriculum, it will not occur during instructional time. Consent/assent materials and other research materials must specify if the work is being done outside of instructional time or if it part of MMSD's standard curriculum.

Note that non-instructional hours include before or after school and recess. The ERC strongly prefers that researchers avoid meal times (e.g. lunch) for student participation in research. 

May MMSD provide copies of consent forms in Spanish or other languages?

Given that preview is the responsibility of the researcher; MMSD will not provide copies of these surveys to parents or provide translation services.

Notification and Access Questions - Answers

What are the responses I can receive from ERC?

Researchers may receive one of five responses from ERC: 1. Incomplete/Not Reviewed – Before proposals are sent to the committee, they are reviewed to ensure all elements of the proposal have been submitted. If they are not complete (e.g., missing IRB approval, missing consent forms), ERC staff will notify the researcher that the proposal will not be reviewed by the committee. Researchers can resubmit to the next committee meeting. 2. Conditional Approval – The committee determines the project is complete and can be approved without modifications. The researcher can then move forward to complete the CMR and CRC process on the way to final approval. 3. Modifications Required – The committee determines the project is of interest to the district and can move forward, but first requires modifications be made to the proposal materials. The researcher receives a letter outlining necessary changes, which can be submitted via email to ERC staff. Once all modifications are approved, the proposal moves to conditional approval. 4. Tabled – The committee determines that the project is of interest to the district, but cannot move forward without significant revisions that must be reviewed by the committee at a future meeting. The researcher receives a letter outlining the outstanding issues that must be resolved for the project to move forward. The researcher can then resubmit to a future ERC review date for reconsideration. 5. Rejected – The committee determines that the project cannot be approved by the district. The researcher receives a letter outlining the reasons why the project cannot be approved at this time. The researcher can resubmit to a future ERC review date, if desired, but the project would need to look substantially different from the one that was rejected.

My proposal was tabled by ERC, but I'd still like to move forward. What are my next steps?

All tabled proposals must be resubmitted for committee review. Researchers should complete a new ERC project application with the modified project information. In addition, they should email ERC staff with the Tabled letter and the attached response. All details are outlined in the initial Tabled letter.

My study only requires distribution of recruitment materials in MMSD, and I will not have any contact with students at MMSD.  Do I still need to complete the CMR and CRC requirements?

Researchers on ERC-approve studies that are designated recruitment only - where researchers will not have any contact with students in the school and are just looking to distribute recruitment materials in MMSD for an off-site study that has nothing to do with MMSD - are exempt from the CMR and CRC requirements.

Do I need to complete a CMR and/or CRC if I have completed one for a previously approved project?

If you have completed a CMR and/or CRC for another project approved within the current academic year, you do not need to complete them again. Instead, you can notify ERC staff that this requirement has already been fulfilled and indicate the ERC proposal number. If you completed a CMR and/or CRC for another project that was approved during a previous school year, you will need to submit this paperwork again.

Do I need to complete a CMR and/or CRC if I am an out-of-state researcher?

Yes, out-of-state researchers are required to complete the CMR/CRC requirement if they are actively involved in data collection and/or analysis with identifiable student information. If you have questions regarding this requirement, please contact ERC staff.