IRB review - ICF

DATE:

May 10, 2019

TO:

Dana Keener Mast; Isabela Lucas

FROM:

Carole Harris, IRB Chair

SUBJECT:

IRB Determination – Exempt

PROJECT #:

141708.0.007.00

PROJECT NAME:

EVALUATION OF THE DP18-1801 HEALTHY SCHOOLS PROGRAM

ICF’s IRB has reviewed the description and supporting materials submitted for the project reference
above and determined that the activities qualify for the Exemption identified below. Note that changes
to your project activities may alter the Exempt determination. Contact the IRB prior to implementing
any changes to discuss whether re-review is needed.
2018 Common Rule Exemptions
Research involving children is allowed in categories 1, 4, 5, 6, 7, & 8. Limitations/exclusions of children apply in
categories 2, 3. Research involving prisoners is allowed under all categories only when prisoners are incidentally
included. To qualify for exemption, the research must align with the following categories and involve only minimalrisk1 to subjects.
Category

Exemption

☐ 1.

Research involving education practices. Research involving normal education practices and instructional
techniques used in classroom management; conducted in established education settings.

45 CFR
46.104.1
☒ 2.

45 CFR
46.104.2

Research involving only educational tests, surveys, interviews, observation of public behavior. (1, 2, or 3
must apply)
☐ 1. Recorded information cannot readily identify the
subject (directly or indirectly/linked)
☒ 2. Any disclosure of responses outside of the research
would NOT reasonably place subject at risk (criminal,
civil liability, financial, employability, educational
advancement, reputation)
☒ 3. Recorded information includes identifiers (and may be
sensitive) but adequate privacy and confidentiality
protections are in place.

1

Minimal risk: defined as the probability and magnitude of physical or psychological harm that is normally encountered
in the daily lives, or in the routine medical, dental, or psychological examination of healthy persons

9300 Lee Highway • Fairfax, VA 22031 • 703-934-3000 • 703.934.3740 fax • icfi.com

EVALUATION OF THE DP18-1801 HEALTHY SCHOOLS PROGRAM
May 10, 2019
2018 Common Rule Exemptions
Research involving children is allowed in categories 1, 4, 5, 6, 7, & 8. Limitations/exclusions of children apply in
categories 2, 3. Research involving prisoners is allowed under all categories only when prisoners are incidentally
included. To qualify for exemption, the research must align with the following categories and involve only minimalrisk1 to subjects.
Category

Exemption

☐ 3.

Benign behavioral interventions. Research with adults limited to verbal or written responses, data entry
or audiovisual recordings where adults prospectively agree.

45 CFR
46.104.3

☐ 1. Recorded information cannot readily identify the
subject (directly or indirectly/linked)
☐ 2. Any disclosure of responses outside the research would
NOT reasonably place subject at risk (criminal, civil
liability, financial, employability, educational
advancement, reputation)
☐ 3. Recorded information includes identifiers (and may be
sensitive) but adequate privacy and confidentiality
protections in place.

☐ 4.

45 CFR
46.104.4

Secondary research use of identifiable Information or identifiable biospecimens. Data were (or will be)
collected for other research. Consent for current project not required.
☐ 1. Biospecimens or information are publically available.
☐ 2. Recorded information/biospecimens cannot readily
identify the subject (directly or indirectly/linked)
☐ 3. Use of data is regulated under HIPAA as healthcare
operations, research, or public health research
☐ 4. Research is conducted by/on behalf of federal agency
using data collected for non-research purposes

☐ 5.

Public benefit or service programs.

45 CFR
46.104.5

Research designed to study, evaluate, improve or examine public benefit/service programs, if the
research is conducted by or supported by a federal department or agency

☐ 6.

Taste and food quality. Research limited to food taste and food quality evaluation and consumer
acceptance studies.

45 CFR
46.104.6

☐ 1. Consumption of wholesome foods without additives
☐ 2. Food contains food ingredient(s) at or below the level
found to be safe, or agricultural chemical or
environmental contaminant at or below the level found
to be safe, by the FDA, EPA, USDA.

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EVALUATION OF THE DP18-1801 HEALTHY SCHOOLS PROGRAM
May 10, 2019
2018 Common Rule Exemptions
Research involving children is allowed in categories 1, 4, 5, 6, 7, & 8. Limitations/exclusions of children apply in
categories 2, 3. Research involving prisoners is allowed under all categories only when prisoners are incidentally
included. To qualify for exemption, the research must align with the following categories and involve only minimalrisk1 to subjects.
Category

Exemption

☐ 7.

Storage or maintenance of identifiable private information or biospecimens. Can only be used with:

45 CFR
46.104.7

☐ 1. Broad consent from subjects for storage, maintenance,

☐ 8.

Secondary research with identifiable private information or biospecimens. Can only be used with:

and secondary use of their materials.
☐ 1. Broad consent from subjects for storage, maintenance,

45 CFR
46.104.8

and secondary use of their materials.
☐ 2. Documentation of consent was obtained.
☐ 3. Individual results are not returned to subjects.

List of Reviewed Project Materials:
1.
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3.
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5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.

IRB Project Information Form
LEA Implementation Survey Consent
LEA Initial Contact Approval Request Email
LEA Key Informant Interview Guide and Consent
LEA Key Informant Interview Guide Consent
LEA Interview Date-Time Confirmation Calendar appointment
LEA Interview Scheduling Email
LEA Survey Respondent First Email
LEA Survey Respondent Reminder Email
School Implementation Survey and Consent
School Implementation Survey Consent
School Initial Contact Approval Request Email
School Key Informant Interview Guide and Consent
School Key Informant Interview Guide Consent
School email to schedule interview 4.25.19
School Survey Responded First Email 4.25.19
School Survey Responded Contact Reminder Email 4.25.19
SEA Implementation Survey Consent
SEA Initial Contact Approval Request Email
SEA Key Informant Interview Guide and Consent
SEA Key Informant Interview Guide Consent
SEA Interview Date-Time Confirmation Calendar appointment
SEA Interview Scheduling Email
SEA Survey Respondent First Email
SEA Survey Respondent Reminder Email

If you have any questions regarding this finding, please email [email protected].
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EVALUATION OF THE DP18-1801 HEALTHY SCHOOLS PROGRAM
May 10, 2019

(Revised 02/2019)

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