About Projects Not Requiring IRB Review
Determining whether a project constitutes human subjects research rather than quality improvement or program evaluation involves multiple factors. The federal definition of research is “a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge." In contrast, quality improvement projects or program evaluation projects systematically collect data for administrative, clinical, or reporting purposes, but are not designed to contribute to, or to advance generalizable knowledge. Instead, they are designed to develop or contribute to knowledge relevant to the organization.
The IRB Office is often requested to provide a determination as to whether a project is research under the Federal regulations or whether the activity is program evaluation or quality improvement. Formal IRB determinations are requested in anticipation of such documentation being required for journals, conferences, funding sources and others. The following IRB self-determination tool guides whether the project is quality improvement versus research requiring IRB review. Documentation can be printed at the completion of the checklist. Please note that this is not an ethical review of the project as that responsibility falls to the individual or institution that is conducting the quality improvement project.
If you have questions about this determination form, then please contact your IRB Research Analyst for assistance.
| Research | Quality Improvement | Program Evaluation | |
|---|---|---|---|
| Intent/Purpose | Intent of project is to develop or contribute to generalizable knowledge (e.g., testing hypotheses) | Intent of project is to improve a practice or process within a particular institution or ensure it confirms with expected norms | Intent of project is to improve or assess a specific program |
| Deviation from Standard Practice | May involve significant deviation from standard practice | Unlikely to involve significant deviation from standard practice | |
| Design | May involve randomization of individuals to different treatments, regimens or educational practices | Generally does not involve randomization to different treatments, or practices | Does not involve randomization of individuals, but may involve comparison of variations in programs |
| Effect on Program or Practice Evaluated | Findings of the study are not expected to directly affect institutional or programmatic practice | Findings of the study are expected to directly affect institutional practice and identify corrective action(s) needed | Findings of the evaluation are expected to directly affect the conduct of the program and identify improvements |
| Population | Usually involves a sample of the target population- universal participation of an entire clinic, program, or department is not expected; statistical justification for sample size is used to ensure endpoints can be met | Information is collected on all or most of the target population | Information on all or most participants in the program |
| Risks/Burdens | May put participants at risk | Does not increase risk to participants, with exception of possible privacy or confidentiality concerns | No risks to participants expected |
| Dissemination of Results | Intent to publish or present generally presumed | If the results are publicized, they are described as “quality improvement” in public presentations, academic curriculum vitae, publications, etc. | Intent to disseminate the information to program stakeholders and participants is assumed This may be publicly posted (e.g., website) to ensure transparency of results |