Research conducted in a school or classroom does not automatically qualify for exempt IRB review.
While certain educational research may qualify under Exempt Category 1, the research must meet specific criteria. The fact that a study involves students, teachers, schools, or educational activities is not enough on its own.
Understanding what Category 1 covers can help researchers determine whether their proposed study may fit within this exemption category and what information the IRB will need to make that determination.
What Is Exempt Category 1?
Exempt Category 1 applies to certain research conducted in established or commonly accepted educational settings that specifically involves normal educational practices.
The regulations provide examples that include research involving:
- Normal and regular educational practices
- Instructional strategies
- Instructional techniques
- Curricula
- Classroom management methods
The research must meet the applicable regulatory criteria and cannot be likely to adversely impact students’ opportunity to learn required educational content or the assessment of educators who provide instruction.
This exemption is designed for certain types of research that examine or compare educational practices within an educational setting.
What Is an Established or Commonly Accepted Educational Setting?
Category 1 generally applies to research conducted in settings where educational activities normally take place.
Examples may include:
- Schools
- Colleges and universities
- Classrooms
- Training programs
- Other established educational environments
However, the setting alone does not determine whether the exemption applies.
Research conducted in a school does not automatically qualify under Category 1. The research itself must involve normal educational practices and meet the other applicable requirements.
For example, a study conducted in a classroom involving a highly unusual intervention that is unrelated to normal educational practices does not fit within this exemption.
What Are Normal Educational Practices?
Normal educational practices generally involve activities that are commonly used in educational settings.
The regulations provide examples involving research on:
- Instructional strategies
- The effectiveness of instructional techniques
- Curricula
- Classroom management methods
For example, a researcher may want to compare two instructional approaches that are commonly used to teach the same subject.
Another study may examine the effectiveness of different classroom management techniques already used in an educational environment.
The key consideration is not simply whether the study takes place in a classroom. The IRB must consider whether the activities involved fit within normal educational practices.
Research on Instructional Strategies
Educational research often involves comparing different approaches to teaching.
For example, researchers may study:
- Traditional lectures compared with interactive learning
- Different approaches to teaching mathematics
- The use of technology in instruction
- Alternative methods of presenting educational material
- Different classroom management approaches
Category 1 may apply when the research involves normal educational practices and meets the other applicable requirements.
Researchers should clearly explain what participants would experience and whether the activities are already commonly used within the educational setting.
Research on Curricula
Category 1 may also apply to certain research involving curricula.
Researchers may compare:
- Different versions of educational content
- Different approaches to teaching the same required material
- Curriculum delivery methods
- The effectiveness of established educational programs
However, researchers should consider whether the study could negatively affect a student’s opportunity to learn required educational content.
For example, if one group of students is denied access to required educational material or receives substantially different instruction that could negatively impact their educational progress, Category 1 may not be appropriate.
Research on Classroom Management Methods
Research involving classroom management methods may also qualify under Category 1.
Examples could include studying:
- Different approaches to encouraging classroom participation
- Established techniques for managing classroom behavior
- Methods for improving student engagement
- Strategies commonly used to organize classroom activities
As with other types of educational research, the proposed activities must meet the requirements for normal educational practices.
Understanding FERPA and Educational Records
Researchers conducting educational research should also consider the Family Educational Rights and Privacy Act, commonly known as FERPA.
FERPA is a federal law that protects the privacy of student education records at schools and educational institutions that receive applicable funds from the U.S. Department of Education.
Educational records may include grades, transcripts, disciplinary records, student identification information, and other records directly related to a student that are maintained by an educational institution or a party acting on its behalf.
When research involves student education records, researchers should understand whether FERPA applies and what permissions or exceptions may be available for the proposed use of those records.
FERPA and the Common Rule are separate requirements. An IRB exemption does not automatically provide permission to access or disclose student education records under FERPA.
Depending on the study, researchers may need written consent from parents or eligible students, or they may need to meet the requirements of an applicable FERPA exception.
Researchers should work with the educational institution and the appropriate reviewing bodies to determine what requirements apply before accessing student records.
Research in a School Is Not Always Category 1
One of the most common misunderstandings about this exemption is the belief that any study conducted in a school qualifies as educational research under Category 1.
That is not the case.
A study may take place in an educational setting but involve research activities that fall outside normal educational practices.
For example, research involving:
- Surveys
- Interviews
- Psychological or behavioral interventions
- Collection of sensitive information
- Experimental procedures unrelated to normal educational activities
may need to be evaluated under a different exemption category or another IRB review pathway.
The research setting is only one part of the analysis.
Research Involving Children and Active Parent Consent
Many Category 1 studies involve children because they take place in schools or other educational settings.
Children are a population requiring additional protections under the federal regulations. Researchers should carefully consider the participant population and the specific study procedures when planning educational research.
Solutions IRB requires active parent or guardian consent for research involving children. This means that parents or legal guardians must provide signed consent before their child can participate in the research. An opt-out consent process, where a child may participate unless a parent objects, is not accepted by Solutions IRB.
For example, sending a notice home to parents and allowing their child to participate unless the parent returns a refusal form does not meet our active consent requirement.
Researchers should plan to obtain signed parent or guardian consent before enrolling students in research. Depending on the study and the participant population, child assent may also be required.
Active parent consent is an important part of protecting children and ensuring that parents or guardians have an opportunity to understand the research before their child participates.
Common Misunderstandings About Category 1
“The research takes place at a school, so it is exempt.”
Not necessarily.
The research must involve normal educational practices and meet the specific criteria for Category 1.
“Any teaching experiment qualifies.”
Not necessarily.
The instructional activity must fit within normal educational practices and should not be likely to adversely impact students’ opportunity to learn required educational content.
“Exempt research involving students does not require protections.”
Exempt research still requires appropriate ethical and regulatory consideration.
Depending on the study, researchers may need to address privacy, confidentiality, parental consent, child assent, institutional requirements, and other applicable protections.
“Parents can simply opt out of the research.”
Not for studies submitted to Solutions IRB involving children.
Solutions IRB requires active parent or guardian consent. Parents must sign a consent form before their child can participate. An opt-out consent process is not accepted.
“FERPA and IRB review are the same thing.”
No.
FERPA protects the privacy of student education records, while the Common Rule governs certain human subjects research. A study may need to satisfy both requirements when applicable.
Preparing an Educational Research Submission
A clear submission can help the IRB understand whether Category 1 may apply.
Researchers should clearly describe:
- The educational setting
- The participant population
- The educational activities involved
- Whether the activities are normal educational practices
- The instructional strategies or methods being studied
- Whether students will receive different educational content
- How the research could affect students’ educational opportunities
- Whether teachers or other educators are participants
- How information will be collected and protected
- Whether children are involved
- How active parent or guardian consent will be obtained
- Whether child assent will be required
- Whether FERPA applies to the research
- What permissions or authorizations will be used to access educational records, when applicable
- District permission and principal permission letters
For research conducted in schools, Solutions IRB requires both a district permission letter and a principal permission letter. Researchers should obtain these letters from the appropriate school or district officials and include them with their IRB submission.
The more clearly the educational activities and required permissions are described, the easier it is for the IRB to evaluate whether the study fits within the exemption criteria.
Understanding Exempt Category 1
Exempt Category 1 provides a pathway for certain research involving normal educational practices in established or commonly accepted educational settings.
However, research does not qualify simply because it takes place in a classroom or involves students and teachers.
The specific educational practices, research procedures, and potential impact on students are all important considerations.
Researchers should carefully describe the educational setting and proposed activities when submitting a study for review. This helps the IRB determine whether the research may qualify under Category 1 or whether another exemption category or review pathway is more appropriate.
For research involving children, Solutions IRB requires active parent or guardian consent before participation. Researchers should also consider child assent, FERPA requirements, and any additional protections applicable to the study.
For a broader overview of exempt research and all eight exemption categories, visit our guide to Understanding Exempt Research.
You may also want to explore our additional resources on research involving youth and children, including considerations for parental or guardian consent and age-appropriate assent.
Disclaimer: This article provides general educational information and is not a substitute for an IRB’s review or determination regarding a specific research study.