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FAQs
Additional Questions
Based on a change to federal regulations in 2019, CUNY no longer requires continuing review of minimal risk research studies. However, please check to make sure your protocol does not have an expiration date.
Any changes to an active protocol, including changes to research personnel, require submission of an amendment application for review and approval.
A final report should be submitted at the conclusion of the research study. All human subjects research activities should be completed, including analysis of all identifiable data and/or specimens.
Identifiable: Means the identity of the subject is known or may be readily ascertained by the investigator or anybody associated with the information.
Identifiable data can be linked to specific individuals by the investigator(s) either directly or indirectly through coding systems, or when characteristics of the information obtained are such that by their nature a reasonably knowledgeable person could ascertain the identities of individuals.
De-identified data: If the dataset has been stripped of all identifying information and there is no way that it could be linked back to the subjects from whom it was originally collected (through a key to a coding system or by any other means). Its subsequent use by the PI or another investigator would not constitute human subjects research, since it is no longer identifiable.
However, even though a dataset may have been stripped of direct identifiers (names, addresses, student ID numbers, etc.), it may still be possible to identify an individual through a combination of other characteristics (e.g., age, gender, ethnicity, and place of employment).
Breaches in protocol, adverse events, and unanticipated problems include, but are not limited to, breakdowns in the consent process, violations of confidentiality of the data, complaints by participants, and adverse physical events. Serious problems and adverse events must be reported to the HRPP/IRB within 48 hours.
The research team should consider getting in to an IRB Authorization/Reliance Agreement (IAA). An IAA is the process by which one institution's IRB assumes IRB responsibilities for another institution. These types of agreements are put into place after HRPP/IRB approval for research studies approved under an expedited category or the full/convened board.
An Independent Researcher Agreement (IRA) is the mechanism by which an individual who is not affiliated with CUNY or another institution can be involved in research activities being conducted by CUNY. The IRA requires the completion of an Independent Researcher Agreement Application. The application can be found on CUNY's Research Agreements.
All consent documents and instruments must be translated after HRPP/IRB review and approval via an amendment application. Please see instruction in section 5 of the Informed Consent Process and Documentation policy.
Subjects that are minors, prisoners, fetuses, pregnant women, or individuals that have a diminished mental capacity are considered vulnerable subjects.
Please see the information found in the FERPA guidance document for information on methods of using educational records for research and maintaining FERPA compliance.
You are responsible for:
- Familiarizing yourself with ethical guidelines and regulations regarding the protection of human participants from research risks
- Conducting the research according to the approved protocol
- Obtaining written informed consent using the approved consent form for each and every study participant if required by the IRB
- Immediately reporting any unanticipated effects on participants which become apparent during the course of the study and the actions taken as a result, to the IRB through the HRPP Office and your immediate administrator
- Obtaining prior review from the IRB if you wish to amend or alter the scope of the project or implement changes in the approved consent form
- Maintaining documentation of consent forms and progress reports for three years in a safe place
- Once the research is completed, submit the final report
HRPP Office at (212) 650-3053 or hrpp@hunter.cuny.edu