This guidance is for investigators who are teaching courses at Lamar University and are planning to include students from these courses in their study as human subjects. These can be curriculum-based and non-curriculum based research projects which collect student’s personally identifiable information. If the instructor is only using their students’ data for internal assessment or evaluation purposes and have no plans to use the data for research purposes, Institutional Review Board (IRB) approval is not needed.

A subject’s participation must be voluntary, based upon full and accurate information. Research with one’s own students inherently challenges the subject’s “voluntariness” due to the power difference between students and instructor. Students may feel as though they have to participate or risk having their non-participation impact their grade or relationship with the professor. The IRB understands that real coercion is rare in research, but the perception of coercion potential can be a problem in obtaining voluntary informed consent. For this reason, the IRB has taken the position that instructors should not use their own students as subjects in their research if it can be avoided.

Population

Students should not be used as a population of convenience for faculty/staff research. In any proposed research project involving recruitment through classrooms, student listservs, or other student groups, a clear explanation or justification should be provided as to why those students are the most appropriate participants for the project.

PIs must provide a compelling reason in the IRB application stating why they need to use their own students for research over any other option. Faculty may use their own current, consenting students in human subject research only under the following conditions:

• Pedagogical Necessity:
  • The research intervention is inseparable from the instructional method being studied (e.g., comparing two feedback strategies within the same course).
  • The learning activity is part of normal course requirements, and excluding your own students would alter the educational experience.
• Population Uniqueness:
  • The course or program has highly specialized content or skills not available elsewhere (e.g., a capstone engineering design course or a rare language class).
  • The students represent the only population relevant to the research question (e.g., studying the impact of a new teaching approach in a specific discipline)
• Institutional Mandate or Accreditation:
  • The study addresses program-level assessment required for accreditation or institutional improvement, and your students are the relevant cohort.
• Feasibility Constraints:
  • No alternative participant pool exists without introducing major logistical or financial burdens (e.g., recruiting from other sections would require cross-campus travel or additional instructors).
  • The sample size needed for valid results can only be achieved through your enrolled students.

Collection of Data by Third Party

An independent third party, who does not have power or authority over the students, must be part of the recruitment, consent process and data collection, if applicable. This third party can recruit in-person or via email, conduct the consent process and explain and provide assurances to the student that no penalties will result by not agreeing to participate in the research. Please note: The specific role of the third party may nor may not require them to be listed as a project team member on the IRB submission. Individuals who are tasked with obtaining consent (describing the study procedures, answering questions about the study, ensuring comprehension, etc.) are engaged in human research activities and are considered investigators by the IRB.

Who qualifies as a third party?

• Someone not directly involved with the student’s academic progress or evaluation.
• Ideally, this means outside the supervisory chain—not the advisor, co-instructor, teaching assistant, or anyone grading the student.
• In many cases, this could be:
  • A faculty member from same department or college.
  • A faculty member from another department or college.
  • A staff member in an administrative or compliance role.
  • A graduate student from a different department or college.
  • A co-investigator.

• If the third party is only tasked with temporarily holding consent, then they would not be considered part of the project team.

There are many variations to using this approach depending on the timing and procedures involved.  Here are some examples of processes that can help minimize coercion of undue influence:

Example A: Data will be collected from students in a targeted class through an anonymous survey (no names or other identifying information will be included).  The researcher, who is also the instructor of the course, has designed a simple written consent statement to describe the research and no signed consent forms will be collected.  At the end of a class period, the instructor/researcher introduces and discusses the study with the students (using the approved recruitment script and consent statement), answers any questions, and then leaves.  A third party would distribute the survey to students and collect any completed surveys.  The surveys could be provided to the instructor after all were collected.  Using this process, the students can be assured that the instructor does not know who provided which survey and who did or did not participate.

Example B: The survey administered to a targeted class is not anonymous (student names and IDs are being collected). The survey data will be linked to participating students’ final exam scores and course grades.  Here, the third party would be used the same as in the first example, but signed consent forms and identifiable surveys are collected and placed in a sealed envelope.  The surveys could be provided to a co-investigator on a project after all are collected, given the co investigator has no direct involvement with the student’s academic progress or evaluation.  Using this process, this ensures time-sensitive studies can proceed and students can be assured that the course instructor does not know who provided which survey and who did or did not participate.

Example C: The survey administered to a targeted class is not anonymous (student names and IDs are being collected). The survey data will be linked to participating students’ final exam scores and course grades.  Here, the third party would be used the same as in the first example, but signed consent forms and identifiable surveys are collected and placed in a sealed envelope.  The third party would keep the sealed envelope in a locked file cabinet until after the class grades were submitted. Only then are the completed consent forms and surveys provided to the instructor/researcher.  The researcher will then know who has agreed to participate in the study and which survey they provided; but, the involvement of a third party and the timing provide students assurance that their participation, or lack thereof, has no impact on their grade or their standing in the class.

Example D: An instructor proposes to use student work products (assignments, papers, quizzes, exams, etc.) as research data.  Documented (signed) consent forms need to be collected from students who are willing to provide their data for the study.  The instructor/researcher would present the study to the class and answer questions, as in the other examples.  The third party would collect signed consent forms and hand-off to a co-investigator whom is directly involved with the student’s academic progress, or keep them in a locked file cabinet until after the class grades have been submitted. Then, the faculty researcher could access the consent forms and collect and analyze only the work products of those students who had given permission to use for their data in the study.  Again, in this process the students can be assured that their participation, or lack thereof, has no impact on their grade or their relationship with the instructor.

As an educator and researcher, you must wait until the end of the professor-student relationship before accessing the consent forms collected by the third party (i.e., after all marks have been submitted to the Registrar’s Office). This will mitigate any real or perceived influence on the student’s grades. Identifiable data can only be analyzed by the course instructor after grades have been submitted, and the course where the data was collected has officially ended.

Request Third Party Collector

Archived Data

Lamar University Policies and Procedures on the Use of Human Subjects in Research currently states in section 3.12 Research Involving Secondary Use of Identifiable that federal regulations extend to the use of existing or “archival” data if it was originally obtained from persons who would meet the definition of a human subject. Exempt category 4 states, “Research, involving the collection or study of existing identifiable data, documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available or if the information is recorded by the investigator in such a manner that subjects cannot be identified, directly or through identifiers linked to the subjects” [45 CFR 46.101(a)].

This might include (but is not limited to) student test scores, academic achievement scores, attendance and/or discipline records, data previously collected in a research project, census records, etc. The application must indicate that the data are publicly available (with a description of how it is obtained) or provide a letter from the person who is the owner or the keeper of the data indicating that permission has been granted for the use of the data in a research activity. Also, the data must be in existence at the time the application is submitted to the IRB.

Incentives

• Grade incentives are prohibited—you cannot offer higher grades for research participation.
• Course credit is allowed. To avoid unduly influencing students to participate in research with the offer of course credit, an assignment of equal/equitable effort and time commitment must be provided to all students being invited to participate in a research opportunity, in the event some wish to qualify for the bonus but do not wish to participate in the research.
• Incentives (monetary or otherwise) must be proportional, not tied to performance or recruitment success.
• Bonuses contingent on participation or completion are explicitly disallowed.