The NYC DOE Institutional Review Board

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The NYC DOE Institutional Review Board

The New York City Department of Education Institutional Review Board (NYC DOE IRB) reviews all requests to conduct research in the NYC Public Schools. Any research being conducted in schools or with NYC public school students, staff, or affiliates must be reviewed and approved by the NYC DOE IRB to ensure it complies with DOE policies, protects the privacy of students, parents, and staff, and does not disrupt the work of our schools.

The NYC DOE IRB must review and approve any research within its jurisdiction. This jurisdiction includes, but is not limited to:

  • Any research conducted with NYC public school students, families, school staff, non-school based staff, or staff of organizations contracted by the DOE (including CBOs, such as pre-K providers)
  • Any research conducted in a NYC public school or other physical or virtual site where DOE affiliates are involved
  • Any NYC DOE employees or offices engaged in human subjects research as part of their employment
  • Any evaluations (even if they do not constitute human subjects research) that involve students, are conducted by an external organization, and were not initiated on the DOE’s behalf.

Many internal program evaluation, continuous improvement, and other activities occur in NYC public schools that are not technically considered human subjects research (HSR). However, in some cases the NYC DOE IRB may conduct a DOE Research Policy Review for non-HSR evaluations if they involve students, are conducted by an external party, and were not initiated on the DOE’s behalf. Please reach out to the IRB inbox (IRB@schools.nyc.gov) if you have questions about if your study needs to be reviewed by the IRB.

Types of IRB Oversight

NYC DOE IRB is IRB of Record

  • If the NYC DOE IRB is the IRB of Record, it will conduct a full human subjects research ethics review of a study.
  • This type of oversight usually applies to internal studies conducted by NYC DOE employees doing research as part of their official work responsibilities. Sometimes the NYC DOE IRB may serve as the IRB of Record in collaborative studies. Please reach out to the IRB inbox (IRB@schools.nyc.gov) if you are unsure if the NYC DOE IRB should be the IRB of Record.

DOE Research Policy Review

  • The DOE Research Policy Review is a review for compliance with specific DOE research policies.
  • This type of oversight typically applies to external or collaborative research studies, where an external IRB has already reviewed the study and is serving as the IRB of Record. This type of review is also used to review non-HSR evaluations involving students, conducted by an external organization, and not initiated on the DOE’s behalf.

Depending on the type of study and the extent to which DOE affiliates are engaged in the research, the NYC DOE IRB may conduct different levels of review.

When to submit a protocol

Do I need to submit a protocol to the NYC DOE IRB?

Your study will need to be reviewed and approved by the NYC DOE IRB if either of the following conditions apply:

  • You are conducting human subjects research involving NYC public schools, students, staff, parents, non-school based staff, or staff of organizations contracted by the DOE.
  • You are an external person/organization conducting a non-HSR evaluation involving students and the study was not initiated on the DOE’s behalf.

 Questions to consider:

  • Has this project been reviewed by an external IRB already? If so, what was the determination?
    • If an external IRB reviewed your study as any category of minimal risk, Expedited, Exempt, or Full Board, you will need to submit to the NYC DOE IRB.
    • If an external IRB reviewed your study as “not research” or some other not applicable category, please email the IRB inbox (IRB@schools.nyc.gov) to determine if you need to submit.
  • What data is being collected?
    • If you are collecting data from DOE staff about their thoughts, feelings, or opinions, you will likely have to submit to the NYC DOE IRB.
    • If you are collecting information from DOE staff about programmatic operations or job functions, this may not require NYC DOE IRB review.
  • Will you be collecting any data from students or families?
    • If you are collecting any data from students or families, you will need to submit to the NYC DOE IRB.
  • How will the results or findings be used and/or shared? Who is the intended audience for the findings? Do you plan on publishing any of the findings?
    • If results will be published or shared with an external audience (such as academic journals, conferences, or funders), you will need to submit to the NYC DOE IRB.

Please note, submission to IRB Manager for a DOE Research Policy Review is required even if you have already received approval from your institutional IRB.

How to submit a protocol

How do I submit a protocol to the NYC DOE IRB?

NYC DOE IRB submissions go through IRBManager. See How to Use IRB Manager for more information.

Requesting administrative data

What if I also need to request administrative data?

If your study also includes a request for administrative data, you will need to submit a separate data request form through IRB Manager. At this time, you must apply to access administrative data separately from the IRB proposal. Please see the Data Requests Page for more information.

DOE employees completing advanced degrees

I am a DOE employee completing an advanced degree, and I want to do research in DOE schools. What do I need to know?

Conflict of Interest

If you are affiliated with the DOE, but conducting research outside of your DOE job responsibilities, such as for an advanced degree, you must contact the NYC DOE Ethics Officer, Ms. Samantha Biletsky (SBiletsky@schools.nyc.gov), prior to submitting to the NYC DOE IRB to determine if a Conflict of Interest Exemption is required for the proposed research. Note that the DOE rarely permits DOE staff to conduct research in their own school or with students, parents, teachers, or other staff that are under the supervision of or in a position of subordination to any member of the study team.

See here for more information about Conflicts of Interest, and to access the Research Waiver Request Form. (DOE login credentials are required to access this page.) 

Institutional Approval

You must receive approval from your institutional/university IRB before submitting to the NYC DOE IRB. The institution/university will serve as your IRB of Record for your study.

Specific Questions in the Protocol

  • Do not complete your submission using your DOE email address. Use your university or institutional email address.
  • List your study as External. DOE employees or affiliates who are conducting research to complete a graduate degree are considered external researchers. Even though the researcher is a DOE employee, they are not conducting their dissertation research on behalf of the DOE, so the study is considered external.
  • Identify yourself as a student.
  • Identify yourself as affiliated with the DOE.
  • Include your COI waiver letter.
  • List your Faculty Advisor on your protocol. They will need to create an IRB Manager account.
  • List your institutional IRB on your protocol. They will need to create an IRB Manager account.

Getting Support

Your institutional IRB and your Faculty Advisor are there to support you in this process. Please reach out to these resources for help completing your protocol. Your Faculty Advisor should review your protocol in detail before submission. The NYC DOE IRB can support with specific questions, but it is your responsibility to ensure your protocol is complete, you have read and followed all instructions, and your submission is free of errors or omissions.

Security Clearance, Fingerprinting, and PETS

All personnel named in an approved IRB protocol who are designated to conduct research in NYC public schools, with NYC DOE staff or students, or using NYC public school student data, must complete the NYC DOE security clearance process. This process involves the following steps:

  1. PI receives IRB approval from the NYC DOE IRB, including approval letter naming all research team member names.
  2. For each research team member, email required information and scanned copies of required documents to IRB@schools.nyc.gov, including:
    • Stamped DOE IRB Approval Letter
    • Government Issued State ID
    • Signed Social Security Card
    • Current email address and phone number
  3. The NYC DOE IRB will verify this information and enter it into the PETS system.
    • Note: We understand individuals may feel uncomfortable emailing SSN information. If so, please state in your email that you would like to verify your SSN over the phone and we will set up a call.
  4. Within 7 business days, researchers will receive a nomination email from PETSAdminSupport@schools.nyc.gov. This email will outline all next steps in the security clearance process, including login access to Applicant Gateway where all required forms can be found.
  5. Researchers must complete the required steps and forms in the Applicant Gateway. This may consist of completing fingerprinting and/or a Background Questionnaire (see below for more information about fingerprinting).

The NYC DOE takes the safety of our students, staff, and schools very seriously. The security clearance process is not optional. If researchers do not follow the NYC DOE’s requirements for security clearance, the study may be paused or terminated, the IRB of Record will be notified, funders may be notified, future studies may not be approved, and the Office of Special Investigations may be involved. It is the PI’s responsibility to ensure all research staff are cleared to enter schools.

If a researcher’s eligibility status changes, and they become ineligible for some reason, the NYC DOE IRB will contact the study PI to inform them and to direct them to remove that researcher from schools immediately.

Fingerprinting

A researcher may need to complete fingerprinting for the security clearance process. If so, once all required forms are completed and signed, follow the directions provided in the Applicant Gateway to schedule the fingerprinting appointment through IdentoGo. Please note:

  • Fingerprinting is no longer conducted at 65 Court Street.
  • Fingerprinting is conducted on an appointment-only basis.
  • The cost for fingerprinting is currently $101.75.

 What if I’m already eligible in PETS?

Security clearance is role-specific, so individuals are cleared for specific roles. Any researchers doing research in DOE schools must be entered into PETS on the IRB roster. If researchers already have fingerprints on file with the NYC DOE IRB, or are already eligible in PETS under a different roster, they still need to submit the required documents to the IRB inbox and complete any required steps. The researcher may not need to be re-fingerprinted, and they may just need to update responses in the Background Questionnaire. If a researcher is already in PETS but not on the IRB roster, they are not cleared to enter schools for research. They must be found eligible on the IRB roster.

What if a researcher does not have an SSN?

Researchers must have an SSN in order to be entered into PETS and to obtain security clearance. We understand that some research study teams include international university students who do not have SSNs. Unfortunately, there is no option at this time to add these individuals into PETS under the IRB roster.

Review Process

How long will it take to review my study?

All submissions are reviewed in the order they were received. The timeline for review depends on the number of studies recently submitted.

NYC DOE IRB Registration

IRB Registration: The NYC DOE IRB is registered with the United States (US) Department of Health and Human Services (DHHS) Office for Human Research Protections (OHRP). The DOE IRB registration number is: IRB00011754 and IRB00012206.

Federal Wide Assurance: The DOE has filed a Federal Wide Assurance (FWA) with the US DHHS OHRP, which documents the DOE’s commitment to comply with federal regulations for the protection of human subjects in research. The DOE FWA number is as follows: FWA00005811.

Contact the NYC DOE IRB

You can email the NYC DOE IRB at IRB@schools.nyc.gov

If you have an active protocol in IRB Manager, please include the protocol number in the subject line and body of your email.

If you have a question about Data Requests, please email RPSGresearch@schools.nyc.gov

See Also