Addendum Research in Schools

Last Updated: 3/28/13

Research in Schools Addendum

*** Be certain to complete both sections A and B as applicable. Section C is provided for guidance on how additional information can be provided to the IRB if necessary.

When research will occur in a school or district building in the US regardless of subject population, the IRB is required to ensure that any school or district that receives funding from the Department of education meets certain requirements of FERPA/PPRA related to research. This form is intended to minimize the burden on researchers and school personnel in providing information for IRB verification of this. The form will be periodically updated to add more schools to the list so it would be best to use a new copy of this form each time either and amendment is planned to add a new school to a current protocol or a new protocol to be conducted in schools is started.

Section A: Schools for which no further information will be needed.

The IRB already has adequate FERPA/PPRA information on file for the following so please simply put a check next to any of the following that will you will be working in. As it is expected that schools in close proximity to the Buffalo area will be accessed the most frequently, schools that are within the Western New York area are listed first followed by other NY State Schools (please check both list) and then those Outside of NY. If a policy has been verified for an entire district, then individual schools need not be indicated and the district can be checked off to indicate any school within that district. Note that Private and Charter schools are not covered by district policies and are therefore listed separately.

WesternNY School districts:

Amherst CSD, Amherst, NY

Buffalo Public, Buffalo, NY

Brockport CSD, Brockport NY

Cahautaqua Lake, Mayville, NY

Cheektowaga CSD, Cheektowaga, NY

Clarence, Clarence, NY

Cleveland Hill Central, Cheektowaga, NY

East Aurora, East Aurora, NY

Eden, Eden, NY

Ellicottville, Ellicottville, NY

Grand Island, Grand Island, NY

Hamburg, Hamburg, NY

Iroquois Central School District, Elma, NY

Kenmore-Town of Tonawanda UFSD, Kenmore, NY

Lakeshore Central Schools aka, Evans-Brant, Evans, NY

Lancaster, Lancaster, NY

Lewiston-Porter Central, Lewiston, NY

Maryvale, Cheektowaga, NY

Newfane, Newfane, NY

Niagara Falls, Niagara Falls, NY

Niagara-Wheatfield CSD, NY

North Tonawanda City, North Tonawanda, NY

OrchardPark, Orchard Park, NY

Oakfield-Alabama Central, Oakfield, NY

Pioneer Central, Yorkshire, NY

Pembroke Central, Pembroke, NY

Sherman Central, Sherman, NY

Southwestern, Jamestown, NY

Startpoint CSD, Lockport, NY

Sweet Home, Amherst, NY

Tonawanda City, Tonawanda, NY

Warsaw Central, Warsaw, NY

Williamsville, Williamsville, NY

West Seneca CSD, West Seneca, NY

Other WNY Public Schools:

Cattaraugus Allegany BOCES, NY

WNY Children's Psychiatric Center, West Seneca, NY

Charter Schools in WNY:

Aloma D. Johnson Charter School, Buffalo, NY

Buffalo Academy of Sciences, Buffalo, NY

Community Charter, Buffalo, NY

Elmwood Village Charter, Buffalo, NY

Global Concepts Charter, Buffalo, NY

Health Sciences Charter, Buffalo, NY

Pinnacle Charter School, Buffalo, NY

TapestryCharterSchool, Buffalo, NY

Westminster Community Charter, Buffalo, NY

Private/Parochial/Independent Schools in WNY:

Department of Catholic Education, Diocese of Buffalo (for any/all Diocese of Buffalo Catholic ElementarySchools)

NicholsSchool, Buffalo, NY

St. Francis High School, Athol Springs, NY

Other NY State Districts (check the WNY schools as well)

Brighton Central SD, Brighton, NY

Fairport Central, Fairport, NY

Greece CSD, Greece, NY

Lyons CSD, Lyons, NY

NewfieldSchool District, Ithaca, NY

Penfield Central SD, Penfield, NY

Rochester City SD, Rochester, NY

Rush-Henrietta SD, Henrietta, NY

Other NY State Schools (check the WNY schools as well)

Children’s Schools of Rochester School # 15, Rochester, NY

Schools and Districts outside of NY (listed by state abbreviation)

San Diego Unified, San Diego, CA

Poway, Poway, CA

PerkinsSchool for the Blind, Watertown, MA

Oakville Elementary, St. Mary's County Public School, Leonardtown, MD

South Washington County #833, MN

IndependentSchool District #832, MN

Barber National Institute, Elizabeth LeeBlack School, Erie, PA

Section B: Schools for which further information may be needed.

Check here if no schools/districts need to be listed in this section because all are covered in section A.

List any other schools/districts in the U.S. that you will be working in that are not already covered in section A above. The IRB will contact you if further information is needed to determine if Schools or Districts meet the necessary FERPA/PPRA Requirements. If necessary, any request for further information will be made as a part of a normal request for protocol changes.

Public School Districts. Use the following format: District1, City1, State1; District2,City2, State2; etc.

Schools that are not a part of a school district. (i.e. charter, private or parochial schools) use the following format: School1, City1, State1; School2, City2, State2; etc.

Section C: Information that will be requested if further information is needed.

(Note that there is nothing to fill in below)

Regulatory Requirements: The IRB is required to have a process to verify compliance with U.S. Department of Education regulations that schools are required to develop and adopt policies in conjunction with parents regarding the following:

  • The right of a parent of a student to inspect, upon the request of the parent, a survey created by a third party before the survey is administered or distributed by a school to a student.
  • Any applicable procedures for granting a request by a parent for reasonable access to such survey within a reasonable period of time after the request is received.
  • Arrangements to protect student privacy that are provided by the agency in the event of the administration or distribution of a survey to a student containing one or more of the following items (including the right of a parent of a student to inspect, upon the request of the parent, any survey containing one or more of such items):
  • Political affiliations or beliefs of the student or the student’s parent.
  • Mental or psychological problems of the student or the student’s family.
  • Sex behavior or attitudes.
  • Illegal, anti-social, self-incriminating, or demeaning behavior.
  • Critical appraisals of other individuals with whom respondents have close family relationships.
  • Legally recognized privileged or analogous relationships, such as those of lawyers, physicians, and ministers.
  • Religious practices, affiliations, or beliefs of the student or the student’s parent.
  • Income (other than that required by law to determine eligibility for participation in a program or for receiving financial assistance under such program).
  • The right of a parent of a student to inspect, upon the request of the parent, any instructional material used as part of the educational curriculum for the student.
  • Any applicable procedures for granting a request by a parent for reasonable access to instructional material received.
  • The administration of physical examinations or screenings that the school or agency may administer to a student.
  • The collection, disclosure, or use of personal information collected from students for the purpose of marketing or for selling that information (or otherwise providing that information to others for that purpose), including arrangements to protect student privacy that are provided by the agency in the event of such collection, disclosure, or use.
  • The right of a parent of a student to inspect, upon the request of the parent, any instrument used in the collection of personal information before the instrument is administered or distributed to a student.
  • Any applicable procedures for granting a request by a parent for reasonable access to such instrument within a reasonable period of time after the request is received.

Discussion and Local Application of the Above: The critical element in the above is that the school or district must have developed and adopted the policy in conjunction with parents. While other forms of documentation may become acceptable in the future, currently the following two forms of verification are considered adequate:

  1. School/District policy documentation from website or other handbook demonstrating that the school/district has developed a policy in conjunction with parents to meet FERPA/PPRA requirements such as:
  2. A website citation and text from the school/district site
  3. Information from a parent handbook including both documentation that the materials came from the school/district and the appropriate text
  4. A statement signed by a school official (see template below). Note that this must typically be from a person above the level of an individual teacher or clerical staff member.

Where non-public schools are involved and funding for the research project is not from the DoEd, there is another alternative but it should be noted that in most known cases there is indirect funding provided to private schools for things like bussing, books, lunches and other items so this alternative is not typically available. However, if it is possible to provide documentation from a school official showing that a school does not receive any direct or indirect funding from the DoEd and therefore is not required to adhere to FERPA and PPRA requirements, the SBSIRB may be able to consider this requirement as not applicable.

School/District FERPA/PPRA Compliance Statement for IRB Purposes

The ______(school/district) is in compliance with U.S. Department of Education regulations that schools are required to develop and adopt policies in conjunction with parents regarding the following:

  • The right of a parent of a student to inspect, upon the request of the parent, a survey created by a third party before the survey is administered or distributed by a school to a student.
  • Any applicable procedures for granting a request by a parent for reasonable access to such survey within a reasonable period of time after the request is received.
  • Arrangements to protect student privacy that are provided by the agency in the event of the administration or distribution of a survey to a student containing one or more of the following items (including the right of a parent of a student to inspect, upon the request of the parent, any survey containing one or more of such items):
  • Political affiliations or beliefs of the student or the student’s parent.
  • Mental or psychological problems of the student or the student’s family.
  • Sex behavior or attitudes.
  • Illegal, anti-social, self-incriminating, or demeaning behavior.
  • Critical appraisals of other individuals with whom respondents have close family relationships.
  • Legally recognized privileged or analogous relationships, such as those of lawyers, physicians, and ministers.
  • Religious practices, affiliations, or beliefs of the student or the student’s parent.
  • Income (other than that required by law to determine eligibility for participation in a
  • program or for receiving financial assistance under such program).
  • The right of a parent of a student to inspect, upon the request of the parent, any instructional material used as part of the educational curriculum for the student.
  • Any applicable procedures for granting a request by a parent for reasonable access to instructional material received.
  • Physical examinations or screenings that the school or agency may administer to a student.
  • The collection, disclosure, or use of personal information collected from students for the purpose of marketing or for selling that information (or otherwise providing that information to others for that purpose), including arrangements to protect student privacy that are provided by the agency in the event of such collection, disclosure, or use.
  • The right of a parent of a student to inspect, upon the request of the parent, any instrument used in the collection of personal information before the instrument is administered or distributed to a student.
  • Any applicable procedures for granting a request by a parent for reasonable access to such instrument within a reasonable period of time after the request is received.

Signature: ______

Name (Please Print):______

Position: ______

(Note that the person signing should have sufficient authority to be able to be able to speak to the above requirement such as a principal or asst. principal, superintendant or asst. superintendant, attorney or other district official. Individual teachers or clerical staff typically cannot be accepted but may be able to provide other documentation such as a copy of the policy handbook that could be used to meet this IRB requirement in lieu of this document).