HUMAN SUBJECTS RESEARCH APPLICATION Instructions: Please complete this form and attach a copy of the study protocol for all new human subjects research. All the questions must be addressed in order to provide the Institutional Review Board with the necessary information to review your proposed research study. IRB approval must be obtained prior to beginning any human subjects research, including recruitment of study participants Researchers are also required to take the Collaborative Institutional Training Initiative (CITI) online training through Emerson College's subscription. The IRB will not consider an application unless we have evidence that all investigators named in this application have completed the online training at the time the application is submitted. If members of the research team completed the training at Emerson, then we will have an electronic record of it. If a member of the team completed the CITI at another institution, then please include a copy of the certificate in the appendix of this application. 1. GENERAL INFORMATION: Protocol Title: Date: Research is being Assignment/Thesis/ALE/Capstone conducted for: Which Category of Approval are you Requesting? Research Project Individual or Group Student Other As an exemption to the Office of Human Research Protections As an expedited review As a full IRB committee review If you are requesting an exemption or an expedited review, please use Section 22 at the bottom of this application to provide a rationale for the request. Please refer to the specific categories of exemptions and expedited reviews outlined by the U. S. government. The descriptions of those categories appear on the Emerson IRB website. 2. PRINCIPAL INVESTIGATOR (Students should insert the name of their faculty/staff sponsor) *Note – CITI Certification is required: Currently CITI Certified: Yes No Name: School/Department: Campus Mailing Address: Telephone Number: ( ) Faculty Staff E-mail Address: 3. CO-INVESTIGATOR *Note – CITI Certification is required: If additional space is needed, please add on a separate page. Currently CITI Certified: Yes No Name: School/Department: Campus Mailing Address: Telephone Number: ( ) E-mail Address: Faculty Staff Student 4. RESEARCH STAFF: If additional space is needed, please add on a separate page. *Note – CITI Certification is required Name Currently CITI Certified Yes No Yes No Yes No 5. COLLABORATORS: If you will be conducting this study in collaboration with non-Emerson investigators or in non-Emerson facilities, please complete the section below. *Note – CITI or Responsible Conduct of Research Training (RCR) required N/A Name Affiliated Institution IRB Approval CITI/RCR Certified Yes No Pending Yes No Pending Yes No Pending Yes No Pending 6. FUNDING SOURCES: If the study is funded, please provide a copy of the full grant, proposal and/or award N/A External Federal-Fund Agency: External Non-Federal Fund Source: 7. INTRODUCTION: Please provide a brief summary of any relevant background information and study aims. Please provide a rationale for the use of human subjects in meeting your study objectives. Duration: From Study Site(s): 8 . STUDY POPULATION To Total Number of Subjects: Age Range: Characteristics of Study Population: Please check all that apply. These categories refer to your intended sample, not individuals who might accidentally become part of your study. Senior (≥ 65) Children (< 18) Emerson Students/Staff Prisoners Non-English Speaking Ethnic Minorities Mentally Disabled Pregnant Women Fetuses /Neonates Other: 9. SELECTION OF SUBJECTS: Describe the inclusion/exclusion criteria and explain rationale for such. Explain rationale for using special populations such as children, pregnant women, prisoners, minorities or any vulnerable individuals and describe the additional safeguards that are in place to protect their rights and welfare. Provide rationale for concluding that the risks and benefits are fairly distributed among the population that stands to benefit from the research. A survey (see Appendix XX) will be conducted at the South End Community Center in Boston, Massachusetts. This will be a self-administered survey, using a convenience sample of women with chronic back pain who access services at the South End Community Center. The purpose of the survey is to assess and understand different attitudes and beliefs of women regarding acupuncture as a treatment option for lower-back pain. Participants must be 18 years or older, fluent in English, and have experienced lower-back pain within the last 12 months. Participants will be recruited from the South End Community Health Center, which is housed in the same building as Pathways to Wellness. It is a comprehensive health care facility that serves a diverse community. The surveys can be completed on the premises for the ease and comfort of the participants. 10. RECRUITMENT TOOLS: Please include all tools used to contact in appendix. 11. RECRUITMENT PROCESS: Describe in detail how subjects will be identified, method of initial contact and rationale for such method. Jane Doe will set up a table with recruitment flyers and consent forms and gather willing participants for the survey during the weekly information table sessions held at South End Community Health Center. Recruitment for survey participants will be ongoing until 150 surveys can be collected. Recruitment techniques include: displaying copies of the recruitment flyer (see Appendix XX) on the table so participants can stop by of their own volition during the information sessions; to generate interest before the information session, there will be recruitment flyers (see Appendix XX) posted on the informational bulletin boards in the lobby of the South End Community Health Center and the Pathways to Wellness waiting room. The flyers will indicate when and where participants can stop by to pick up the survey, should they choose to participate. Once someone approaches the survey table, they will be greeted by Jane Doe, who will answer any questions they may have about the survey or the research project. She will ask them if they are interested in participating, and if so, she will give them the survey to complete. If not, she will thank them for stopping by. Participants will be assured that declining to participate will have no bearing on their ability to receive services at the South End Community Health Center. 12. INFORMED CONSENT PROCEDURES: Please provide copies as separate attachments for all marked. Written Informed Consent will be obtained Waiver of Documentation of Informed Consent per §46.117(c) Please complete appropriate form. Informed Consent will be obtained via a short form written document per §46.117(b)(2) Waiver of some of the elements of informed consent per §46.116(d) Please complete appropriate form. 13. INFORMED CONSENT/ASSENT PROCESS: Describe consent/assent procedures to be followed, including the circumstances under which consent/assent will be sought and obtained, the nature of information to be provided to prospective subjects, and method of documentation. FOCUS GROUP EXAMPLE Informed consent will be obtained by Jane Doe, who has completed the CITI training for Human Subjects (see Appendix XX for a copy of the certification document). Informed consent will be obtained from all focus group participants at the community centter prior to the start of the focus group. The consent form will be handed to participants when they arrive at the center for the focus group. A copy of the consent form can be found in Appendix XX. Participants will be made aware of the key elements of the consent, including the use of audio recording. Participants will be encouraged to ask questions about the focus groups and the consent process at the time of consent. Participants will be permitted as much time as is necessary to completely read the informed consent document and ask any questions. It is estimated that this will require no more than 15 minutes to complete. Before they can participate in the focus group, participants must hand a signed copy to Ms. Doe. SURVEY EXAMPLE The online survey will include an abbreviated form of consent for completing the survey by indicating “yes” to the first question (see copy of the survey in Appendix XX), which will provide details about the research project and the survey process and ask potential respondents if they understand their rights as a participant. If they indicate yes, they will be instructed to continue on with the rest of the survey and their answers will be included in the study results. If they indicate no, they will not be able to move forward in the survey to any other questions. It is estimated that the consent portion of the survey will require no more than 5 minutes to complete. 14. RESEARCH TOOLS: Please provide copies for all marked. Surveys or Questionnaires (e.g. online surveys, mailed surveys, personal or medical history) Measurement Instruments (e.g. psychological tests, IQ tests, diagnostic tools) Record Review (e.g. chart review, public school records, medical records, agency records) Recorded: Audio Video Interviews In Person Phone Other: Recorded: Audio Video Focus Groups In Person Phone Other: Other: 15. RESEARCH PROCEDURES: Describe the study procedures that a research participant should expect during the protocol. Define the type, frequency, duration of participation (e.g., what is done and when). When applicable, describe which procedures are experimental and which are routine. If deception is used, describe how subjects will be deceived and/or debriefed. SURVEY EXAMPLE Starting March 17, 2013, Jane Doe will set up a table with recruitment flyers and consent forms and gather willing participants for the survey during the weekly information table sessions held at South End Community Health Center. Recruitment for survey participants will be ongoing until 150 surveys can be collected. Recruitment techniques include: displaying copies of the recruitment flyer on the table so participants can stop by of their own volition during the information sessions; to generate interest before the information session, there will be recruitment flyers posted on the informational bulletin boards in the lobby of the South End Community Health Center and the Pathways to Wellness waiting room. The flyers will indicate when and where participants can stop by to pick up the survey, should they choose to participate. Once someone approaches the survey table, they will be greeted by Jane Doe, who will answer any questions they may have about the survey or the research project. She will ask them if they are interested in participating, and if so, she will give them the survey to complete. If not, she will thank them for stopping by. Participants will be assured that their participation or not will have no bearing on their ability to receive services at the South End Community Health Center. Survey participants are informed that their participation is voluntary and that refusal to participate will involve no penalty or loss of benefits. They are also informed that they may discontinue participation at any time without penalty or loss of benefits. Surveys will be anonymous; no identifying information will be provided. The surveys will be assigned a randomized number prior to printing which will be coded on the survey in advance of it being given to pregnant women receiving care at the South End Community Health Center. The randomized numbers coded on the surveys will not be in sequential order, so the research team will not be able to identify which survey number was given to which person. Jane Doe will hand out the surveys and participants will drop the completed form in a lock box that only members of the research team have the key to unlock. FOCUS GROUP EXAMPLE Both focus groups will be 60 minutes long, and will be conveniently scheduled for potential participants. The focus group discussion will be conducted at a conference room within the main hospital location. All participants must complete the Informed Consent Form before participating (Appendix XX). The informed consent form will explain that the discussion will be recorded by an audio recorder, and notes will be taken by two observers. The form will also explain that the participation of each individual is voluntary, confidential, and that once the recording is transcribed, coded and analyzed it will be destroyed. Once all potential participants have signed the consent form, the group will commence. The focus groups will be moderated by Jane Doe. As described in the Focus Group Moderator’s Guide (Appendix XX), the moderator will begin by explaining the ground rules of the group and having each participant introduce him or herself with first names only. The moderator will then ask questions on the guide and probe where appropriate. Once the focus group discussion has been completed, participants will be rewarded with their $10 Coffee Central gift card incentive as a thank you. Focus group data will be collected through audio recording and supplemented by the notes of the two observers taken during the discussion. 16. COMPENSATION METHOD: If participants will not be compensated check this box N/A; skip to section 17. Amount/value of total compensation? Type: Gift Card; Cash; Raffle; Other: If students are being used as research subjects, will they receive course credit (including extra credit)? Yes No If yes, describe an alternate and equitable way to earn this credit without participating as a subject in research. Alternatives must not entail more time, effort, or stress on the part of the student than the research activity. 17. RISKS: Describe any known or potential risks and/or discomforts (physical, psychological, social, legal or other) and assess their likelihood, seriousness and potential reversibility. Describe procedures for protecting against these risks and assess their likely effectiveness. Describe any alternative procedures including the choice not to participate. Please do not say that there are no risks. There are always risks involved with human subjects research, even if they are minimal. FOCUS GROUP EXAMPLE This focus group study presents minimal risk. The primary risk is loss of confidentiality through the breach of focus group data (audio recording) or disclosure of information by participants upon leaving the group. This will be guarded against by keeping all recordings of the focus group session stored in a secured drive accessible only by Jane Doe and the authorized research assistant, who was also responsible for notetaking and recording the session. We also will instruct focus group participants to only use first names. Recordings will be digitally destroyed and the computer they were stored on swept clean of the electronic record using the latest digital erasing software tools available at the conclusion of the project timeline. Notes taken during the focus group and the completed surveys will be kept in a locked cabinet accessible only to Jane Doe and the authorized research assistant. Audiotapes will be destroyed when coding has concluded. To minimize the risk of post-group disclosure of information, participants will be reminded of the importance of maintaining confidentiality at the start and conclusion of the focus groups. Participants also may be uncomfortable talking about attitudes and beliefs related to acupuncture and lower-back pain but the participants of the focus group will be told that their participation is completely voluntary and that they may terminate participation at any time. SURVEY EXAMPLE For the survey participants, there is minimal risk. The primary risk is feelings of discomfort. Participants may be uncomfortable talking about attitudes and beliefs related to acupuncture and lower-back pain. Survey participants are informed that their participation is voluntary and that refusal to participate will involve no penalty or loss of benefits. They are also informed that they may discontinue participation at any time without penalty or loss of benefits. Surveys will be anonymous; no identifying information will be provided. Jane Doe will hand out the surveys/recruit participants and they will drop the completed form in a lock box that only the research assistant has the key to unlock. The research assistant will enter the data from the survey, having had no contact with the participant. The surveys will be stored in a locked file cabinet. 18. BENEFITS: Describe any potential benefits to the individual subjects and/or to society in general that may be expected from the research. Describe the importance of knowledge that may reasonably be expected to result from the study. If no direct benefits are anticipated, please state so. Information gained during the focus group will allow the research team Jane Doe to assess and understand different attitudes and beliefs of women regarding acupuncture as a treatment option for lower-back pain. This information can be used to create an effective intervention that will benefit other women with lower-back pain. There is no direct benefit to participants at the time of the study. They may potentially hear new information or perspectives about acupuncture as a treatment modality for lower-back pain that they may want to explore, but that is not being advocated by the study. 19. RISK/BENEFIT ANALYSIS: Discuss why risks are reasonable in relation to the anticipated benefits to subjects and in relation to the importance of the knowledge that may be reasonably be expected to result. 20. RESEARCH DATA Will personally identifiable information be recorded? Yes No; If so, please check all that apply: Names (First and Last) Date of Birth Telephone/Fax Number Email Address Social Security Number Student ID Street address, city, five digit zip code, county Internet IP Address Other: Will you be sharing any research data with anyone outside of Emerson? Yes No Will the research data be assigned a unique ID? Yes No; If yes, will a link between the unique ID and person’s identifiable information be retained? Yes No; If yes, for how long and how?: 21. PRIVACY AND CONFIDENTIALITY: Describe procedures for protecting privacy and maintaining confidentiality including procedures for collection, storage and future use of data. Describe whether codes will substitute names and/or identifiable records, who will have access to study data, whether database will be password-protected or encrypted for online data collection. Describe how long written records, tapes or recordings will be maintained, in what manner they will be kept or destroyed and for how long. FOCUS GROUP EXAMPLE All focus group participants will be fully informed that their participation is voluntary and confidential. Only Jane Doe and the authorized research assistant will have access to any participants’ responses or personal information. Responses will not be connected to participants’ personal information in any way. Focus group participants will be provided with an Informed Consent Form (see Appendix XX) prior to their agreement to participate. Once at the site of the focus group participants will be verbally reminded of their confidentiality prior to the start of the focus group. Although the participants will be asked to maintain confidentiality for each other as well, the research team realizes that compete confidentiality cannot be guaranteed. During these sessions, the respondents will be instructed to use only their first names. The focus group recordings will be kept only long enough to be transcribed. They will be kept on a secured computer drive and accessible only by Jane Doe and the authorized research assistant, who was also responsible for notetaking and recording the session. Once transcriptions are made and data analysis is complete, recordings will be digitally destroyed and the computer they were stored on swept clean of the electronic record using the latest digital erasing software tools available at the conclusion of the project timeline. Transcriptions made from the recordings and written notes made during the focus group will be stored in a locked file cabinet and accessible only by the research assistant and Jane Doe. The transcripts and notes will be shredded after three years. SURVEY EXAMPLE Survey respondents will be anonymous; no identifying information will be provided. The surveys will be number coded in advance and be given to women receiving care at the South End Community Health Center. The surveys will be placed in random order prior to distribution so, for example, the survey marked #1 will not likely be the first survey returned. Jane Doe will hand out the surveys to participants, and they will drop the completed form in a lock box that only the research team has the key to unlock. The research assistant will enter the data from the survey having had no contact with the participant. The surveys will be stored in a locked file cabinet. The surveys will be shredded after three years. 22. FURTHER INFORMATION: Is there other information that would help the IRB better understand your proposal? Please use this space to provide a rationale for why this data collection should be considered exempt or receive an expedited review. EXPEDITED REVIEW EXAMPLE FOR INTERVIEWS The Federal government specifies the research activities that (1) present no more than minimal risk to human subjects, and (2) involve only procedures listed in one of several categories, may be reviewed by the IRB through the expedited review procedure authorized by 45 CFR 46.110 and 21 CFR 56.110. Category 7 in that list specifies that one form of research that can receive an expedited review is research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural beliefs or practices, and social behavior) or research employing survey, interview, oral history, focus group, program evaluation, human factors evaluation, or quality assurance methodologies. This study will use interviews. The Federal guidelines also specify that for a project to qualify as expedited that identification of the subjects and/or their responses would not reasonably place them at risk of criminal or civil liability or be damaging to the subjects’ financial standing, employability, insurability, reputation, or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal. For these interviews, we believe that asking participants about their opinions of comic book material about a health issue poses no more than minimal risk to the participants, because identification of their responses would not reasonably place them at risk of criminal or civil liability or be damaging to the subjects’ financial standing, employability, insurability, reputation, or be stigmatizing. We also have taken measures to make sure that there is not a breach of confidentiality. HHS further defines minimal risk as "the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests." We believe that talking about comic book material will cause no greater harm or discomfort than if the research participants were talking about these topics with family, friends, and colleagues in daily life. EXEMPTION EXAMPLE FOR AN ANONYMOUS ONLINE SURVEY We believe that the collection of these data should be exempt from IRB review based on Exemption #2 of the HHS Human Subjects Research Regulations at 45 CFR Part 46. The criterion states that exemptions can be granted for: Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless: 1. information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; AND 2. any disclosure of the human subjects responses outside the research could reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects financial standing, employability, or reputation. This is an anonymous survey that does not meet the first "unless" condition (i.e., respondents cannot be identified, directly or through identifiers linked to the subjects). Thus, we believe that any survey that is totally anonymous such as this one should be exempt by definition. EXEMPTION EXAMPLE FOR FOCUS GROUPS We believe that the collection of these data should be exempt from IRB review based on Exemption #2 of the HHS Human Subjects Research Regulations at 45 CFR Part 46. The criterion states that exemptions can be granted for: Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless: 1. information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; AND 2. any disclosure of the human subjects responses outside the research could reasonably place the subjects at risk of criminal or civil liability or be damaging to the subjects financial standing, employability, or reputation. We will be conducting a focus group. Focus group subjects, of course, can be identified, but we believe that the project does not meet the second “unless” condition. We can guarantee confidentiality but not anonymity to the participants, but even if responses were disclosed outside of the research, we do not believe that the information obtained would reasonably place anyone at risk for criminal or civil liability, nor do we believe that there is any reasonable risk of damage to someone's financial standing, employability, or reputation. When you see the moderator's guide, you will see that all of the questions relate to opinions about a new phone application for tracking physical activity. We are not asking participants to disclose any personal information. 23. PRINCIPAL INVESTIGATOR’S SIGNATURE By submitting this form, I acknowledge and accept my responsibility for protecting the rights and welfare of human research participants as discussed in the Common Rule (45 CFR 46) and Belmont Report. I certify that I will comply with all applicable regulations and directions of the Institutional Review Board, which may include: 1. Conducting this research study as approved by the IRB 2. Submitting any changes to the protocol to the IRB for review and approval prior to implementation. 3. Monitoring and supervising investigators and research staff in the conduct of the research. 4. Maintaining accurate, current and complete records of all study materials including all IRB correspondence. 5. Complying with all state and federal laws as well as Emerson College’s institutional policies regarding the conduct of research with human subjects. Principal Investigator’s Name: