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IRB Policy and Procedures

Policies and Procedures: Human Subjects in Research

Introduction

The University of Illinois at Springfield Institutional Review Board (IRB) operates under policies and procedures mandated by the U.S. Department of Health and Human Services and the Office for Human Research Protections. These policies are available for review at www.hhs.gov/ohrp/. This document is meant to serve both as a policy statement for the IRB at UIS, and as a handbook for investigators involving human subjects in their research.

Questions regarding this document or submission of materials should be directed to:

Dr. Lynn Pardie
Associate Vice Chancellor for Graduate Education and Research

Public Affairs Center Room 525
University of Illinois Springfield
One University Plaza
Springfield, IL  62703-5407

217-206-7230 (phone)
217-206-7623 (fax)
pardie.lynn@uis.edu

Deborah Koua, staff to the IRB, can also provide assistance.  She can be reached at 217-206-7409, koua.deb@uis.edu.

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Statement of Policy

The following statement of policy applies to all research conducted at or sponsored by the University of Illinois at Springfield.

1) Anyone conducting research or responsible for research involving human subjects must:

  • Adhere to the principles of Respect for Persons, Beneficence, and Justice embodied in the Belmont Report
  • Adhere to the policies and procedures set forth in this document

2) The decision of human subjects to participate in research governed by this policy must meet the standards of informed consent.  An individual’s decision to participate must be:

  • Voluntary, occurring as the result of free choice without compulsion or obligation
  • Based on full disclosure of the information needed to make an informed decision about whether or not to participate
  • Based on the subject’s comprehension of the information provided

If persons are involved as subjects who cannot legally give consent but are capable of assent, normally their assent to participate must be solicited in addition to the permission of a parent or guardian.

3) The selection of research subjects must be fair.  Subjects should not be selected for potentially beneficial research on the basis of favoritism, nor should risky research be targeted to subjects who are less powerful.

4) The procedures for recruiting subjects must protect their privacy and be reasonable in terms of their condition or circumstances.  No coercion, explicit or implicit, should be used to obtain or maintain cooperation.

  • Any payment made to subjects should not be so large as to constitute excessive inducement for participation
  • When access to subjects is gained through cooperating institutions or individuals, prior commitments made to the subjects about the confidentiality or other terms of the primary relationship should not be abridged

5) Risks to subjects must be minimized and should be justified by the anticipated benefits to the subject or society.

6) Adequate provision must be made to protect the privacy of subjects and to maintain the confidentiality of identifiable information.

7) Approval for conducting research with human subjects must be obtained prior to any involvement of the subjects.  All such research protocols must be reviewed by the UIS Human Subjects Research Officer; the IRB; or in cases of signed, written agreements between a department and the IRB, by a designated departmental review officer. 

8) This policy does not apply to routine course, workshops, or curriculum development using accepted educational practices sponsored by the University of Illinois; or to aid or services provided by professionals to their clients. 

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Scope of Policy

This policy applies to any research activity conducted at or sponsored by the University of Illinois at Springfield that involves human subjects.  The policy is relevant to research in which an investigator 1) obtains data through intervention or interaction with an individual or 2) obtains private information by which an individual could be identified.  The policy is therefore applicable to research involving human beings whose physical, emotional, or behavioral conditions, responses, tissues, or fluids are investigated for research purposes (that is, for any reason other than the sole purpose of benefiting the subject as an individual).  It applies to the use of interviews, tests, observations, and inquiries designed to elicit or obtain nonpublic information about individuals or groups, as well as the study of existing public or privately held records where the identity of individuals is known. 

The policy is applicable whether the research is undertaken on a large or small scale and whether or not it is externally funded.  Pilot projects, student dissertation and thesis projects, independent study projects, and course projects must follow this policy if they involve research with human subjects.

UIS will waive human subjects review for studies aimed at improving institutional effectiveness that are carried out by administrative units.  The responsible administrator should contact the Human Subjects Review Officer prior to conducting the study in order to confirm eligibility for the human subjects review waiver.

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UIS Institutional Review Board

The IRB shall consist of a minimum of five persons with varying backgrounds.  The IRB must include at least one member whose primary concerns are in scientific areas and at least one member whose primary concerns are in nonscientific areas.  It must also include at least one member who is not otherwise affiliated with the institution and who is not part of the immediate family of a person who is affiliated with the institution. 

A quorum shall be met if more than one half of the members are present and voting at any meeting.  Members shall be appointed by the Chancellor upon recommendation from the Vice Chancellor for Academic Affairs, and shall serve for terms of three years.  There is no limit on the number of terms an individual can serve.

The Human Subjects Review Officer (HSRO) is appointed by the Chancellor.  Duties of the HSRO include, but are not limited to:

  • determining the appropriate level of review for protocols
  • calling and chairing meetings
  • maintaining files
  • reporting IRB decisions to researchers, and to campus and external officials as required

The IRB may, at its discretion, invite individuals with competence in special areas to assist in the review of issues that require expertise beyond or in addition to that available on the IRB.  These individuals are not considered voting members of the IRB.

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Meeting Schedule

The IRB meets several times each semester, and posts its meeting schedule on its website (www.uis.edu/grants/irb/index.html).  Protocols and supporting materials are due to the Grants and Contracts Office, MS PAC 525, at least two weeks before each meeting date.  Materials not received in a timely fashion will be discussed at the next regularly scheduled IRB meeting.  Researchers submitting protocols during semester breaks, or any time when faculty are not normally on campus, may need to allow additional time for the approval process.  Researchers (and their faculty adviser, when applicable) are required to attend the IRB meeting at which their protocol is discussed.

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Fundamental Principles

In 1978, the National Commission for the Protection of Human Subjects in Biomedical and Behavioral Research developed broad ethical principles to provide a basis on which specific rules could be developed.  These principles, discussed in The Belmont Report, are: respect for persons, beneficence, and justice.

Respect for persons – this principle specifies that individuals should be treated as autonomous agents, and that persons with diminished autonomy are entitled to protection.  In most cases of research involving human subjects, respect for persons demands that subjects enter the research voluntarily and on the basis of adequate information about the research situation and possible consequences. 

Beneficence – this principle requires investigators to maximize possible benefits and minimize possible harm.  Learning what will, in fact, benefit may require exposing persons to risk. Careful consideration must be given to determine when it is justifiable to seek certain benefits, despite the risks involved, and when the possible benefits should be foregone because of the risks.

Justice – this principle requires researchers to carefully consider the selection of research subjects.  An injustice occurs when some benefit to which a person is entitled is denied without good reason, or when some burden is imposed unduly.  The selection of research subjects needs to be scrutinized in order to determine whether some groups are being systematically selected simply because of their easy availability, their compromised position, or their ability to be manipulated, rather than for reasons directly related to the problem being studied.

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Definition of Terms

This section is intended to provide definitions of terms and provide guidance to investigators.

Human Subjects Research – research is defined as any systematic gathering and analysis of information that aims to test a hypothesis, to discover some unknown principle, or to re-examine some known or suggested principle.  The term research includes:

  • studies in which any substance or stimulus is administered to a subject by any means
  • studies that involve changes in physical or psychological state or environment or major changes in diet
  • interviews, surveys, tests, observations, and inquiries designed to elicit or obtain nonpublic information about individuals or groups
  • studies of existing public or privately held records where the identity of individuals is known
  • course assignments in which students are asked to conduct research involving human subjects

The term “research” is not intended to apply to:

  • routine course, workshop, or curriculum development using accepted educational practices sponsored by the University of Illinois, including evaluation to determine student/participant satisfaction, attitude change, and/or knowledge gained during the educational experience
  • aid or services provided by professionals to their clients that are consistent with accepted and established practice, and intended only to meet the clients’ own personal needs

Human Subject – the term human subject means an individual about whom an investigator conducting research obtains data through intervention or interaction with the individual, or obtains identifiable private information.

Intervention includes both physical procedures and manipulations of the subject or the subjects’ environment that are performed for research purposes.  Interaction includes communication or interpersonal contact between the investigator and the subject.  Private information includes information about behavior that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place, as well as information that has been provided for specific purposes by an individual with the reasonable expectation that it will not be made public (for example, a medical record).  Information is individually identifiable if the identity of the subject is associated with the information or can be readily ascertained by the investigator.

The definition of subject excludes all accepted and established service relationships, such as normal relationship of patients to physicians, students to instructors, and other clients to professionals in which the patient, student, or client is receiving aid or services consistent with accepted and established practice, that is intended only to meet her or his own personal needs.

Responsible Project Investigator – a qualified staff or faculty member must serve as the responsible investigator and oversee the conduct of research involving human subjects.  In cases of student theses or dissertations, this person is normally the student’s project adviser.

Informed Consent – participation in research must be voluntary and be based upon adequate knowledge and understanding of relevant information.  The informed consent process ensures that both of these principles are followed in all research involving the participation of human subjects.

The methods used to obtain consent may vary.  They should be designed to fit the nature of the research; the nature and magnitude of the risks involved; the research setting; the nature of the subjects who will participate; and the requirements of applicable policies, laws, and regulations.

Minimal Risk – research is defined as having minimal risk if the risks of anticipated harm are not greater, considering probability and magnitude, than those ordinarily encountered in the subject’s daily life or during the performance of routine physical or psychological examinations or tests.

Children – children are persons who have not attained the legal age for consent to treatment or procedures involved in research.  In Illinois, this age is 18 years.

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Review Procedures

All research involving human subjects that is conducted at or sponsored by the University of Illinois at Springfield must comply with federal policy for the protection of human subjects.  This policy applies whether the research is funded or unfunded, and whether it is conducted by faculty, staff or students.  It applies to pilot projects, student thesis and dissertation projects, independent study projects, and course projects if they involve human subjects.  The Institutional Review Board and authorized departmental review bodies share responsibility for ensuring that all UIS research activities meet both federal and campus policy.

How to Obtain Approval for Human Subject Research

Any research involving human subjects must be submitted to either the Human Subjects Review Officer, or the designated departmental review officer authorized to approve exempt research. (Note: As of January, 2008, departmental authorization to approve exempt research has been granted to the UIS Psychology and Communications programs.)

A research project may be exempted from full review if the only involvement of human subjects will be in one or more of the six categories listed in Section B below.  Regardless of the researcher’s view of the project’s fit one of these six categories, a protocol for research involving human subjects must be submitted to either an authorized academic department or the UIS Human Subjects Review Officer (HSRO).  Upon completion of review by the department, HSRO, or IRB, a letter will be sent to the researcher (and faculty adviser in the case of student research) authorizing initiation of the project or noting stipulations that must be met before approval is granted.  The portion of the research project involving human subjects cannot be undertaken until formal approval to proceed is granted.

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Categories of Human Subject Research not requiring full IRB review

Research in any of the following six categories may be exempt from full IRB review.  The following categories are defined in the Federal Policy for the Protection of Human Subjects.

  • Federal Regulation 46.101(b)1
Research conducted in established or commonly accepted educational settings, involving normal education practices such as research on regular and special education instructional strategies, or research on the effectiveness of or the comparison among instructional techniques, curricula or classroom management methods.
Limitations
Subjects must be placed at no more than minimal risk. 
The consent of authorized school officials can serve in lieu of consent of the individual subjects, but consent must be obtained in an appropriate way.  Children with the capacity to give assent are normally asked to do so.
Confidentiality of identifiable information must be maintained without the expressed permission of the subjects to do otherwise.
  • Federal Regulation 46.101(b)2
Research involving the use of educational tests (diagnostic, aptitude, achievement), survey procedures, interview procedures or observation of public behavior, unless:
  • Information obtained is recorded in such a manner that human subjects can be identified, directly or through identifiers linked to the subjects; and
  • 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.
Limitations
Subjects must be placed at no more than minimal risk.
If the research is undertaken in a commonly accepted educational setting, the consent of authorized school officials can serve in lieu of consent of the individual subjects.  Otherwise, consent of the subjects or their authorized representatives must be obtained.  Children with the capacity to give assent are normally asked to do so.
Confidentiality of identifiable information must be maintained without the expressed permission of the subjects to do otherwise.
  • Federal Regulation 46.101(b)3
Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior that is not exempt under paragraph (b)(2) of this section if
  • Human subjects are elected or appointed public officials or candidates for public office, or
  • Federal statues require without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter.
Limitations
Subjects must be placed at no more than minimal risk.
Confidentiality of identifiable information must be maintained without the expressed permission of the subjects to do otherwise.
  • Federal Regulation 46.101(b)4
Research involving the collection or study of existing 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.
Limitations
Subjects must be placed at no more than minimal risk.
The requirement for consent of the subjects is waived if the data, documents, records, or specimens, etc. are publicly available.  The authorization of the custodian of the data can serve in lieu of specific subject consent for access to data, which are not publicly available.  In such cases, the investigator must be satisfied that the custodian is authorized to release the data for research purposes.
  • Federal Regulation 46.101(b)5
Research and demonstration projects which are conducted by or subject to the approval of department or agency heads, and which are designed to study, evaluate, or otherwise examine:
  • Public benefit or service programs
  • Procedures for obtaining benefits or services under those programs
  • Possible changes in or alternatives to those programs or procedures
  • Possible changes in methods or levels of payment for benefits or services under those programs
  • Federal Regulation 46.101(b)6
Limitations
Such work cannot be exempted if prior review is specifically required by statute, or if the Secretary of HHS determines that a research or demonstration project presents a danger to the physical, mental, or emotional wellbeing of a participant or subject of the research or demonstration project.
Taste and food quality evaluation and consumer acceptance studies if
  • Wholesale food without additives are consumed
  • Food is consumed that contains a food ingredient at or below the level and for a use found to be safe
Different standards apply is the research is governed by HHS

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Review of Research Involving Human Subjects

The IRB review process hinges on the following, each of which is described in detail below:

  • Informed consent
  • Level of risk
  • Selection of research subjects
  • Assurance of confidentiality of identifiable subject information

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Informed Consent

As noted earlier, the participation of human subjects in research must be voluntary.  Each subject must give informed consent or, if a subject lacks the capacity to consent, an authorized representative must consent.  The principle of voluntary participation of subjects applies whether or not the research is federally funded and whether or not the research requires full IRB review.  Federal regulations regarding informed consent are listed here:

Federal Regulation 46.117 Documentation of Informed Consent

Informed consent shall be documented by the use of a written consent form approved by the IRB and signed by the subject or the subject’s legally authorized representative.  A copy shall be given to the person signing the form.

The IRB may waive the requirement for the investigator to obtain a signed consent for some or all subjects if it finds that the only record linking the subject and the research would be the consent document and the principal risk would be potential harm resulting from a breach of confidentiality.  Also, if the research presents no more than minimal risk of harm to subjects and involves no procedures for which written consent is normally required outside the research context the consent form may be waived.  In cases where the documentation requirement is waived, the IRB may require the investigator to provide subjects with a written statement regarding the research.

The basic elements of informed consent are presented below.  Not all items will be applicable to every project, but the language used in every consent form should be understandable to the subject or representative (the UIS IRB recommends an 8th grade reading level or below for information given to the general population).

  • Statement that the study involves research
  • Explanation of the purposes of the research
  • Expected duration of the subject’s participation
  • Description of the procedures to be followed
  • Identification of any experimental medical treatments or procedures
  • Statement that participation is voluntary
  • Statement that refusal to participate will involve no penalty or loss of benefits to which subject is otherwise entitled
  • Statement that the subject may discontinue participation at any time without penalty or loss of benefits to which the subject is otherwise entitled
  • Explanation of any compensation and, if appropriate, procedures to pro-rate compensation for subjects who withdraw prior to completion of the study
  • Description of any reasonably foreseeable risks or discomforts
  • Description of any benefits to the subject or to others which may reasonably be expected from the research
  • Disclosure of appropriate alternative procedures or courses of treatment, if any, that might be advantageous
  • Statement describing the extent, if any, to which confidentiality or records identifying the subject will be maintained
  • Name and telephone number of person to contact for questions about the research, and name and telephone number of responsible project investigator, if different
  • Name and telephone number of person to contact for questions about research subjects’ right (Human Subjects Research Officer, 217-206-7230)
  • Name of person to contact in the event of research-related injury or trauma
  • Statement that subjects may have a copy of the consent form
  • Language is understandable to the subject or representative
  • No language through which the subject waives any of his or her legal rights, including any release of the university or its agents from liability or negligence

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Level of Risk

There are different risks inherent in different research procedures.  For purposes of safeguarding human subjects, risks are classified as either minimal risk or more than minimal risk.  Under minimal risk, the risks of harm in the proposed research are no greater, considering probability and magnitude, than those ordinarily encountered in the subject’s daily life or during the performance of routine physical or psychological examinations or tests.

The potential for physical risk is most obvious in procedures requiring medical intervention or involving strenuous exertion.  There is a wide range of medical, social and behavioral research that may pose no immediate physical risk to the subject, buy may involve varying degrees of emotional stress, deceit, invasion of privacy, etc.  It is the investigator’s responsibility to minimize the risks associated with any research and to make clear to the research subjects any benefits that may result to them directly or more generally to society.  Direct payments or other forms of remuneration to the research subject are not considered to be benefits of participation.  Evaluation of the risk/benefit ratio is a primary consideration in the IRB review of research proposals.

 

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Recruitment of Research Subjects

The selection of subjects must be carefully considered.  Subjects should not be selected for potentially beneficial research on the basis of favoritism, nor should risky research be directed to subjects who have limited power.  Certain groups, such as the economically disadvantaged, the very sick, and the institutionalized, may have compromised capacity for free consent, and should be protected against the danger of being involved in research solely for administrative convenience or because they can be relatively easily manipulated.

No coercion, explicit or implicit, should be used to obtain or maintain cooperation.  When the investigator has a specific relationship—faculty-student, professional-client, employer-employee—with a potential subject, special care must be taken to ensure that the subject feels completely free to decline to participate.  Where access to subjects is gained through cooperating institutions or individuals, care should be taken not to abridge prior commitments made to the subjects about the confidentially or other terms of the primary relationship.

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Confidentiality

In all research involving human subjects, confidentiality of identifiable information is presumed and must be maintained unless the investigator obtains the expressed permission of the subject to do otherwise.  The more sensitive the material, the greater the care that must be exercised.  Ordinarily, the following requirements must be met:

  • Data gathering instruments (e.g. questionnaires) should be carefully designed to limit the personal information to be acquired to only that which is essential
  • Data that could reveal a subject’s identity should be stored in files accessible only to the project investigator and authorized staff
  • As early as feasible, the data should be coded to remove identifying information
  • The identity of subjects must not be released except with their expressed permission
  • Use of existing data that were originally obtained for different purposes and that involve identifiable subject information requires an examination of the risk involved.

Some research projects utilize audio and video taping of research subjects.  Subjects should always be told in the informed consent that taping will occur, how tapes will be disposed of, and when disposal will occur.  Explicit consent must be obtained for any public use of the tapes such as use in the classroom or as part of a public presentation of the research results, since this constitutes a waiver of the normal confidentiality of research data.

Some studies involve collection of data on sensitive matters such as sexual behavior or criminal activities.  There have been instances in which the identities of subjects or research data have been sought by law enforcement agencies.  Researchers can obtain an advance grant of confidentiality that will provide some protection even against a subpoena for research data.  Please contact the HSRO if you have questions on this matter.

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Continuation Reviews

The IRB and IRB-approved departmental review bodies conduct continuing reviews of research at intervals appropriate to the degree of risk, but at least once per year.

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Record Retention

Federal regulations and University of Illinois policy require that all records relating to the IRB and to human subjects activities be retained for at least three years after completion of the research.  Records, including signed consent forms and collected data, must be accessible for inspection at any time.

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Research Involving Special Subject Groups

Children

The following special requirements are imposed on all research involving children.  In Illinois, individuals under the age of eighteen are usually considered children.

Permission of Parents or Guardians

When children are subjects in research, the permission of the child’s parent(s) or guardian(s) must usually be obtained prior to the child’s participation.  The requirements for obtaining parental permission are essentially the same as those for obtaining consent.  The permission of one parent is usually sufficient, especially if the research does not involve greater than minimal risk.  Special provisions must be met for children who are wards of the state.

Assent of Children

In addition to parental permission, the investigator must obtain the assent of the children who are to be subjects in the research, as long as those children are capable of providing assent.  A child’s desire not to participate in a given research project should be respected by the investigator, even if parental permission has been granted.  The level of information provided to the children will vary depending on age and sophistication of the children involved.  It can vary from a simple description of what the children will experience to the equivalent of the information that would be presented to an adult subject.  All children capable of assent must be informed that they are free to withdraw from participation at any time.

Waiver of permission and assent

Under some circumstances the IRB may waive some or all of the parental permission and child assent requirements. Some examples of instances when waivers may occur include:

  • The research protocol is designed for conditions or for a subject population for which parental or guardian permission is not a reasonable requirement to protect the subjects (for example, neglected or abused children) and
  • An appropriate mechanism is devised for protecting the children who participate in the research and
  • The waiver is not inconsistent with federal, state or local laws.

Prisoners

In addition to the requirements listed elsewhere in this policy, the following requirements apply to all research involving prisoners.

  • All research involving prisoners must be reviewed by the IRB
  • Any possible advantages accruing to the prisoner through his or her participation in the research, when compared to the general living conditions, medical care, quality of food, amenities, and opportunity for earnings in the prison are not of such a magnitude that his or her ability to weigh the risks of the research against the value of such advantages in the limited choice environment of the prison is impaired.
  • The risks involved in the research are commensurate with risks that would be accepted by non-prisoner volunteers.
  • Procedures for the selection of subjects within the prison are fair to all prisoners and immune from arbitrary intervention by prison authorities or prisoners.  Unless justified, the control subjects must be selected randomly from the group of available prisoners who meet the characteristics needed for that particular research project.
  • The information is presented in language that is understandable to the subject population
  • Adequate assurance exists that parole boards will not take into account a prisoner’s participation in the research in making decision regarding parole, and each prisoner is clearly informed in advance that participation in the research will have no effect on his or her parole

Fetuses, Pregnant Women and Human Tissues

In addition to the requirements listed elsewhere in this policy, the following requirements apply to all research involving fetuses, pregnant women, and human in vitro fertilization.

  • All research involving these groups must be reviewed by the IRB
  • Research is permitted only under the following conditions:
  • Appropriate studies on animals and nonpregnant individuals have been completed
  • Except where the purpose of the research is to meet the health needs of the mother of the particular fetus, the risk to the fetus is minimal and, in all cases, is the least possible risk for achieving the objectives of the research
  • Individuals engaged in the research will have no part in any decision as to the timing, method, and procedures used to terminate the pregnancy and determining the viability of the fetus at the termination of the pregnancy
  • No procedural changes that may cause greater than minimal risk to the fetus or the pregnant woman will be introduced into the procedure for terminating the pregnancy solely in the interest of the research
  • No inducements, monetary or otherwise, may be offered to terminate the pregnancy for the purposed of the research.

Student Research

All research conducted by UIS students must be supervised by a UIS faculty member.  That faculty member is responsible for:

  • the quality of the design of the research protocol
  • ensuring that the student is informed about the Policies and Procedures that apply to all research conducted at or sponsored by the University of Illinois at Springfield
  • preparing the student to fulfill the responsibilities associated with conducting the research
  • keeping the HSRO apprised of any changes in the status of the protocol