Overview of the Process

What is external research?

External research is the conduct of data collection activities (which may include but is not limited to the use of surveys, tests, interviews, focus groups, record reviews, or observations) from students, parents, or employees. This may also include data release which is the provision or release of non-public data to individuals outside of FCPS. Recruitment of study participants also falls under the purview of external research.  

All requests to conduct research require approval and must comply with Policy 1475 and Regulation 1475.

Learn More About:
Policy 1475

Regulation 1475

Which types of external research studies require approval?

• Conducting data collection activities (including but not limited to surveying, observing, or conducting focus groups or individual interviews) from students, parents, teachers, administrators, or other staff members.
• Requesting personally identifiable student information, personally identifiable personnel information, or other records held by the school division that are protected from disclosure under federal law, Virginia law, or school division policies or regulations.
• Using FCPS resources (staff, sites) to recruit participants for external research projects.

What type of external research is not allowed?

• Studies to fulfill undergraduate- or master’s-level or doctoral-level course requirements by individuals who are not FCPS employees (this includes these and Capstone projects).
• Studies that involve greater than minimal risk.
• Testing of a product for commercial purposes not related with the FCPS mission to educate children.

What is minimal risk?

Minimal risk is the probability and magnitude of harm or discomfort anticipated in the research, which 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.

Any proposed study that may involve more than minimal risk must be submitted to the Division Research Screening Committee. This committee will determine whether more than minimal risk exists.

Are any data collection activities allowed without research approval?

The following do not fall within the definition of external research and do not require approval:

• FCPS task forces, review groups, and committees gathering, having access to, or using data that are inherently required and customarily used in the discharge of their responsibilities and functions;
• Data-gathering procedures, tests, or other data accessing forms that FCPS teachers develop and use to assess their assigned students’ educational status and growth;
• Classroom work conducted by FCPS students in their schools;
• Information requested from Parent Teacher Associations (PTAs), Parent Teacher Student Associations (PTSAs), and school-related organizations directly from parent members. However, data collection activities directed toward FCPS staff members or students are subject to Regulation 1475; and
• Studies using publicly available FCPS data.

How is external research approved?

The Division Research Screening Committee reviews and approves external research requests during seven designated periods. Only complete application packets can enter the review process. An application packet is considered incomplete if it is missing any of the required items listed on the application.

The committee consists of a chair and other FCPS staff, both central- and school-based, with expertise in areas relevant to your study. The Office of Research and Strategic Improvement oversees this committee.

This committee makes every effort to ensure:

• Protection of privacy of FCPS students and staff and compliance with state and federal laws.
• All parties acknowledge that participation in research is voluntary.
• Anonymity of the Fairfax County Public Schools division, individual schools, and all individual persons participating is preserved in reporting the results.
• Limited interference upon instructional time and the educational process including scheduled testing and end-of-year activities at schools.

Who signs the Division Research Screening Committee application?

The Principal Investigator indicated on the IRB is responsible for signing the application for research in FCPS.

What criteria are used to screen a research application?

The committee considers each of the following areas:

• Relevance – The relevance and utility of the collected information for informing Division plans, goals, priorities, commitments, or specific interests;
• Technical Adequacy – The technical adequacy of the data collection design and instruments, as well as the feasibility, and the appropriateness of the data collection activities in a public school setting;
• Demand – The minimizing of time demands on respondents for participating in data collection activities, as well as the time demands for staff in overseeing, and supporting data collection activities;
• Legal, Ethical, and Political Considerations – Adherence to legal requirements, ethical aspects of data collection and reporting, and potential political consequences of a decision to approve or deny a proposal; and
• Benefit to FCPS – a specific benefit to FCPS for participating in the study. This should be in the form of a specific FCPS report or information for FCPS to make decisions or take action to improve conditions for teaching and learning in FCPS.

While each area is rated separately, a summative judgment is reached by weighing the potential benefit to FCPS against the demand of the study. Relevance and technical adequacy can be used to infer potential benefit if the application does not address this directly.

I paid the application fee and have all the required documents except for the approval letter from the IRB. Can I still submit my application packet to meet the submission deadline?

No, if we do not receive all of the required documents, including the IRB documentation, by the submission deadline, we will hold your application for the next submission deadline. If the required document is not received by then, the committee will close-out your application packet and you will receive a rejection notification.

You may re-submit the application when you receive the required document. No additional application fee is assessed for the first re-submission within three months of the same school year.

How long is the review process?

Typically, the review process is completed in approximately six weeks from the submission deadline. Other FCPS departments may be contacted regarding proposed methodology or consent procedures, which could extend the review an additional two weeks before a decision is made..

Once the committee completes its review, the Office of Research and Strategic Improvement will contact you, via email, informing you of the committee’s decision. The committee may decide to approve, defer, or reject an application.

What happens if the committee decides to approve my application?

You will receive an Acknowledgement of Researcher Responsibilities, which you must sign and email back to [email protected]. Upon receipt of this Acknowledgement, you will receive a final approval letter that will accompany the signed acknowledgment. You must be prepared to share both documents with the school/participants upon request. You may not begin data collection until you receive the final approval letter and you contact your FCPS sponsor or division contact.

What happens if my research request is deferred?

When a research request is deferred it means that the committee felt that the research request needed minor adjustments to obtain approval. If your research request is deferred, you will receive a deferral letter listing out the necessary changes to the application with a timeframe to submit the changes. If changes are not submitted within the given timeframe, the research request will be held until the next window, at which time an approval letter will be issued if the necessary changes have been submitted or a rejection letter will be issued if they have not.

What are the common reasons an application is deferred?

• Improper form of consent proposed or consent forms missing required elements (See Consent Requirements below);
• Data collection proposed during black-out window;
• Data collection proposed to occur before the completion of the approval process;
• An individual data collection activity is proposed to occur for longer than two weeks;

What are the common reasons an application is rejected?

• Incomplete application packet (missing supporting documents);
• Lack of sponsorship;
• Data collection involving greater than minimal risk;
• Legal, ethical, or political concerns;
• Anticipated demand outweighs potential benefit;
• Methodology that is not aligned with FCPS policy and practice;
• Little to no benefits to FCPS due to methodological concerns;
• Little to no benefits to FCPS due to lack of relevance to division strategic priorities.

If my application is not approved, can I resubmit?

No. For more information on the reason for rejection, please contact the chair at [email protected].

If you believe the review committee has misunderstood or missed information in the application that resulted in the rejection decision, you may appeal the decision by contacting the chair at [email protected]. Appeals for other reasons may not be submitted.

How long is the approval valid?

Approval is granted only for one school year at a time, ending on June 30th of each year. If you need to continue the study the following school year, you must submit a new application.

Can I make changes to an approved study?

Yes, with approval from FCPS. You must contact the committee chair first and submit a Research Modification Form to [email protected]. You may not implement any of the modifications before receiving approval for them. Also, you may be required to pay an additional application fee for the processing of the request.

When can approved data collection occur?

Research/data collection may occur on all dates with the exception of the reserved time periods called “blackout periods.” These dates are reserved for beginning-of-year and end-of-year activities and testing. There may be dates unavailable at specific schools that may also prevent research/data collection. It is the practice of the committee to approve data collection from only one external research study during a two-week period for the same stakeholder group. However, please be aware of the School Year Calendar and dates on which students and staff may be unavailable or not in buildings (e.g., Winter Break, Spring Break, Professional Development days).

Requests to conduct research during these reserved dates will not be approved. Participating schools may also choose to limit data collection to specific days or times.

See Blackout Dates 

If my research is approved, do I need to share the results with FCPS?

Yes, by signing the Acknowledgement of Researcher Responsibilities, which is required prior to receiving approval from FCPS, you commit to sharing the findings of your data collection with your sponsor and with FCPS' Division Research Screening Committee to provide benefit to the school division. If no reports or results of the research are shared, there is no benefit to the school division.

Fees

Why is there a non-refundable application fee?

The non-refundable application fee covers the administrative costs of processing of the application packet.

What happens when my application also includes a request for non-publicly available data FCPS already has?

There are two additional requirements for data requests or data analysis requirements; completion and approval of a data security checklist and a memorandum of understanding called a Data Agreement will be sent to the researcher for signature.

The data security checklist is a form required by the FCPS Department of Information Technology (IT) that evaluates the risk of releasing data from the FCPS community to those individuals external to FCPS.  Data security checklists must be completed by the Researcher or their IT department and submitted to FCPS’ Department of IT for approval.  Once approved, the Researcher may request the process to engage in a Data Agreement with the Office of Research and Strategic Improvement.

The Data Agreement will include the cost to complete the data provision based on an estimate of hours from all parties involved. We charge an hourly rate for data requests that require one or more hours of staff time. Once the data agreement is signed and returned to us and the fees are paid, we will begin processing the requested data. Data will be provided through the Research Screening Committee only. Do not contact other FCPS schools or offices to request extant data for approved research.

Can the application/data fee be waived?

Fee waivers are granted under limited circumstances (e.g., studies funded by internal sources, nonprofit community organizations, or government agencies).

If you believe you may qualify for a fee waiver, contact the Research Screening chair at [email protected]. You are responsible for providing detailed information to the chair to aid in decision-making. You will be notified of the committee’s decision.

How do I make payment electronically?

DRSC uses MySchoolBucks to receive electronic payments. The link below will take you to the FCPS central store. Electronic payment may be made via credit/debit card or by electronic check. The information requested to complete payment must match the information on the DRSC proposal  form. Further directions to complete electronic payment are provided on the website.

MySchoolBucks

Payment of data provision fees will also be handled through MySchoolBucks. A separate link will be sent to researchers as needed for the payment of the data provision fees.

Sponsorship

How do I find a sponsor?

When searching for an FCPS staff member to sponsor your research, you should consider both the position level and area of expertise of a potential sponsor.

Position Level

For studies planned to be conducted in more than one school or site, the sponsor must be a central office or region staff member at the level of director or above. For studies planned to be conducted at only one school site, a principal may be a sponsor. Region staff may only sponsor studies within their region. The sponsor should be in a position to understand how the research will benefit FCPS and whether it will conflict with ongoing FCPS initiatives.

Area of Expertise

The sponsor should have expertise in the subject area of your research that could potentially benefit from your research.

For information about FCPS departments or contact information, visit https://www.fcps.edu/.

If you need assistance in finding a sponsor, complete and submit your application and supporting materials and indicate on your application that you do not have a sponsor. The committee chair will attempt to identify an appropriate sponsor. Please note, if you submit your application on the submission deadline without a sponsor, your application will not enter the review process even if all other materials are received. If the chair cannot identify a sponsor within 10 business days, the research application will be rejected.

What does my sponsor do?

Your FCPS sponsor will:

• Submit a signed Sponsor Commitment Form directly to the committee on your behalf.
• Review your submitted application.
• Provide justification for the use of our resources and will help you identify schools to participate in your study and timelines for data collection.
• Serve as a liaison between you and FCPS.
• Monitor your compliance with your research agreement.
• Receive your written product.

Consent Requirements

Is informed consent required for studies?

Yes, we require informed consent for all data collection in our school district. The only exception to the informed consent requirement is for the release of anonymous FCPS data.

What is required on informed consent forms?

Informed consent must be provided to participants in writing and must contain the following elements:

• Purpose of the study
• What participants will do in the study
• Time requirements
• Risks/Benefits
• Privacy/Confidentiality
  • Data linked with identifying information (if applicable)
  • Anonymous data (if applicable)
  • Confidentiality cannot be guaranteed (if applicable)
• Voluntary participation
  • Right to withdraw from the study
  • How to withdraw from the study
  • What will happen to withdrawn participants' data?  
• Compensation/payment (if applicable)
• Contact information for questions about the study
• Signature and date of consent
• If audio-recording, separate consent must be obtained.

Applications not following this proper form of consent will be rejected.

If you intend to request identifiable data from FCPS, this should be specifically listed on consent forms (i.e., instead of saying “demographic data,” specify race/ethnicity, gender, English proficiency, free and reduced-price lunch status, and disability status). The legal guidelines on which data release procedures are based and drawn are from the Family Educational Rights and Privacy Act (FERPA; 20 U.S.C. § 1232g; 34 CRF Part 99).

FCPS will only provide individually identifiable information that is explicitly identified on the consent form. Personnel records of school staff are confidential, and information cannot be released from these records except in certain conditions and formats (FCPS Policy 4220).

Read more on consent requirements in Regulation 1475.

Is active consent required for studies?

Active consent is required for any data collection or the release of nonpublic data to external parties when the data identifies students, parents, or staff. We reserve the right to require active consent even if it is not required by state code or has been waived by an Institutional Review Board (IRB).

Typically, active consent can be in the form of a signed consent form or opt-in process (e.g., parents return a signed form indicating their child may participate).

What are the special consent requirements for research involving student participants?

If you are requesting/collecting personal identifying information on student participants (under 18 years of age who are not emancipated minors), you must obtain:

• Active consent from a parent or legal guardian. Active consent form must include:
  • A full description of what the student will be asked to do;
  • Potential risks and benefits of participation; and/or
  • Any information about the student that you plan to obtain; and
  • Name of parent, signature, and date;
  • Note: If students are being recruited to engage in research activities external to FCPS, consent forms must state that parents need to be present during those activities. The only exception to this requirement is for high school students participating in an external program with minimal data collection activities (e.g., a survey).
• Child assent, if student participants have the capacity to understand the proposed research. Child assent must:
  • Explain the required informed consent elements. Please use language appropriate for the student’s age/developmental level; and
  • Inform students that their parents have given permission for participation and that the student may decide for him or herself whether to participate.

If a student is 18 years or older, active consent must be obtained from the student.

Research Involving Sensitive Topics

What are sensitive topics (for students only)?

• Political affiliations or beliefs of the student or the student's parents;
• Mental health information, including psychological problems of the student or the student’s family;
• Sexual behavior, attitudes, or any other sexual information (not permitted for Grade 6 and under);
• 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 clergy;
• Religious practices, affiliations, or beliefs of the student or student’s parents;
• Income (other than that required by law to determine eligibility for participation in a program or for receiving financial assistance under such program);
• Medical information;
• Information on student health risk behaviors pursuant to Code of Virginia § 32.1-73.8; and
• Information on controlled substance related to alcohol, tobacco or illegal drugs, or controlled substances.

The Superintendent reserves the right to deem other topics as sensitive in nature and subject to these requirements.

What are the consent requirements when the data collection involves sensitive topics?

External parties collecting data on sensitive topics from students, as described above, shall obtain active parent consent, even if responses are anonymous. Parents/guardians must be informed about the following:

• How to decline their child’s participation;
• The nature and types of questions that will be asked;
• The purpose and age appropriateness of the survey;
• How the information collected will be used and who will have access;
• How student privacy will be addressed;
• Whether and how the findings will be disclosed.

In addition:

• For data collection involving sensitive topics, you must notify the parents/guardians 30 days before administration of the study to allow time for inspection of data collection instruments.
• Parents/guardians have the right to inspect data collection instruments as well as any additional materials used in connection with the data collection activity.

FCPS staff and students collecting data (e.g., surveys, focus groups, interviews) on sensitive topics shall notify their principal/director in advance of data collection.