Current Study. In early 2017, the authors began a national study of family nurse practitioner (FNP) clinical education practices using a complex, national, cross-sectional survey approach. First the researchers created a sophisticated survey questionnaire to be completed by FNP students currently enrolled in their final clinical education course and a parallel survey for NP faculty. Next, IRB review for research meeting exempt criteria was sought and received from the PI’s home institution as well as both Co-PI’s institutions. In addition, an informational website dedicated to the research study was published online and all IRB approval letters, study information sheets, and other relevant documentation was posted for the public to see. The subject recruitment plan included recruiting up to 4,000 current FNP students and 1,000 FNP faculty from schools in all 50 states in the US using electronically delivered surveys via Qualtrics®. To reach potential subjects, Deans and Directors from all schools offering eligible programs were contacted by email to facilitate access to potential study participants. Despite a strong, evidence-based recruitment plan, several roadblocks were encountered which fall into 2 main categories: 1) there was widespread variability in understanding of IRB regulations and what they mean for survey researchers seeking access to potential student or faculty subjects, and 2) how the Federal Educational Privacy Rights and Privacy Act (FERPA) permits (or does not permit) researcher access to certain limited kinds of information about students currently enrolled in educational programs.
It is well-known that researchers conducting studies at the national level face significant barriers to recruitment and site access due to variations in the local interpretation and implementation of IRB requirements in each institution. While protection of the privacy and confidentiality of human subjects is essential and necessary, there is little evidence which suggests that repeated reviews by multiple Institutional Review Boards increases research participant protection (Mealer et al., 2017). Moreover, most education-related survey research falls under the exempt category when participant identity is not associated with survey responses. Many software programs used in large scale survey studies can provide additional protections by anonymizing responses even when individually identifiable information (e.g., name, email address) is used to invite subjects to participate in the study, further reducing concerns about privacy and confidentiality.
Methods. In the study discussed here, the study PIs initially made contact with the administrative contact (usually a dean or director) for each school and provided all relevant documentation related to the study’s purposes, its IRB approval status, and a notice that the study was being funded by a large grant from a well-known national nursing organization. Because of the strong response rates and relative overall efficiency associated with direct, personalized email invitations to potential subjects, the research team’s preferred approach was for schools to provide a very limited set of contact information for eligible students and faculty, comprised of name, email address, and for students only, their program of enrollment (MSN, post-master’s certificate, etc.). We encountered two main issues which ultimately forced us to modify our procedures in several regards.
Challenges with IRB. The first issue we encountered involved many schools’ requirements that we obtain additional local IRB approval before the program administrator could invite students and faculty to participate in the study. Despite clear federal guidance from the US Office for Human Research Protections (OHRP) that simply making potential subjects aware of research for which they may qualify and have an interest in participating, such as by forwarding a study invitation email – or even permitting access to potential subjects directly, such as by providing contact information for the potential subject – does not “engage” an institution in conducting the research, and therefore obviates the need for local IRB approval, many schools indicated that by policy or just historical practice, the research team would need to obtain local IRB approval before the school’s students or faculty could be invited to participate in our research. Because obtaining individual IRB approvals from potentially hundreds of different sites is prohibitive, alternative approaches to gaining approval were developed, with some success and will be discussed in this session.
Challenges with FERPA. The second issue we encountered was that schools were generally hesitant, and in many cases completely unwilling, to share a list of student and faculty contact information over concerns about compliance with FERPA guidelines for the privacy of student records. While this appears to be a common interpretation, many faculty and administrative leaders are unaware that FERPA permits disclosure of certain kinds of student information without additional student consent, so long as the school notifies students each year about what information may be disclosed. The mechanism by which FERPA provides for this disclosure is through what it terms “directory information”, which is limited non-confidential student information which may be released at the school’s discretion. Permitted disclosures of directory information typically include information such as name, email address, date of admission, program of enrollment, etc. The “directory information” provision within FERPA is what enables schools to provide searchable online directories of its students, to provide student contact information to job recruiters, and in publishing academic awards lists like Dean’s lists. To overcome site concerns related to FERPA, several optional strategies were employed with varied success and will be discussed during the session.
Overcoming barriers. Since gaining access to potential subjects proved more difficult than anticipated and the researchers had to develop and implement several innovative strategies beyond email solicitation using students' school-issued email address. To be successful, we developed innovative technology, social media and relationship-based solutions to reach potential participants. The use of technology and computer programs designed for survey research and data management is not new, however, but the sophistication and options available now provide researchers with opportunities to leverage recruitment in large studies for minimal costs. Likewise, the use of social media to access potential research participants has been reported in recent years (Howerton Child, Mentes, Pavlish & Phillips, 2014; Kosinski et al., 2016) however there are many issues to consider when thinking of using social media for recruitment, including, perhaps most importantly, verification of eligibility for inclusion in the study. While these issues are not new or unique to this study (Mealer, Flynn, Ironside, & Spurlock, 2017), rarely are strategies for addressing these issues shared between research teams. In this interactive session, the authors will not only share successful strategies but also the knowledge and theory behind successful navigation of potential roadblocks.