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***EFFECTIVE IMMEDIATELY***

IMPORTANT UPDATE for SU Researchers conducting Face-to-Face Research

Based on the current Syracuse University Fall 2022 Public Health Guidelines, the Institutional Review Board (IRB) and the Office of Research have determined researchers conducting face-to-face research are no longer required to submit a return to face-to-face research plan. In addition, approved plans are no longer required to be followed. All in-person interactions, including those with research participants, are required to follow current Syracuse University guidelines.

If you will be updating procedures currently approved in your approved IRB protocol, please submit a completed IRB Amendment Request Form to ORIP@syr.edu to update your protocol.

IMPORTANT UPDATE based on Stay Safe – Syracuse.edu:   (https://www.syracuse.edu/staysafe/) :

*IF* your study involves face-to-face/in-person research, please refer to the following options below:

• Submission of the Return to Face-To-Face Research Plan (RF2FRP) documents ARE required when:

• • Research Procedures conducted on-campus do not adhere to the current Syracuse University requirements: COVID Levels – Syracuse.edu
  • Research procedures conducted off-campus, in the United States, do not adhere to Guidance for COVID-19 | CDC
  • A researcher will travel internationally to conduct in-person research.

• Submission of the Return to Face-To-Face Research Plan (RF2FRP) documents are NOT required when:

• • Research protocols for on-campus research adhere to current Syracuse University requirements: COVID Levels – Syracuse.edu
  • Research procedures conducted off-campus, in the United States, adhere to Your Health | COVID-19 | CDC

Go to Stay Safe – Syracuse.edu:  for the latest University guidance and public health information

Submit a Return to Face-To-Face Research Plan (RF2FRP) in the Syracuse University Application Portal. The RF2FRP includes the following:

• Return to Face-to-Face Research Form
  • Study Team Isolation Contingency Plan can be described in the Return to Face-to-Face Research Form or uploaded as a separate document.
• Important Information about COVID-19 and Research Participation Sheet  completed by researcher(s) with project specific information.

IMPORTANT Update based on the University’s COVID-19 Update: Important Public Health Information:

*IF* your study involves face-to-face/in-person research, please refer to the following options below:

The return to face-to-face research documents ARE required when:

• Social distancing and masking cannot be maintained in an indoor research space.
• A researcher will travel internationally to conduct in-person research.

The return to face-to-face research documents are NOT required when:

• Social distancing and masking will be maintained in an indoor space.
• In-person research will take place outdoors.

•  Please use the link provided to access return to face-to-face research documents:
• Resuming Face-to-Face Human Participant Research
• Go to Syracuse University – Stay Safe for the latest University guidance and public health information.

IMPORTANT NOTE:

*IF* your study involves face-to-face research, please refer to the following options below:

The return to face-to-face research documents ARE required when:

• Social distancing and masking cannot be maintained with unvaccinated individuals.
• A researcher will travel internationally to conduct in-person research.

The return to face-to-face research documents are NOT required when:

• The research will only be conducted with vaccinated individuals.
  • Researchers should ask for proof of vaccination and document the date of last vaccination in their research records. If the participant does not provide proof, the researcher should follow procedures for unvaccinated individuals (see below).
• Unvaccinated individuals will wear masks and follow a social distancing plan. 

 Please use the link provided to access return to face-to-face research documents:

https://researchintegrity.syr.edu/resuming-face-to-face-human-participant-research/

Go to Syracuse University – Stay Safe for additional University guidance and public health information.

Effective August 31, 2020, research involving human participants that was halted by the COVID-19 emergency may resume and new human participant research may begin.
Please review the information on the Resuming Face-to-Face Human Participant Research page to learn more about resuming face-to-face research.

For the most recent updates and FAQs on COVID-19 for researchers, please visit the Office of Research website.

This webpage will be updated with further guidance as requirements change.  Link

**UPDATED** March 22, 2020 Link

Frequently Asked Questions

1. Which human participant research studies have to be paused?
   Given the current COVID-19 coronavirus outbreak, and the real or perceived risk of exposure, the risk/benefit ratio for research participation must be reassessed for each protocol. Ethical principles of research and federal regulations for the protection of human research participants require an acceptable risk/benefit ratio.Any biomedical or social, behavioral and educational study that involves in-person, face-to-face interactions with participants including faculty, staff, students and community participants must be paused until further notice in recognition of the COVID-19 pandemic. This directive is being made to decrease exposure for our staff, faculty and learners as well as research participants. Research studies that limit participant interactions to online or remote communication, telephone contact, remote monitoring, remote data collection or secondary data analysis may continue.

2. What if research involving face-to-face interaction with participants provides a direct health benefit?
   If a research activity involving face-to-face interaction with participants provides a direct health benefit and is considered an essential research activity [Coronavirus (COVID-19 Guidance for Researchers], the activity may continue. However, such studies must be approved for continuation by the Department Chair and Associate Dean for Research through the disclosure of essential research activities form. The Office of Research has provided the following online portal for the disclosure and approval of essential research activities: Syracuse University Disclosure of Essential Research Activities.

3. What will the Syracuse University IRB require for my study?
   The following information is ONLY applicable for studies regulated by the Syracuse University IRB. If your study is regulated by a non-SU IRB, you should consult directly with that IRB for their requirements.The federal research regulations require that the IRB review modifications to a study before they are implemented; there is one important exception, “where necessary to eliminate apparent immediate hazards to the human subjects.” 45 CFR 46.108(3)(iii).Should you determine that such changes in your procedures are required, you may implement them immediately, without prior notice to or approval from the IRB. Implementing protocol changes without prior IRB approval must be limited to changes directly related to eliminating an immediate hazard.

4. What changes can be implemented without prior notice or approval?

• Replacing in-person interventions/interviews/focus groups with telephone calls
• Replacing in-person interventions/interview/focus groups with video-conferencing
• Replacing in-person interventions/interviews/focus groups with other remote options

5. Rather than having participants come to Syracuse University, can I conduct home visits to collect data for my study?
   No. Traveling to a participant’s home still carries the COVID-19 related risks.

6. Do I need to submit a protocol deviation or amendment for all these changes?
   Syracuse University IRB policies require that changes to IRB-approved research may not be initiated without IRB review and approval, except when necessary to eliminate apparent immediate hazards to the subject (45 CFR §46.108(a)(3)(iii)). Syracuse University also has a responsibility to ensure the safety of its employees. Therefore, while Syracuse University’s plan for COVID-19 is in effect, these interim measures to reduce immediate hazards to research participants and staff are warranted and may involve deviating from IRB-approved study procedures prior to obtaining IRB approval.

• For studies that provide no direct health benefit to the participant (studies approved under 45 CFR 46.404 and 406): Protocols and parts of protocols may be paused without formal notification to the IRB to eliminate apparent immediate hazards to the subject. Conducting follow-up procedures with participants by telephone or video-conference while in-person data collection is paused also does not require prompt submission to the IRB. However, any deviations will need to be tracked by the investigator (see the FAQ regarding tracking protocol deviations below);
• For studies with a prospect for direct health benefit (studies approved under 45 CFR 405): If the risk outweighs the benefits, the study should be paused (as outlined above). If benefits are significant see FAQ #2.
• If investigators anticipate making the changes to their research plan permanent (e.g. substitute telephone surveys or video-conference for in-person visits), IRB approval of a protocol amendment must be sought.

7. Do I need to track the protocol deviations?
   Yes. If investigators deviate from their approved protocol to eliminate apparent immediate hazards, please keep track of these deviations and report them to the IRB with the next continuing review (if one is required).

8. How do I document the justification for these deviations in my study records?
   Investigators can use the following language: Due to the potential risks of COVID-19, Syracuse University has determined that all research studies that provide no direct health benefit to the participant should be paused, unless they can be effectively completed remotely.

9. I am conducting a study that is currently only approved to obtain written consent? Can I continue enrolling by just getting verbal consent over the phone?
   No. If the IRB did not waive the documentation of consent, written consent must be obtained.  Study teams may discuss the study with a potential subject and answer their questions over the phone, but must have a consent form signed by the participant and the person obtaining consent before any study procedures may begin.  One option is to have the discussion by phone, email the consent form to the subject, who can sign it and send it back to the study team (e.g. scan and email or send via USPS).  Another option is to submit a modification to the IRB to obtain verbal or electronic consent.

10. I have a continuing review due soon. Do I still need to submit it and should I include information regarding the pause in research activity in the submission?
    Yes. You still need to submit your continuing review on time. Please keep track of the deviations and pause in study activity and report this to the IRB with the next continuing review.

11. What is the effect of the pause on pending studies?
    The IRB will continue to review and approve submissions. For studies that are approvable, but involve in-person interactions with study subjects and do not have the potential for direct benefit, the IRB will approve the study but explicitly note that enrollment cannot start until the pause in face-to-face human participant research has lifted.

12. Do I need to let the NIH or other sponsors (e.g. industry) know that some protocol activities or in-person visits for a funded study will be paused?Investigators will need to work with their funders and regulatory sponsors to develop appropriate plans in light of the current circumstances. Contact the Office of Sponsored Programs (OSP) for questions regarding NIH and all other sponsored research.

13. How do I contact the Office of Research Integrity and Protections/Institutional Review Board Office?
    The office staff is working remotely, therefore, the office is only accepting electronic submissions until further notice. Please submit all IRB new applications, continuing renewals, amendment requests along with appropriate documentation to orip@syr.edu.Due to staff working remotely without physical protocol files, voicemail and email inquiries regarding existing or pending protocols will be answered as soon as possible, please be patient.

Share this information with research staff listed on your protocol as appropriate.

REVISED COMMON RULE
*EFFECTIVE JANUARY 21, 2019*

All studies approved after January 21, 2019 will be required to comply with the Revised Common Rule.
In most cases, the Common Rule changes will not impact your ongoing research.
The Syracuse University IRB is beginning to make changes to relevant policies and pertinent procedures in accordance with the Revised Common Rule.

For a more detailed description of the Common Rule changes, please visit the Common Rule page found here.