IMPORTANT NOTES regarding the 2008-09 Academic Year:

• We are pleased to welcome Kathy Hayes as the new chair of the committee. Dr. Hayes is happy to be succeeding Artineh Samkian as the comittee's new leader. Please feel free to contact her any time with any questions you have about the information presented below.
  
• The district has undergone and continues to face reductions in its workforce due to state budget cuts. For this reason, our ability to support external research projects, including the staff time allocated to review and comment on proposals, during this year has become increasingly limited. Only proposals that have a clear, direct, and immediate benefit to the district in terms of informing practice will be considered for approval. We are also limited in our ability to provide access to student data. Please understand that we can only accommodate requests for data that do not involve merging of data from different sources or across multiple school years. We have also reduced the amount of time proposers have to re-submit applications upon invitation to do so, from 30 days to 20 days following the notice of non-approval. If you have any questions, feel free to contact the committee chair.

Anyone wishing to access Los Angeles Unified School District (LAUSD) resources to conduct research studies—other than studies conducted by LAUSD—must obtain approval from the Committee for External Research Review (CERR) housed in the Research and Planning Division. The following guidelines describe the general principles underlying the review process and the procedure to follow in submitting a research proposal for review.

Application Windows for the 2009-10 Academic Year

We are accepting proposals to conduct research involving LAUSD resources during the following periods during the 2009-10 year:

• July 6-17, 2009
• October 5-16, 2009
• January 4-15, 2010
• April 5-16, 2010

We will accept proposals during each application period on a first-come-first-served basis. Once review capacity is reached during a given window (i.e., we have exhausted our supply of reviewers), proposals will no longer be accepted during that period. Researchers will then have two options 1) to submit again during the next application window (If your project is on a tight schedule, we recommend submitting as early as possible during the next upcoming application window). or 2) the researcher can choose to pay for the review (see below for the Fee for Review Policy). Please submit any questions you have about the process to the committee chair.

Fee for Review Policy

Once we have reached our capacity in terms of regular staff time to review proposals within a given application window, a researcher may still submit a proposal for review. Such a review would be conducted for a fee. The fee covers the additional staff time required for two independent reviewers to review the proposal and provide feedback and recommendation to the Chair of Committee for External Research Review (CERR) as well as time for the Chair to review and make a final decision. The fee also covers the review of any resubmission should the reviewers recommend that the proposal be revised and resubmitted. The current fee is $415.00. This fee does not guarantee that the proposal will be approved by the CERR, only that it will be reviewed and an approval or rejection will be provided to the researcher. This fee does not cover the cost of a second resubmission should the initial submission be rejected by CERR.

See Frequently Asked Questions

Guidelines for External Research Review

I. General Principles

II. The Approval Process

III. Required Proposal Elements

IV. Legal and Ethical Principles

I. General Principles

LAUSD recognizes the value of high-quality research for improving education and serving the needs of future generations of students. On the other hand, the District has legal and moral obligations that require oversight of research activities conducted with district resources (such as data, facilities, employee time, and access to students). These obligations include:

• Protecting students and employees from risk of harm, violations of rights, and losses of privacy
• Protecting the educational process from unwarranted distractions and interruptions
• Protecting public resources including data from misappropriation for private or unjustified use

Research conducted in LAUSD or with its resources must be justified in terms of the anticipated benefit to the District and not merely to the advancement of knowledge. LAUSD encourages research in the following areas:

• Improving educational outcomes across all or selected subgroups of students
• Improving our understanding of children’s emotional and cognitive development
• Improving the design and delivery of services that promote learning
• Improving the management of the school environment
• Improving community involvement in education

Research should be designed to answer well-formed research questions of educational importance, and it should use methods that are appropriate to the research questions. Elements of the research design, including the theoretical framework, hypotheses, sample selection, instruments, and analysis plan should support the goals of the research, and it is the responsibility of the researcher to communicate these things clearly in the proposal. Even research that imposes no risks may be rejected by the review committee if they judge it to be poorly designed, described, or justified.

CERR approval does not impose any obligation on any person, school, or office to cooperate with researchers. The burden on respondents should not be excessive. However, time has very different values in different contexts, and only participants can decide whether the cumulative burden on them is acceptable. Researchers bear responsibility to inform potential respondents of the anticipated benefits and burdens in obtaining their consent. Of course, no research may be conducted at a school site without the informed approval of the principal.

Furthermore, CERR approval does not constitute any agreement to release administrative or educational data to researchers. Depending on the research design, substantial time and effort may be required for staff to provide requested data with the appropriate selection and matching of records and concealment of personal identities. Such assistance must be requested directly from the appropriate District offices, and provided at their discretion.

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II. The Approval Process

A. Formatting Your Research Proposal

Any researcher wishing to conduct research for a purpose external to the district is invited to submit a proposal for review during a designated application period. Only one proposal per researcher is permitted per window. Review of proposals submitted and accepted during a given application window are generally completed within 20 working days following the date at the start of the application window (for example, if were accepted a proposal from you for review during the September 1 - 15 period, you could reasonably expect to have an answer from us by September 30). The proposal should address each of the required elements (A through K) delineated in section III below and should not exceed ten pages (assuming single line spacing). Proposals that do not address one or more of the required elements or exceed the page maximum will not be considered for review.

In order to expedite research requests, we ask that you present your research proposal in an acceptable electronic format. Our preference is that you prepare your document using Adobe’s portable document format (.pdf), which preserve the integrity of the original document. If you do not have a copy of Adobe Acrobat (Adobe Acrobat Reader does not have the capacity to write pdf files, only to read them), you can use a trial version available at Adobe’s web site: http://createpdf.adobe.com.

If you prefer, you may submit your proposal as a word processor file. Either Microsoft Word or Corel WordPerfect is acceptable. However, note that significant formatting differences may occur in different computing environments, and it is your responsibility to ensure that your proposal can be read clearly. For this reason, the pdf file is the preferred format.

B. Submitting Your Research Proposal File

Please e-mail your proposal to the committee chair, Kathy Hayes, at kathy.hayes@lausd.net along with necessary supporting materials. In the subject line of your email message, please include the last name of the principle investigator, the abbreviated name of the institution (e.g., "UCLA" or "CGU") and the word Proposal. Following this procedure helps us to be identify the proposal quickly and ensure that it gets processed in a timely manner. Email is the only acceptable mode of submitting a proposal. Mailed of FAXed proposals will not be considered for review.

Once your proposal has been received, you will receive a message from the chair acknowledging receipt of your proposal with a confirmation number. Keep this number handy and use it whenever corresponding with the chair about a proposal you submitted. If you do not receive a confirmation number within 48 hours, contact the chair to inquire. It is the responsibility of each external researcher to ensure that the proposal reaches the committee and that all materials are readable and available to the committee in order for the review process to start. Our committee cannot be held responsible for reviewing proposals that are damaged or lost in transit.

C. Review of Your Research Proposal

Proposal review generally takes ten working days to complete. If approved, you will be notified by e-mail and will receive an electronic copy of an approval letter signed by the Chair. The letter will indicate that CERR has approved your proposal for research within LAUSD, but will not authorize you to claim LAUSD support or endorsement for your research.

If your proposal is not approved, you may be given the opportunity to submit a revised proposal at the discretion of the committee. If this is a case, a new copy of the revised proposal must be submitted to the Chair for consideration. If the proposal is not re-submitted within 20 days of the notice of non-approval, and the guidelines for re-submittal are not addressed to the satisfaction of the review committee, the proposal will be rejected.

D. Statement of Agreement

We require that all researchers sign a statement of agreement. This statement establishes that your research activities within Los Angeles Unified School District are in compliance with existing legal and ethical codes. It further establishes that the research you perform will not differ significantly from the research proposed, and that you are to provide the Committee with an executive summary of your findings. Violation of this statement of agreement will be considered a breach of contract.

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III. Required Proposal Elements

The following elements are required in every proposal and should be clearly identified and presented in the correct order (sections A through K). It is not the responsibility of reviewers to search for hints of the required elements in the text of your proposal. If an element is not considered relevant to the proposal, please provide a brief reason that it is inapplicable rather than simply ignoring the requirement. Proposals that do not follow this format will not be considered for review.

A. Title of Project

B. Researchers’ Identities and Titles

Include the following information for the principal investigator of the proposed study:

1. Name
2. Title
3. Email address
4. Mailing Address

Formal correspondence regarding acceptance of proposals will be addressed to the principal investigator. Include the same information for the main contact person if different from the principal investigator. This contact information will be used for notification of proposal review status, questions about missing documents, etc.

C. Institutional Support

Professional: Research is sponsored by universities, governmental agencies, or by similar nonprofit organizations engaged in scholarly research. Submit the name of a supervisor or dean, with contact information.

Graduate Student: Research is sponsored by a graduate school or university and supervised by a faculty member. Submit a letter of sponsorship from the faculty advisor, with contact information.

Other: Research may sometimes be sponsored by a for-profit entity such as a textbook publisher, or a non-profit agency with a primary mission other than scholarly research. Because of the potential for biased outcomes, inappropriate incentives, and misappropriation of public resources, the proposal will be held to an extremely high standard of validity and justification in terms of benefit to the District. Submit a letter of endorsement with contact information from an independent monitor with a university professorship or equivalent research status.

D. Statement of Purpose

State clearly what you intend to accomplish with this research.

E. Research Questions, Hypotheses, Literature, and Anticipated Contribution

State briefly the research questions you plan to address, along with any hypotheses. Also provide a brief statement of the theoretical basis for your study from prior published research (include references in APA format), and what contribution your work is expected to make in that context.

F. Sample, Methods and Analysis

Describe the target population, sampling frame, and selection procedures. Describe the methods that you will use and why they are appropriate for your research questions and your sample. Also describe your anticipated analysis plan (essential), including specifics regarding your treatment of the data, statistical or otherwise.

G. Instrument(s)

Include any survey or other instruments to be used. Include results from pilot testing and/or other evidence for the validity of the instruments. Although conditional approval may be granted on the basis of preliminary instruments, the complete and finalized instruments must be submitted before research can begin.

H. Legal and Ethical Principles

State which regulations and ethical codes will govern this research. Provide the appropriate IRB documents or evidence that IRB review is not required. See Section IV below for more details about legal and ethical principles and what documentation is required.

I. Anticipated Benefits of Research The proposal must identify the benefits that the research is expected to provide to the District in terms of the areas of interest listed in Section I, above.

J. Burden on Research Subjects

The following is required of all research proposals that involve human subjects:

• The research proposal will clearly state the number of participants, specifying the role of each group of participants. For example: Twenty math teachers in four schools will be observed, six principals will be interviewed, forty students from five classrooms will be surveyed.
• The research proposal will clearly state the amount of time to be requested from each participant and when the interaction will occur. For example: Math teachers will be observed for four class sessions during the first two weeks in March.
• It is in the District’s interest to minimize the human costs of research. Therefore, the research proposal will provide a clear rationale for the number of participants, the number of contacts, and the total time required by each participant.
• The research proposal will include a statement of how research participants are to be compensated for their involvement, if at all.

If your research project indicates a need to obtain district school-level or student-level data (e.g. student test scores, English learner status, course/teacher information, etc.), please include information about the type of data you will need in this section of your proposal. You should include the variables you are interested in obtaining, the population of students and/or teachers you are interested in, and the years from which you would like the data. This will be evaluated separately from the rest of your proposal for the availability of the data and any costs associated with pulling the data out of our district database. However, we will respond to the data request with your proposal review.

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IV. Legal and Ethical Principles

A. Legal Protections

Although this committee does not function as an institutional review board (IRB), as a school district, we must require that all research within the District adhere to federal regulations regarding family and pupil rights, privacy, and protection. In addition, we must require that all research within the district adhere to federal guidelines regarding the protection of human subjects. Although we rely to an extent on approval from your organization's IRB to ensure you have taken all necessary steps to protect human subjects involved in your research, our own guidelines may go above and beyond those of your IRB. Therefore, each researcher should become familiar with these guidelines before submitting a proposal to our committee.

Federal Policy for the Protection of Human Subjects (34 CFR Part 97) This policy is found in the regulations of various departments, but the Department of Education version differs slightly from the DHHS version often cited by researchers and institutions. It can be found at http://www.ed.gov/policy/fund/reg/humansub/part97.html

One subsection in particular should be noted, Additional ED Protections for Children Involved as Subjects in Research: http://www.ed.gov/print/policy/fund/reg/humansub/part97-3.html

Note that research involving “normal educational practices” is exempt from IRB review under 34 CFR Part 97.101(b)(1). However, 34 CFR Part 97.101(b)(2) makes it clear that survey and interview procedures are not included in the definition of normal educational practices. For such procedures, what is required for exemption from IRB review is that information be recorded in a such a manner that human subjects cannot be identified, and that any disclosure outside of the research cannot reasonably be damaging to the subjects’ financial standing, employability, or reputation.

Because of the special relationship that schools have with students and their families, the Family Educational Rights and Privacy Act (FERPA: 34 CFR Part 99) and the Protection of Pupil Rights Amendment (PPRA: 34 CFR Part 98) impose stricter requirements on the District than those imposed on researchers by IRB review or its exemption. These rules may be found at

PDF:
http://www.ed.gov/policy/gen/guid/fpco/pdf/ferparegs.pdf

HTML:
http://www.access.gpo.gov/nara/cfr/waisidx_04/34cfr98_04.html

Before research may begin in LAUSD, one of the following must be submitted to Committee on External Research Review:

• In the case of research subject to Institutional Review Board (IRB) review, the researcher must submit a copy of the IRB submission along with the LAUSD proposal, and provide the Committee on External Research Review with a copy of the IRB approval letter before beginning research.
• In the case of research exempt from IRB review, the proposal must include documentation from the institution clearly delineating reasons for such an exemption.
• In the case of research not affiliated with any institution subject to IRB requirements, the proposal must include persuasive evidence that the researcher has carefully considered the potential risk to human subjects, especially students and families, and has ensured the appropriate protections in the research design.

In any case, the proposal should identify the protections relevant to working with students and student data. If the research involves contact with students other than normal educational practices, student and parent consent forms must be included. Note that even with parental consent, minors in school settings must be given the opportunity to assent or refuse to participate in research activities other than routine educational practices.

B. Ethical Principles

We expect researchers to abide by the code of ethics for their respective disciplines. As a general guideline, we offer the following principles. These principles have been adapted from the American Psychological Association’s (1992) Ethical Principles of Psychologists and Code of Conduct. The entire code is available at http://www.apa.org/ethics/code.html.

Familiarity with Ethics Code. Researchers have an obligation to be familiar with applicable ethics codes and their application to research. Lack of awareness or misunderstanding of an ethical standard is not itself a defense to a charge of unethical conduct.

Compliance with Law and Standards. Researchers plan and conduct research in a manner consistent with federal and state law and regulations, as well as professional standards governing the conduct of research, and particularly those standards governing research with human participants.

Informed Consent to Research. Researchers use language that is reasonably understandable to research participants in obtaining their appropriate informed consent (except when consent is waivable). Such informed consent is appropriately documented. For persons who are legally incapable of giving informed consent, researchers nevertheless (1) provide an appropriate explanation, (2) obtain the participant's assent, and (3) obtain appropriate permission from a legally authorized person, if such substitute consent is permitted by law.

Minimizing Intrusions on Privacy. In order to minimize intrusions on privacy, researchers include in written and oral reports, consultations, and the like, only information germane to the purpose for which the communication is made. Researchers discuss confidential information obtained in schools, or evaluative data concerning students, teachers, and other research participants, only for appropriate scientific or professional purposes and only with persons who are clearly concerned with such matters and have pledged to uphold confidentiality.

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Frequently Asked Questions

Who needs to submit proposals for review by this committee?

Anyone wishing to conduct research involving LAUSD resources (human, information, or otherwise) for which the purpose is primarily external. This includes but is not limited to students, academicians, research firms, non-profit or government agencies wishing to collect data for a purpose that is not part of regular district business. Those hired by LAUSD to research internal programs or the effectiveness of contractors with LAUSD are considered to be conducting internal research and do not need to seek the approval of this committee. Anyone in doubt about the nature of his specific case should submit an inquiry to the committee chair before submitting a proposal.

For how long is CERR approval valid?

Should your study be approved by our committee, you will be given a formal letter of approval signed by our committee chair. This approval is valid until a year following the date of the approval letter.

What if I am proposing to do a study that takes longer than a year?

You may propose a multi-year study. Independent of how long your study takes to complete, you will be asked to submit an annual update. This update would consist of a summary of findings if the study is at completion or a request for an extension should the study need to continue beyond one year. So long as no substantive changes are made to the original proposal for a multi-year study, approval may be renewed via the annual update without the need for a revised proposal to be submitted each year.

May I send a copy of my dissertation, institutional review board, or other proposal I have already prepared even if it doesn’t quite fit the LAUSD format?

No. Only proposals that include the eleven sections (A-K) and no more than ten pages, as outlined in our guidelines, will be accepted. It is acceptable to cut-and-paste from an existing proposal to save time and effort on your part. Be mindful, however, that our reviewers’ recommendations will be based solely on the content of your ten-page proposal and not necessarily on any supplemental documents you might submit, so it is a good idea to edit your proposal for clarity and completeness.

Do I have to wait until my institutional review board (IRB) has completed its review before submitting to this committee?

No. Although we rely heavily on the opinions of IRBs to ensure that researchers are adhering to human subjects protection guidelines, we are willing to review proposals while they are under review by an IRB in order to save time. However, the IRB review must be completed and a copy of the approval submitted to us before an approved study may move forward with data collection. (NOTE: some IRBs require an approval letter from us before they will grant their own approval. It is perfectly legitimate to submit both at once, submit a copy of your application to us, and if approved, submit a copy of your approval letter from us to the IRB so they can complete their review.)

Is the process any different for me if I happen to be an LAUSD employee?

No. You must go through the proposal process if you wish to conduct research for purposes that fall outside your normal job duties. In fact, because of the potentially conflicting roles played in such a scenario, the researcher should take great care to conduct all business related to the external project as someone external to the district in order to avoid the appearance of a conflict of interest (for example, a principal of a school who is conducting research for an Ed.D. thesis should not solicit participation from teachers or students at that school, using his or her title as principal, as it may compromise the extent to which individuals feel they are volunteering to participate and could even create the image that he or she is using human resources accessible to a principal for personal use). When questions arise as to whether a district employee is potentially crossing ethical lines, it would be a good idea to consult the chair of this committee or the district's Ethics Office.

What if I need to make changes to a proposal that has already been approved? Do I need to go through the whole process again?

The need to submit a revised proposal really depends on whether the changes are substantial. If you make changes to the study that increase the burden to subjects (e.g., increasing sample size, adding data collection method) or modifies the design or analysis plan, you should inform the committee chair and obtain approval. The types of changes that do not require re-submission usually involve switching a school in a sample or rewording a couple of items on an interview protocol. Those that would require a re-submission involve changes such as deciding to add an additional role group to an interview sample (such as deciding to interview local district directors, when the original plan was to interview only principals). In each case. the chair can assist you in determining whether a revised proposal would be necessary.

What do you mean by “benefits to LAUSD”?

In a time of drastic budget cuts and tight resources, LAUSD must prioritize its goals on student learning and achievement. All district business must be aligned with the LAUSD mission and vision. External researchers must demonstrate that their study contributes to achieving the district’s goals and does not only fulfill goals that are external to the district.

What are reasons why a proposal would be rejected?

There are three general reasons why a proposal would be rejected: 1) lack of relevance 2) lack of quality, or 3) intense burden on district resources. A study is deemed to be lacking relevance if the variables are not directly related to the mission of LAUSD. For example, a researcher interested in the political affiliations of public school teachers might find LAUSD to be a convenient laboratory for his work but could probably not argue that the findings would be of use to the district. Thus use of LAUSD teachers as a resource is not justified. A study is deemed to be lacking quality if an adequate level of scientific rigor is not demonstrated. Our office is comprised of professional researchers who observe professional standards for their work. The work of external researchers must be held to the same standards as use for our own work. If some elements are missing or unclear in the proposal, the researcher will normally be invited to resubmit with changes. In some cases, reviewers may deem that a minimum level of technical proficiency was not demonstrated (e.g., basic terms are used incorrectly, or the quality of writing is below professional standards), in which case the proposal would be rejected. Proposals might also be rejected if reviewers determine that the study would place a greater strain on resources than the district would be able to accommodate. This would be particularly relevant during times when the district's resources have been limited by budget cuts or other means.

How many proposals may I submit during an application period?

Each Principal Investigator may submit one proposal per application window. See the above section on application periods for the current year to determine the next time you may submit.

If my proposal is not accepted, will I be told the reasons why?

Yes. Our committee is interested in supporting any high quality research that could potentially benefit LAUSD. When proposals are not accepted, in many cases, we will provide an itemized list of recommended changes and invite the researcher to resubmit the proposal within 20 days. Proposals are only rejected without the invitation to resubmit if the reviewers determine that, even with changes, the work is not likely to yield benefits to the district.

How long does the approval process take?

Although the process generally takes about ten working days, it can vary depending on the volume of proposals we receive during an application period. You will be notified of the committee's decision by the last working day of the month during which you submitted the proposal (for example, if you were to submit on September 5, you should expect to hear from us by about September 19 and would be guaranteed to hear from us by September 30).

Does approval by CERR guarantee I will be able to get the data I need from LAUSD?

No. Approval from this committee merely means that your proposal is methodologically sound and that it is likely to yield benefits to the district that outweigh any cost in resources. It does not require schools or offices to allow you access to their resources, nor does it negate the rights of subjects to decline participation. It might be helpful to think of this approval process as the first phase in a multiphase process.

I am on a tight schedule. To save time may I contact people in the district to solicit their participation in my research while the proposal is undergoing review?

No. External researchers may not contact any district personnel, schools, students, or their families without having a formal letter of approval from this committee.

Okay, but I am still on a tight schedule. Is there any way to expedite the process so I can meet my deadlines?

No. We do our best to complete each review within a ten-day period, which involves two separate reviews by independent members of the committee followed by a third review by the chair. Depending on the volume of proposals we receive, this process may at times take longer than ten days but generally cannot be done any faster without compromising the process.

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Contact for more information: Kathy Hayes.