Concern over the impact federal regulations have on the internal affairs of higher education institutions remains a critical issue in higher education (Dash, 2007; Feeley, 2007; Hemmings, 2006; Jaschik, 2008; Stark, 2012; White, 2007). Protection of human subjects is one area that the Federal government has promulgated policy through its agencies to influence higher education policy and action at the institutional level. Federal public policy for research involving human subjects, better known as the Common Rule, impacts higher education institutions by requiring all federally funded research to be passed by an institutional review board. The influences of this federal policy determine institutional and faculty ability to gain access to federal research funds (U.S. Department of Health and Human Services, 1999). In light of the value of undergraduate research to colleges and universities, one would have expected to find studies that examined the relationship between the institutional review board and undergraduate research. Unfortunately, these types of studies do not exist.
Undergraduate research benefits students, faculty, and institutions. Student benefits include: increases in retention, intellectual gains, skill attainment, graduate school placement and career preparation (Crowe & Brakke, 2008; Hathaway, Nagda, & Gregerman, 2002; Ishiyama, 2002). Faculty benefits include: increased lab assistance, ongoing research opportunities, and assistance with tenure and promotion (Corley, 2013; Nagda, Gregerman, Jonides, von Hippel, & Lerner, 1998). Institutional benefits include: increased admissions selectivity, increased institutional funding, and lower attrition rates (Kierniesky, 2005; Nagda, et al., 1998). In 1998, Reinventing Undergraduate Education: A Blueprint for America's Research Universities was published by the Boyer Commission on Educating Undergraduates in the Research University. The report called for increased involvement of undergraduates in faculty-mentored research experiences. This led to increased funding through the National Science Foundation, the National Institutes of Health, and the Howard Hughes Medical Institute to support American colleges and universities in creating opportunities for authentic research experiences for undergraduate students across multiple disciplines (Adedokun, Carleton Parker, Bessenbacher, Childress, & Daniels Burgess, 2012; Hunter, Laursen, & Seymour, 2006).
In 2002, The Association of American Colleges and Universities advocated for additional attention on undergraduate research calling it a key means to engage students, and in its 2007 College Learning for the New Global Century report, it recommended undergraduate research as a key focus area. In 2005, National Survey of Student Engagement included undergraduate research as an indicator for effective teaching (Corley, 2013). Kuh (2008) listed undergraduate research as one of ten high-impact educational practices beneficial to students and Lopatto (2006) discussed how undergraduate research engages students in active learning, provides academic challenge, and creates student-faculty interaction in ways that meet student engagement benchmarks reflected in the National Survey on Student Engagement (NSSE). The literature reflects a multitude of well-researched benefits of undergraduate research as well as a call for institutions to increased involvement in undergraduate research. Given this, it is important to understand the policies that regulate undergraduate research. Most notably, undergraduate research, as with all human subjects research conducted on the campuses of American colleges and universities, requires institutional review board approval and monitoring.
Institutional Review Boards
In 2008, there were more than 5,500 IRBs nationwide providing oversight to any federally funded project, and a large amount of unfunded research (Sanders & Ballengee-Morris, 2008). In a published report titled Research on Human Subjects: Academic Freedom and the Institutional Review Board, the American Association of University Professors (2006) spoke out strongly against IRB policies and practices stating, "there could hardly be a more obvious potential threat to academic freedom" (p. 1). Stark (2007) argued that the regulations aimed to protect the rights of human subjects actually violated the rights of researchers. Furthermore, some research indicated a handful of isolated, unethical practices may have created a spiral of knee-jerk reactions resulting in a loss of academic freedom, and a laundry list of other problems for researchers (White, 2007). The Office of Human Research Protection database now contains over 10,500 records of registered IRBs (U.S. Department of Health and Human Services, 2016).
The basic provisions of the FCR Title 45 Part 46, better known as the Common Rule, were written in such a way that allowed for institutional interpretation and discretion. Institutional discretion impacts how the regulations are actually implemented at the institution. The literature reviewed reflected a variety of different...