Frequently Asked Questions

About CYFAR Common Measures and Human Subjects Protection

When completing my CYFAR grant application, if I have questions regarding sections that address whether my research is considered research on human subjects, where can I get more information?

Please refer to the NIFA Federal Assistance Policy Guide for further information about how to document whether your program includes research on human subjects.

Will the University of Minnesota’s Institutional Review Board (IRB) provide overall Human Subjects approval for all participating CYFAR SCP grantees to collect Common Measures data?

No, the University of Minnesota’s IRB will not provide overall Human Subjects approval for the Common Measures data collection process.

According to the University of Minnesota’s IRB, and in compliance with the United States Department of Health and Human Services, Office for Human Research Protections (OHRP), the CYFAR Common Measures data collection process does not constitute human subjects research because:

  • CYFAR Common Measures data will be collected as part of routine program evaluation and is not part of a specific intervention (program or activity) proposed by the University of Minnesota;
  • CYFAR Common Measures data will be de-indentified (stripped of personal information and coded with a unique identifier provided by the site) when it is submitted by CYFAR SCP grantees to the University of Minnesota; therefore, the University of Minnesota will not be able to trace data back to specific individuals and will not be able to identify individual persons based on their data

Why doesn’t the CYFAR Common Measures data collection process qualify as research involving Human Subjects?

According to the United States Department of Health and Human Services, Office for Human Research Protections (OHRP) 45 CFR 46.102(f), if the following conditions are both met then the activities do not qualify as research involving Human Subjects:

  1. The private information or specimens collected from individuals were not collected specifically for the currently proposed research project through an interaction or intervention with living individuals; and
  2. The investigator(s) cannot readily ascertain the identity of the individual(s) to whom the coded private information or specimens pertain.

Does my CYFAR program need to obtain Human Subjects approval from my own university’s Institutional Review Board in order to collect CYFAR Common Measures data?

Each university’s Institutional Review Board mandates different requirements and may have varying interpretations of the federal guidance related to Human Subjects protection requirements. It is always advisable to consult your university’s Human Subjects Protection Program for university-specific requirements.

If the Human Subjects Protection Program at specific universities define the CYFAR Common Measures data collection process as research involving human subjects, then it will be necessary to complete and submit all of the institution’s Human Subjects submission procedures. Additionally, if a CYFAR SCP grantee would like to collect data above and beyond the designated CYFAR Common Measures data, they will need to consult with their institution’s Human Subjects Protection Program for requirements.

Do all CYFAR SCP grantees need to collect CYFAR Common Measures data?

All CYFAR SCP grantees funded beginning in 2011 are required to collect CYFAR Common Measure data. The CYFAR Common Measure(s) used by each program will depend on the program’s short-term outcomes, as determined through development of the program’s Logic Model.

Where will my CYFAR program send the CYFAR Common Measures data?

Once grantees collect their CYFAR Common Measures data, the data should be uploaded/submitted using the CYFERnet SEARCH website that is currently housed at the University of Minnesota. The University of Minnesota will store the data in a private database housed on a secure server. Aggregate-level analysis of data across all CYFAR programs nationally will be performed by the University of Minnesota. However, each CYFAR program will still be required to run their own site-level data analysis (in conjunction with their program evaluator) and submit their data findings using the approved CYFAR reporting system (e.g., REEport).

Does my CYFAR program still need to complete site-level data analysis or will all of the data be analyzed by the University of Minnesota?

Each CYFAR program will still be required to run their own site-level data analysis (in conjunction with their program evaluator) and submit their data findings using the approved CYFAR reporting system (e.g., REEport).