Updated: March 31, 2020 9:30 a.m.
March 31st Communication
Dear Villanova Researchers,
As you may have already heard from the Associate Vice Provost for Research, Amanda Grannas, non-critical on-campus research activities must be suspended in order to protect the health and safety of the Villanova community. As indicated in the same briefing, the Institutional Review Board (IRB) has issued a corresponding directive requiring all human subjects research activities be conducted remotely effective immediately. The full announcement can be viewed by visiting the IRB’s COVID-19 Directives webpage.
We want to be sure all personnel involved in research understand their responsibilities as we transition. If you are the Principle Investigator on a project, you must ensure that your students and other study staff understand that they are not permitted to interact directly with human subjects until further notice. This includes projects that are being conducted by students in pursuit of a degree or honor’s designation. If data collection (for a student project or otherwise) can continue remotely (telephone, web conference, online survey platform) you may adapt your study to be carried out without direct person-to-person contact.
The IRB and ORP have adopted the following changes to facilitate adaptation:
- Under ordinary circumstances, procedural changes to IRB protocols may not be made without obtaining IRB approval in advance. An exception may be available when the IRB or PI determines that changes are necessary to eliminate apparent immediate hazards to participants. Therefore, while under these extraordinary circumstances, substitution of telephone, web conferencing and secure electronic communication (Zoom, Qualtrics) for data collection procedures normally completed in-person are allowable without first notifying the IRB.
- If your active research protocol is affected by the VU IRB COVID-19 Directives, you must notify the IRB within 10 business days of implementing a change to your protocol. Such notification should take place by completing a modification application for your protocol via Cayuse IRB so that there is a record of implementation of these procedures. (If you are not in active data collection, already have remote data collection procedures in place, or will simply pause your research until this restriction is lifted, you do not need to be in contact with the IRB.)
- If the participants’ research experience will be different due to the remote operation directive than it otherwise would have been, you will need to be sure to accurately convey the new experience in your Informed Consent Document/Process. In order to reduce burden on researchers, reviewers, and administrative staff, the IRB has allowed a temporary addendum cover sheet to be added to already-approved consent forms explaining those changes. This cover sheet should clearly explain to participants how their experience will differ from the text of the original document. We have developed a template to assist in the creation of such a cover sheet, which is available on the IRB COVID-19 Directives website. Your cover sheet should be attached to the modification application you submit to the IRB.
- If your study was not already approved with a waiver of documentation of consent (meaning that the IRB determined it is appropriate for you to not collect a signed consent document), you must continue to collect signatures electronically (e.g. a scanned signed document or a typed “signature”) . If you believe collecting electronic signatures presents an additional risk to your participants, please contact IRB@villanova.edu to discuss other options.
IRB staff remain available and willing to assist with the transition to remote data collection. Please reach out to IRB@villanova.edu with any questions. Stay safe and healthy!
March 23rd Directive:
Villanova University is currently experiencing an unprecedented series of events in response to the national outbreak of COVID-19. The University and the Institutional Review Board (IRB) are heeding the guidance of local, state and national leadership to reduce the spread of the virus.
This document is to provide the University’s research community with information regarding the review and conduct of human subject research in this time of social distancing. As was communicated in the March 13 briefing from the Office of the President, Villanova’s campus is closed to the public. This will no doubt have an impact on human subject research. However, the IRB will remain operational during this time of social distancing.
- IRB staff will be working remotely and will still respond to e-mails and voicemails.
- Though it will not be possible for IRB staff to meet with study teams in person, phone and web conferences remain an available option for consultation.
- The review process will continue as normal (weekly review batches will be distributed to reviewers each Friday including all complete submissions received by Thursday at noon)
- Reviewers are still expected to return their initial decision within two weeks of each Friday’s assignment. However, we ask for understanding from researchers if there are longer than usual wait times for initial decisions. Most reviewers are faculty who are quickly adjusting to new demands on their time like lack of childcare and un-planned remote teaching.
To protect the welfare of both our investigators and research participants, the IRB mandates that all human subject research activities must be conducted remotely effective immediately. In particular, research participants are no longer permitted to travel to campus, and Villanova personnel must not travel to participants' homes.
These changes will be in place until further notice. As necessary, the IRB will adjust this directive and post changes to this page. For up-to-date University information, please see Villanova’s COVID-19 website. For guidance on best health safety practices, consult the resources available at the federal, state and local levels such as the CDC or the Pennsylvania Department of Health.
In this time of public health concern, the following change to IRB process will occur:
Under ordinary circumstances, procedural changes to IRB protocols may not be made without obtaining IRB approval in advance. An exception is available when changes are necessary to eliminate apparent immediate hazards to participants. Therefore, while under these extraordinary circumstances, substitution of telephone, web conferencing and secure electronic communication (Zoom, Qualtrics) for data collection procedures normally completed in-person are allowable without first notifying the IRB. If you did not already have plans for a remote informed consent process, please reach out to the IRB staff to discuss options for consenting your participants from a distance. These methods may be added when possible and practical for mitigating research risks to subjects or others related to COVID-19.
If your active research protocol is affected by the VU IRB COVID-19 Directives, you must notify the IRB within 10 business days of implementing the change. (If you are not in active data collection, you do not need to be in contact with the IRB.) Such notification should take place by completing a modification application for your protocol via Cayuse IRB so that the IRB has a record of implementation of these procedures.
**IMPORTANT** Please do not include other changes to your study in these special modification submissions beyond those required to conduct study procedures remotely.