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Policy 3030 Implementation Procedures - Research in the Howard County Public School System

Policy Document

Implementation Procedures

I. Screening, Review, Timeline, and Reporting of External Research Requests

For external research proposals governed by Policy 3030, the following provisions apply:

  1. For research proposals that meet criteria to be considered for review as described in Policy 3030 Section III.A., external researchers may access the application form on the HCPSS website. Research proposals will be screened and the types of research described in Policy 3030 Section III.B.4. will not be reviewed or approved.

  2. Items deemed out-of-scope under Policy 3030, Section III.G. will not be considered under this process. If the Superintendent/designee receives requests to review these types of items, the Superintendent/designee will forward these items to the appropriate Howard County Public School System (HCPSS) office for consideration.

  3. Research proposals submitted for approval will be sent to the Superintendent/designee in the form of a completed Application to Request Permission to Conduct Research in the HCPSS, which will include the following:

    1. The applicant’s qualifications to conduct high-quality research as outlined in Policy 3030, Section III.A.4. through 7.

    2. A list of all researchers and personnel who are to be involved and their qualifications and roles. Qualifications should include each personnel’s successful completion of learning modules provided by the Superintendent/designee related to protecting human subjects and adhering to data privacy laws and regulations as outlined in Policy 3030 Section III.A.7.

    3. A detailed research proposal that includes a clear research question that refines or tests a hypothesis or assesses a theory, rationale for the study, and detailed justification of how the research findings would support current HCPSS goals, priorities, and initiatives.

    4. A thorough description and justification for the proposed research methodology, including a research design that takes into account the need to eliminate any potential power differential between the researcher and research subjects, or perceived and real authority of the researcher over the research subjects. Proposed methods also delineate the study sample, study design, instrumentation, data collection, and data analysis plan.

    5. A thorough description of the proposed data points that will be requested and/or collected, as well as how the data collected will be safeguarded and maintained, and when and how the data collected will be destroyed.

    6. A thorough description of how findings will be reported to maintain the confidentiality and anonymity of participants and avenues by which study findings are intended to be disseminated.

    7. Copies of all research materials (e.g., questionnaires, interview protocols, surveys, procedures, recruiting materials, and informed consent and assent forms) that will be used.

    8. An estimate of the number of HCPSS schools, teachers, students, and/or other school system employees that are proposed to be involved.

    9. A detailed estimate of the time and burden required of students, teachers, and other school system employees involved, including the time that students will miss classroom instruction in order to participate; along with a justification for how HCPSS will benefit from this study.

    10. A timeline that includes: the timeframes for conducting the research, collecting and analyzing data; the estimated date for submitting the final report, the executive summary, and an interim report if applicable; and any justification for maintaining the data beyond the end of study completion, if applicable.

    11. For proposals involving human subjects: Institutional Review Board (IRB) decision letter. Only those proposals that are reviewed by an IRB and have an IRB letter either approving the research or exempting the research from IRB review will be considered for approval in HCPSS.

    12. Applicant’s and, if appropriate, supervising researcher’s curriculum vitae.

  4. All researchers who will be conducting research at any HCPSS location are required to complete a criminal background investigation and obtain clearance from HCPSS before beginning their research, in accordance with Md. Family Law Code Ann. §5-560. A list of the external researchers and their approved research timeframe will be maintained by the Superintendent/designee and shared with the HCPSS Office of Human Resources.

  5. All proposals to be considered during any given school year will be received at least twelve (12) calendar weeks prior to the desired starting time.

  6. Research proposals that have all completed documentation will be reviewed within one (1) calendar month.

  7. The research proposal will initially be reviewed by the Superintendent/designee. In addition, the appropriate curricular and/or program departments will provide input in order to determine the benefit-burden balance and suitability of the research, adherence to high-quality research standards as noted in Section I.A., and risks to data privacy. If proposals involve specific schools, the supervisor of principals, the principals and appropriate staff of those schools will also provide input.

  8. The Superintendent/designee will contact the principals of the schools and/or leaders of the offices named in the proposed research to obtain their approval as part of the review process. As part of this approval, principals and/or leaders of the offices named in the proposed research agree to assign an employee as the point of contact to monitor that the research is conducted as approved.

  9. The Superintendent/designee may request clarification and additional information from the researcher as part of the application review process.

  10. If educational records are requested as part of the research proposal, the Superintendent/designee will consult with appropriate HCPSS and/or educational data privacy subject matter experts to determine if those data could be shared according to the Family Educational Rights and Privacy Act (FERPA) regulations. Under FERPA, only properly de-identified data and only under certain exceptions may educational records be shared without written parental consent.

  11. Using the input and recommendations from the reviewers, the Superintendent/designee will approve or reject the research proposal based on the standards and procedures outlined in this policy. A letter will be sent to the researcher to notify them of the decision.

  12. If approved, the research approval letter will contain conditions under which the research is approved. The researcher must comply via written agreement with all conditions to conduct research in HCPSS. These conditions may include the following:

    1. Data maintenance requirements (e.g., safeguarding, destruction schedule).

    2. HCPSS Student Data Sharing Agreement completion requirement.

    3. Data privacy and protection requirements, including proper de-identification of any employee and student data, as well as de-identification of any school and the school system, in reporting findings.

    4. Confidentiality considerations and requirements.

    5. Considerations and parameters for use of HCPSS resources (for HCPSS employees only).

    6. Requirements for mitigation of dual role (for HCPSS employees only).

    7. Necessary changes in order for the research to be approved.

    8. Logistical considerations, including assigning a point of contact (if necessary) and communication/correspondence expectations.

    9. Timeframe to conduct approved research activities.

    10. Expectations for sharing of results with HCPSS.

    11. Requirement that if the researcher would like to make changes to the study design after this approval, the researcher must submit a new application to request permission to conduct research in HCPSS.

    12. Requirement for the inclusion of this approval letter specifying the conditions under which the study is approved in initial communications with HCPSS employees, students, and families.

    13. Signature of primary investigator and the applicant, indicating their understanding of and commitment to adhere to the conditions stated in the letter and all HCPSS policies and procedures.

  13. All approved research will be completed within the approved timeline. If research is not completed within the allotted time period, the researcher will apply for an extension and obtain approval from the Superintendent/designee in order to extend the research timeline. If the research involves specific schools and offices, the principals and appropriate HCPSS employees of those schools and offices will be asked for input regarding the researcher’s request for an extension.

  14. All approved research will be conducted as approved in the proposal. If modifications to the approved research proposal are needed, researchers will apply for a modification and obtain approval from the Superintendent/designee. If the research involves specific schools and offices, the principals and appropriate HCPSS employees of those schools and offices will be asked for input regarding the researcher’s request for modification.

  15. Within the timeframe specified in the approved research proposal, the researcher will submit an interim report if applicable, a final report, an executive summary, and a verification of proper data disposal to the Superintendent/designee and any offices specified in the approval letter.

  16. Within thirty (30) calendar days from the end of the approved research activities timeframe, the Superintendent/designee will send a letter to the researcher indicating that the approved study period is over and all research activities must cease.

  17. At the end of each school year, researchers who have not submitted documentation as specified in Section I.O. in the required timeframe will be contacted and made aware that their permission to conduct research in HCPSS is on hold and any future research requests will not be reviewed until reporting requirements have been met.

II. Approval Process, Timeline, and Reporting of Requests to Disseminate Information Obtained from Action Research

For requests to disseminate information obtained from action research as governed by Policy 3030, the following provisions apply:

  1. The HCPSS employee’s immediate HCPSS supervisor will act as the Superintendent’s designee. For HCPSS pre-service candidates/interns, their HCPSS site supervisor’s immediate supervisor will act as the Superintendent’s designee.

  2. Requests to disseminate information obtained from action research submitted for approval under this provision will be sent to the appropriate immediate HCPSS supervisor, and will include the following:

    1. A statement that the HCPSS employee or pre-service candidate/intern was the one who conducted the research activities as part of a systematic reflection on their own professional practices, and that the HCPSS supervisor was aware of this action research.

    2. A high-quality research description that includes a clear research question, rationale, and justification of how this research is grounded in the HCPSS employee’s or pre-service candidate/intern’s job-embedded professional learning and involves normal educational practices that are not likely to adversely impact students' opportunity to learn required educational content, nor are these activities likely to adversely impact the evaluation of the employees who provide or support instruction.

    3. A thorough description and justification for the research methodology, including a research design that takes into account the need to eliminate any potential power differential between the researcher and the research subjects, or perceived and real authority of the researcher over the research subjects. The research methodology description also includes measures used and the data analysis steps.

    4. A thorough description to demonstrate that the data collected were job-embedded data that did not interrupt typical teaching and learning or operational processes. If educational records are requested as part of the research proposal, the Superintendent/designee will consult with appropriate HCPSS and/or educational data privacy subject matter experts to determine if those data could be shared according to FERPA regulations. Under FERPA, only properly de-identified data and only under certain exceptions may educational records be shared without written parental consent.

    5. A thorough description of how the findings will be properly de-identified and reported to maintain the confidentiality and/or anonymity of participants, how data collected will be safeguarded, and avenues by which study findings are intended to be disseminated (e.g., professional conference, journal article).

    6. Copies of all action research materials used (e.g., questionnaires, interviews protocols, surveys, procedures, recruiting materials, and informed consent and assent forms, as appropriate).

    7. At the end of each semester, HCPSS supervisors will submit to the Superintendent/designee all approved or denied requests to disseminate information obtained from action research during that period. Summer requests may be submitted following the subsequent semester.

  3. Using the application materials submitted, the HCPSS supervisor will approve or deny the request based on the standards and procedures outlined in Policy 3030 and these Implementation Procedures, and send a letter to the researcher to notify them of the decision. The HCPSS supervisor will copy the Superintendent/designee on these letters.

  4. If approved, the action research findings dissemination approval letter will contain conditions under which the request is approved. The researcher must comply via written agreement with all conditions to disseminate action research findings. These conditions include the following:

    1. Data privacy and protection requirements in reporting findings, including proper de-identification of any employee and student data, as well as de-identification of schools and the school system.

    2. Considerations and parameters for use of HCPSS resources.

    3. Expectations to get HCPSS supervisor sign-off on final draft prior to dissemination of action research findings.

    4. Signature of the HCPSS employee or pre-service candidate/intern requesting permission to disseminate information obtained from their action research, indicating their understanding of and commitment to adhere to the conditions stated in the letter.

III. Data Governance Before, During, and After Completion of Approved Requests

  1. Per FERPA, properly de-identified data may be shared without written parental consent. Otherwise, any disclosure of educational records from HCPSS to researchers requires prior written parental consent.

  2. While conducting approved research activities, all research personnel must safeguard any data obtained or collected. Data safeguarding strategies include data file encryption and proper de-identification of subjects in the data files.

  3. At the conclusion of the research study or at the time agreed upon, the researcher will submit to the Superintendent/designee a signed form certifying that data obtained or collected as part of the approved research have been cleared, purged, or destroyed.

  4. External researchers must complete the HCPSS Student Data Sharing Agreement prior to (a) gaining access to or (b) collecting student data.

IV. Violation of Policy

If a research incident arises, the Superintendent/designee will call together a response team to:

  1. Assess the potential incident;

  2. Take coordinated action, which may include automatic rejection of the research application or immediate termination of the research;

  3. Notify the researcher-in-question and appropriate supervisory personnel (e.g., IRB, principal investigator, university advisor, direct supervisor) and determine corrective actions (e.g., destroy data collected), if any; and

  4. Use the lessons learned from the incident response to improve the processes of identifying, defending, detecting, responding to, and recovering from future potential incidents.

V. Training HCPSS Employees

The Superintendent/designee will appoint HCPSS subject matter experts to provide training to HCPSS employees on the following topics. Training is required only for supervisors who need to review action research dissemination requests, as noted in Section III.B.3. of Policy 3030. Training includes but is not limited to:

  1. Awareness of Policy 3030 and HCPSS employees’ roles in the implementation procedures. For example, the Superintendent/designee may send an email annually to all employees to highlight Policy 3030 and the conditions under which external researchers may contact HCPSS employees to recruit them for research.

  2. How to properly de-identify data, as well as a basic understanding of FERPA and PPRA regulations related to student data collection and sharing practices.

  3. Guidelines for supervisors when reviewing action research dissemination requests to determine approval or denial in accordance with Policy 3030, as well as expectations to communicate with the Superintendent/designee as outlined in the implementation procedures.

  4. Guidelines regarding appropriate use of system resources and role boundaries in the context of research as defined within the scope of this policy.

  5. Awareness of HCPSS offices to contact when Superintendent/designees have questions regarding implementation of this policy.

VI. Monitoring

Policy 3030 implementation procedures will be overseen by the Office of the Deputy Superintendent.

VII. History

ADOPTED: October 25, 1990

REVIEWED: December 19, 2019

MODIFIED: October 10, 2013

REVISED:

  • September 7, 2006

  • June 14, 2007

  • June 11, 2009

  • February 12, 2015

  • December 7, 2021

EFFECTIVE: July 1, 2022

Policy History Key

  • Adopted-Original date the Board took action to approve a policy
  • Reviewed-The date the status of a policy was assessed by the Superintendent’s Standing Policy Group
  • Modified-The date the Board took action to alter a policy that based on the recommendation of the Superintendent/designee did not require a comprehensive examination
  • Revised-The date the Board took action on a that policy based on the recommendation of the Superintendent/designee needed a comprehensive examination
  • Effective-The date a policy is implemented throughout the HCPSS, typically July 1 following Board action.