Student Research FAQs

1. If I am a student that wants to target DoD-affiliated personnel as research subjects, are there specific requirements that I must follow? 

Yes. Most student research is subject to an assistance review, with a few exceptions.
 
The assistance review is applicable for student research projects where the student researcher/investigator is conducting research as part of their role as a student at an academic degree program and that research will be receiving non-financial support, or assistance, from the Department of the Army (DA) to conduct the research project (e.g., recruiting DoD-affiliated personnel as subjects).

The primary function of the assistance review is to ensure that the study has been reviewed by a non-DoD IRB/HRPP and that special protections are in place for DoD-affiliated personnel as subjects.
 
2. If my student research project is funded by the Army, do I still need a review by AHRPO? 

Yes. If your project is funded by the Army, a Human Research Protection Official (HRPO) review is required which may be performed by AHRPO or the funding agency if that funding agency has been delegated HRPO authority.
 
3. How does an assistance review differ from a HRPO review? How are they the same? 

An assistance review is akin to an abbreviated HRPO review.

Assistance reviews and HRPO reviews are both secondary administrative reviews that are required when the DoD provides support to a non-DoD institution for the conduct of HSR. Both reviews are performed after the non-DoD institution’s Institutional Review Board (IRB) and/or Human Research Protection Program (HRPP) has reviewed and approved the HSR activity.
 
The key difference is that a HRPO review is required when the non-DoD institution receives funding from the DoD for HSR in the form of contracts, grants, or other agreements.
 
If the DoD provides non-financial resources to a non-DoD institution for the conduct of HSR, then there are fewer review requirements. HSR activities that are eligible for an assistance review are less risk to the DoD, therefore are appropriate to have an abbreviated review as allowable IAW DoDI 3216.02, § 3.7.

4. If a student researcher is also a DA civilian* who will be conducting the HSR activities while on duty and using resources that are only available due to their status as a DA civilian, how does this impact the assistance review? 

If someone has dual roles such as a DA civilian and a student researcher, they must seek advice on how to “pick their hat” or designate the role they will be functioning in for the HSR activity.
 
If DoD-affiliated personnel are conducting the HSR activities on behalf of a non-DoD institution (e.g., non-DoD academic institution) that are outside their official duties (i.e., when off-duty, when the personnel are acting as private citizens) then the assistance review may proceed.
 
If there is a case where both hats apply because an investigator is acting in official capacities for both the DoD and non-DoD institutions in the conduct of HSR, then requirements for the DoD-conducted and DoD-supported (assisted) research applies. Therefore, the HSR activity is not eligible for the assistance review.
 
*This response is applicable for DA civilians and any other DoD-affiliated personnel defined as Service members, Reserve Service members, National Guard members, DoD civilians, and DoD contractors.