I was asked about the need for an evaluation plan to be reviewed by the institutional review board (IRB) office. In pausing to answer, the atrocities that have occurred and are occurring throughout the world
registered once again with me…the Inquisition, the Crusades, Cortes, Auschwitz, Nuremberg trials, Sudan, to name only a few. Now, although I know there is little or no evaluation in most of these situations, humans were abused in the guise of finding the truth. (I won’t capitalize truth, although some would argue that Truth was the impetus for these acts.)
So what responsibility DO evaluators have for protecting individuals who participate in the inquiry we call evaluation? The American Evaluation Association has developed and endorsed for all evaluators a set of Guiding Principals. There are five principals–Systematic Inquiry, Competence, Integrity/Honesty, Respect for People, and Responsibilities for the General and Public Welfare. An evaluator must perform the systematic inquiry competently with integrity, respecting the individuals participating and recognizing diversity of 
public interests and values. This isn’t a mandated code; there are no evaluation police; an evaluator will not be sanctioned if these principals are not followed (the evaluator may not get repeat work, though). These guiding principals were established to “guide” the evaluator to do the best work possible within the limitations of the job.
The IRB is there to protect the participant first and foremost; then the investigator and the institution. So although there is not a direct congruence with the IRB principals of voluntary participation, confidentiality, and minimal risk, to me, evaluators following the guiding principals will be able to assure participants that they will be respected and that the inquiry will be conducted with integrity. No easy task…and a lot of work.
I think evaluators have a responsibility embedded in the guiding principals to assure individuals participating in evaluations that participants engage voluntarily, that they provide information that will remain confidential, and that what is expected of them involves minimal risk. Securing IRB approval will assure participants that this is so.
Although two different monitoring systems (one federal; one professional), I think it is important meet both sets of expectations.
With 30 years of experience, I have struggled with “to IRB or not to IRB” many times. I am in full agreement with you regarding the guidance of the AEA Guiding Principles, and perhaps even the consideration and use of the Joint Committee’s Program Evaluation Standards as ways of regulating our behavior and assuring folks that we mean no harm, and hopefully, do no harm. That’s all well and good. So too, I agree that IRB review potentially provides a great opportunity for external validation of those claims and offers folks even more assurance that they can participate “safely.” I wish my comments could end with a simple and hearty “me too!” Not so. As an academically-housed evaluator, I am bound by a research university IRB model that relies heavily on a medical research model and a turnaround for review that adds up to months on average. The medical model essentially turns the process into a remote, disconnected exercise in compliance that yields frustration on bad days and humor on good days (it is extremely unlikely that my evaluation work will use radioactive carcinogens — ever). Perhaps more importantly, by the time I will get IRB approval, my potentual client may be beyond the question they were asking that even brought them to my door. Add to the mess that IRB staff are often folks who have limited research experience, and zero evaluation experience — with no understanding of the cultural and practical differences.
So, from a practical perspective, I avoid IRB involvement, not because I want avoid good ethical practice (and even strongly value external review and evaluation!), but rather because often the review is irrelevant and not responsive to the realities of evaluation. I wonder how colleagues struggle with these issues, as well.
Hi Cindy, Thank you so much for your thoughtful comment. I have experienced more often than I would like to admit the situation you mention above. I also realize that there is no easy answer here. So I ask you–What advice would you give faculty who need to publish their evaluation results/findings and need IRB approval in order to do so? What advice would you give to faculty who avoided IRB involvement only to discover that their important finding can only sit in the drawer. I’m not asking these questions to be “flip”. These are questions I struggle with. if not daily, at least regularly. Most social science journals (at least the evaluation ones) require an assurance of protection of human subjects and the easiest way to get that is through IRB even if it adds a month or more to the time line. Thanks, again for your thoughtful reply.
So back to the basic question. Are youth serving programs required to have an IRB for applications, beginning and end-of-year surveys, and program evaluations? At what point is there a bright clear line? What is optional? And what constitutes publication?