Public Service Quality Improvements: A Case for Exemption from IRB Review of Public Administration Research

Abstract

Should the exemption from Institutional Review Board (IRB) evaluations currently in place for quality improvements research be extended to public administration research that addresses questions of improving the quality of public service delivery? As a means to both reduce the level of disdain held by a group of social science researchers for IRBs and to reduce the cost of review for minimal risk studies, I argue here that much of the current public administration research should also be exempted from normal processes of review by IRBs on the basis of their similarity to Quality Improvements (QI) research, a category of studies already granted exemption. This argument dovetails provisions currently in place for studies of public service and public benefit, but reframes these exemptions in the language of “quality improvements,” which may be a more comfortable language for IRBs concerned to demonstrate compliance for review of all fields. To expedite this argument into the practices of IRBs, I included a checklist that researchers could use to self-identify their studies as QI, not research as such.

Keywords:

• Applied Public Administration
• Institutional Review Boards
• quality improvement

Notes

1. Public administration researchers are only a small subset of social sciences researchers concerned with the scope of IRB oversight. Applied public administration research includes studies falling under the general headings “public management,” “public productivity evaluation,” or “program utilization evaluation.”

2. Readers familiar with the Federal Acquisitions Regulation System will recall that Title 48, subpart 370.3 stipulates that, “t is HHS policy that the Contracting Officer shall not award a contract involving human subjects until a prospective contractor has provided acceptable assurance that the activity will be subject to initial and continuing review by an appropriate Institutional Review Board (IRB) as described in HHS regulations at 45 CFR 46.103. The Contracting Officer shall require an applicable federal-wide assurance (FWA), approved by the HHS Office for Human Research Protections (OHRP), of each contractor, subcontractor, or cooperating institution having responsibility for human subjects involved in performance of a contract” (370.301).

3. These data and tables are reproduced from Jordan and Gray (2013).

4. New public management is a paradigm in public administration, both in theory and application, that build on successive efforts to “build a government that works better and costs less” beginning as early as the Brownlow Report and extending to the “reinventing government” movement of the 1990s (Obsourne and Gaebler, 1993). The reinventing movement has embraced a number of quality improvement principles, such as total quality management.