Research Continuity during the COVID-19 Pandemic

To the extent possible, Principal Investigators (PIs) should continue their research, particularly aspects of research that can be conducted without visiting a campus or site, such as manuscript writing, data analysis, report writing, administrative tasks. PIs should consider suspending projects or not starting new projects, but if study activities can be conducted remotely, research should proceed in this way (see below). The research enterprise must continue to follow regulatory guidance. Federal sponsors are allowing for maximal flexibility with regard to administrative, cost, and reporting requirements (see NIH, NSF). If a study needs to be paused, use the standard process to notify the sponsor in accordance with sponsor issued timelines. Unless otherwise notified by the sponsor, all reports due to sponsors must continue to be submitted.

All research engagement, whether by faculty or student, whether funded or not, requires compliance with federal research guidelines.

Human Subjects Research

For research involving interactions with people, interactions should be limited to minimize risk of contracting or spreading COVID-19, in accordance with CUNY Coronavirus Guidance, CDC Guidance, and school guidance. Follow your campus HRPP guidelines, but in general human subject research involving direct interaction with study participants should be paused and no study participants should travel to campus. The exception would be studies with therapeutic benefit. To the best of my knowledge, no one at SPH is conducting such research. Ethical principles of research and federal regulations for the protection of human research participants require an acceptable risk/benefit ratio for in-person contact associated with research. This guidance is being provided in order to promote public health. When PIs do not follow guidance that is in the interest of public health, they are not engaging in responsible conduct of research. Unethical or irresponsible conduct may result in disciplinary action taken by campus administration.

Studies which do not offer direct therapeutic benefit to participants or where stopping procedures will NOT cause harm to participants and PIs would like to continue the study, PIs must submit a modification to change study procedures requiring NO face-to-face interactions. Studies which do not involve face-to-face interactions (i.e., conducted electronically or via telephone) may continue.

PIs should notify Kristen Cribbs (kristen.cribbs@sph.cuny.edu), our HRPP coordinator, and sponsor of any changes in research procedures and submit all HRPP/IRB modifications via Ideate. For PIs submitting new protocols, data collection protocols should be for remote data collection, depending upon therapeutic benefit on a case-by-case basis. Protocols may also include in-person data collection for some future time, when guidance for remote collection is removed CUNY-wide.

Data Use Agreements

For studies of data access and analysis covered by data use agreements (DUA), PIs may need to request modification if you require a different platform than is covered by the DUA. Please contact Michele Kiely (michele.kiely@sph.cuny.edu). If the DUA involves human subjects and the protocol requires modifications, an IRB modification should be submitted via Ideate.

Researcher Travel

For researcher travel, including conferences and field research, researchers should follow CUNY travel guidance on the CUNY Coronavirus page. For guidance about NSF or NIH reimbursement, see the CUNY Research links.

Additional guidelines for PIs from federal funders can be found on the CUNY Office of Research Home Page, which also links to the CUNY Research Foundation.

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