Proposal to Change the Definition of the Research & Scholarship Category

Governance

On May 30, 2013, the following pair of related changes to the Research & Scholarship Category definition was proposed to the InCommon Technical Advisory Committee (TAC):

1. Remove the following language from the definition of the Research and Scholarship Category:

   However, because of the risk involved, a Service Provider that engages subjects in experiments that require specific oversight is not eligible for the R&S Category.

2. Remove the following self-attestation from the Research and Scholarship Application Form:

   My service does not engage subjects in experiments that require specific oversight.

The original purpose of this requirement was to encourage support for the Research & Scholarship Category by risk-averse IdP operators. However, the requirement had the unintended consequence of slowing adoption by SP owners.

The TAC discussed the proposed change on four (4) separate occasions, at meetings held on 2013-05-30, 2013-06-13, 2013-08-08, and 2013-09-05. The consensus of the TAC was that the requirement should be dropped. The TAC noted that the requirement is problematic for at least the following reasons:

• The requirement is very general, resulting in confusion and delay on the part of SP owners who wish to comply.
• The Federal Policy for the Protection of Human Subjects, the so-called "Common Rule", defines common oversight provisions for human subjects research at all US research institutions, even when not all subjects are affiliated with the institution. There is little reason for InCommon to reaffirm the Federal requirement.
• Compliance with the Common Rule is not readily verifiable by InCommon.

On September 9, 2013, the InCommon Steering Committee reviewed and confirmed the TAC recommendation pending feedback from the InCommon community. On November 5, 2014, a two-week public review period was announced. The public review ended on November 21, 2014. Finally, on December 1, 2014, the InCommon Steering Committee formally approved TAC's recommendation to remove the human subjects requirement.

Actions

1. The language regarding human subjects was removed from (Version 104 of) the definition of the Research and Scholarship Category on October 31, 2014.
2. The self-attestation regarding human subjects was changed to a yes-no-maybe question on (Version 38 of) the Research and Scholarship Application Form on November 8, 2014.
3. The self-attestation regarding human subjects was completely removed from (Version 39 of) the Research and Scholarship Application Form on December 1, 2014.