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  • Open Comment Period: March 23 - April 21, 2017

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Comments Apr 21, 2017 4:31 pm

I strongly oppose the adoption of these policies. The safety and privacy of research participants should be the priority of UIC, and these requirements will inhibit the trust and respect necessary to work with and for local communities. Apr 21, 2017 12:31 pm

As someone, who conducts most of his research online, targeting globally distributed populations, these requirements will make it practically impossible for me to collect data. In many developing countries, for example, it may be impractical for them to receive a check from the US. Also, as someone surveying people living under opressive regimes about their political views, I may put them in danger by requiring them to identify.

On a different note, prohibiting the use of personal funds for research may significantly hinder the work of graduate students, many of whom are actually willing to spend their personal, hard-earned, funds to compensate their participants. Unless the university provides adequate funding to support gradaute student research, implementing such ban will hurt our marticulation rates and, in some cases, literally kill gradaute students' research. Apr 18, 2017 5:05 pm

I strongly urge that these guidelines not be adopted, particularly related to tax identification numbers for nonresident aliens and no personal payments of participants. As many others have noted, the policy for nonresident aliens creates a barrier to research with vulnerable populations, which has negative implications for the University mission to reach underserved populations, the ethical responsibility to protect vulnerable populations, and the need to reach scientifically valid conclusions through representative sampling. Researchers (such as myself) who predominantly study these populations will also have a difficult time continuing their research agenda. Additionally, not allowing personal payment of participants will decrease graduate student ability to conduct research and complete their Ph.D., as graduate students often do not have funding and pay for their dissertation out of pocket. Apr 16, 2017 12:12 pm

I strongly oppose this rule change. It is unethical and would contradict the university's mission and values of serving communities and people of color. It would ruin community relationships with the university, and discourage individuals from participating in research. Apr 14, 2017 12:31 pm

I strongly urge that these guidelines not be adopted. The goal of our work is to partner with communities and work to remove injustices and structures that inhibit health and well-being and this policy directly thwart that mission. It will create a barrier to research and evaluation participation that will ultimately harm research endeavors, the University's relationship with these communities, and will inhibit the work that aims to find ways for communities to better promote health and wellbeing. 


Elizabeth Jarpe-Ratner, Evaluation Director, MidAmerica Center for Public Health Practice Apr 14, 2017 11:38 am

I strongly oppose this policy change. Aside from the complete disregard of any consideration of the ethical implications of the proposed change, it is also discordant with the mission of the University of Illinios at Chicago. This mission include commitments to underresourced and underprivileged communities. 


Furthermore, as a new faculty member who came here to conduct community engaged research with a population that includes a variety of immigration statuses, this policy change could impede my (and others'!) work to such a degree that we might have to take our research (and grant dollars) to another institution. Apr 14, 2017 11:31 am

Thank you for the new FAQ, which includes this information:

"Yes, OBFS and the customer focus groups reviewed a number of human subject payment policies prior to drafting this policy.  This review demonstrated that there is no consistency amongst universities to address the IRS reporting requirements.  Policies for payments to nonresident alien human subjects ranged from (i) the extreme of not allowing payments to human subjects who are nonresident aliens if they have not obtained authorization from their sponsoring agency to receive compensation to (ii) requiring tax identification numbers be obtained only if it is known a human subject is a nonresident alien.  The University’s policy proposed is in the middle of the spectrum of the policies reviewed to ensure compliance with mandatory IRS reporting requirements."

If a policy must be adopted, I strongly urge you to adopt policy (ii) (only ask for ITIN if the subject is known to be a nonresident alien -- to the investigator or to the payer, I'm not sure which) rather than try to fall in the middle. Proactively choose a policy that puts the safety of research subjects and the ability to conduct valid research first. Apr 13, 2017 4:41 pm

The proposed change directly violates federal law regarding the protection of human subjects participating in research (The Belmont Report).  It is not clear that any currently IRB-approved studies would continue to meet ethical standards if the proposed change was implemented, as we would be  a) endangering a specific subset of participants, b) treating participants differently based on their immigration status, or c) conducting biased sampling. Apr 13, 2017 4:12 pm

I strongly urge OBFS to reconsider this proposal. I deeply oppose these proposed changes for compensating potential research volunteers. The purpose of an Institutional Review Board review is to minimize risk and eliminate potential harm to prospective research subjects. This proposed change would work in direct contravention to this stated purpose.

To continue with this proposal would put potential research participants at unnecessary level of risk. This burden is unnecessary and should be avoided. I work closely with UIC’s Survey Research Laboratory because they conducted scientifically sound research; the proposed change puts our relationship at significant risk. This proposal is not good for participants, and not good for UIC. I am ashamed that my alma mater would even consider this policy. This is not what is expected of a research-intensive university. Apr 13, 2017 12:53 pm

"Adds additional information about the tax reporting requirements for payments to non-resident aliens; clarifies the requirement that non-resident alien payments be processed through University Payroll and Benefits due to tax reporting requirements."

Several of our PIs expressed the concern about this policy breaches the confidentiality requirement of human subject research. Apr 13, 2017 9:46 am

I work at Enlace Chicago, a community-based organization that has done research with UIC. Requiring studies to ask about citizenship status will effectively make it impossible to do research with undocumented residents, a vulnerable group that is already difficult to get to participate in research. This will negatively impact research and practice. 

Kevin Rak

Data Specialist, Enlace Chicago Apr 12, 2017 1:47 pm

I strongly opposed this policy change as it is unethical and puts vulnerable populations at risk. This policy change should not be implemented. Apr 12, 2017 1:00 pm

I am strongly opposed to this policy change. This policy proposes the implementation of an unnecessary risk to some of our most vulnerable populations. Apr 9, 2017 6:56 pm

I am strongly opposed to this policy change affecting payment of very small funds to non-resident aliens. It will make it all but impossible to do any kind of research with undocumented communities. This is fundamentally at odds with what President Kileen has U of I as a Welcoming University. Apr 8, 2017 4:23 pm

I deeply oppose these proposed changes for compensating potential research volunteers. The purpose of an IRB review process is to minimize, if not eliminate, risk and potential harm to prospective research subjects. This proposed policy change would work in direct contravention to this stated purpose. These reporting guidelines would put immigrant research participants, especially Latinas/os, in great risk given the increased surveillance by federal authorities against all immigrants, in particular those who lack documentation. In addition to the clear ethical violations this proposed policy would create, it will undermine the research mission of the University of Illinois System. Any researcher who is involved in volunteer recruitment knows how difficult that process is in the best of conditions. If these changes are allowed to go into effect, then they will make recruitment substantially harder. In the long-run, this could even have the effect of researchers leaving Illinois to do their research at institutions without such regulations, and could even impact our ability to recruit future researchers. Apr 8, 2017 2:43 pm

I am opposed to new policy and its requirement that researchers inquire as to the immigration status of study participants. It is unethical, will interfere with research, and contradicts UIC's stated policies on immigration and documentation. Apr 7, 2017 1:55 pm

I have grave concerns about whether this revised policy is ethical or not. I urge the OBFS to solicit and publish statements from the University's ethics officer and IRB officials on their interpretation of the ethical status of the proposed changes. As many other people have posted, this creates an additional danger to people who are not US citizens. This is not a hypothetical danger either. I'm sure you are aware of the case some years ago of the Iranian student at UIUC who got into huge trouble for taking part in a study and being paid a very nominal sum. An internal account audit somehow obtained payment information, realized the student was not allowed to earn $20 and reported them to the authorities. Isn't it strange we don't talk about that real world case in our IRB training? Apr 6, 2017 10:14 pm

I am absolutely opposed to this proposed policy change. The University of Illinois frequently claims to be invested in the well-being of its students. If this policy were to be implemented, the message would be clear: the University of Illinois cares for SOME students, but chooses to treat the others as though they are not humans. 

This policy change should have never been an option, and it certainly should not be implemented. Apr 6, 2017 7:22 pm

I am against researchers being required to ask for documentation of citizenship.  It hampers research on important topics facing our nation.  As a member on the CEAB, we are always asked about increasing subject numbers.  Adding this burden to researchers will greatly reduce their credibility.  Similar issues have occured in the past with police outside places where drug studies were taking place.  That greatly increases the risk for the subject.  The more personally identifiable the subject is the greater the risk.  

This would be an egregious mistake. Apr 6, 2017 5:47 pm

To whom it may concern:

I strongly oppose this or any other change to university policy that discriminates against people on the basis of their immigration status, including undocumented status.  

Such changes are wrong for participants.

  • They put people at risk of being exposed as undocumented.  This can open people up to harassment, discrimination, or violence.
  • They make it harder for participants to be compensated for their labor.
  • They make it harder for students to find opportunities to learn about research.

Such changes are wrong for researchers.

  • It is already incredibly difficult to find participants, but these changes would only make it harder to find enough participants to conduct meangingful research.
  • It is especially difficult to find enough participants to conduct research on special populations, like undocumented immigrants or DACA recipients.  Researchers who need these unique participants will be hit the hardest, and the diminished quality and/or quantity of their research will influence their career trajectory.

Such changes are wrong for the University of Illinois.

  • The University of Illinois is rightfully regarded as a powerhouse of high quality research.  Making it harder to obtain participants will damage our research and our reputation.
  • The University of Illinois also prides itself on its diversity.  This or similar policies undermines this inclusive spirit.

These days it seems like I get an email every other week telling me how devoted to diversity and non-discrimination this university is, but those are just words.  If you mean it, prove it.  


Thank you,

Emily K. Sanders

Doctoral Student

Social Psychology Apr 6, 2017 5:01 pm

I oppose this change. Our research studies require the participation, observation and investigation of diverse populations. The research questions we concern ourselves analyze conditions outside the norm. We often include persons with a diverse backgrounds, age, race, ethnicities, gender, locations, etc. Examining populations with diverse backgrounds help identify resolutions for a broad segment of our populations and not isolated segments.

We recruit and seek to include human subjects that fit requirements to study our concern. We ask them to trust us and agree to do no harm. We protect their privacy and confidentiality in response to their participation and trust. These are difficult conditions for vulnerable persons. Requiring payments to non-residents in a research study to be made by check, complicates recruiting members of the population we seek. This increases a non-diverse sample and results may not be as meaningful for all. Please allow for non-residents confidentiality and do not change the requirement. Allow them cash payments and to be treated fairly along with the all other study participants. Apr 6, 2017 5:00 pm

I'm surprised this is even legal because putting human research subjects at more than minimal risks completely goes against the legislation put into place via implications from the Belmont report. Additionally, I find it hard to grasp how the scientific research concerning humans will be as reliable as before since it is basically excluding a whole subset of people. This issue isn't relevant to science, science needs to seriously consider the safety and wellbeing of all human research subjects. Apr 6, 2017 4:55 pm

This policy change is unethical and should not be implemented. I strongly oppose this policy change. Apr 6, 2017 4:55 pm

I also strongly disagree with this policy. With more research being done in undergraduate learning, I fear this policy would deter, instead of encourge, students to avail themselves of the learning and tutoring services provided at UIC.

- Tim Boester

Director, Mathematical Sciences Learning Center Apr 6, 2017 4:43 pm

I am against this policy, I do not believe that it is ethical to ask study participants about their documentation status. The research that we do is to serve vulnberable populations, the undocumented being one of them. If this policy goes through, we will be doing a diservice to marginalized groups.