ACS Research and Evaluation Submission Guidelines

The ACS Research Review Committee (RRC) reviews proposals for research and evaluation involving children and families served by ACS. Research/evaluations involving staff, foster parents, and contract agencies is also subject to review by the RRC. This includes master's, and doctoral level student projects. These guidelines outline the review process for requests to conduct research or evaluations using Agency data. Research/evaluation that is based solely on aggregate data or aggregated results of statistical analyses is exempt from the review process.

The types of research and evaluation covered under these guidelines include studies by both outside organizations and Agency program areas that require access to agency clients, administrative data, and/or agency staff, for the purposes of analyzing a research question or conducting a program evaluation.

Research/evaluation approval will be extended only to proposed studies that are of sufficient value to program areas to justify the time, resources and staff that ACS participation may require.

The RRC is chaired by a designee within the Division of Policy, Planning, and Measurement (PPM). Membership represents many disciplines within ACS.

A complete copy of your research/evaluation proposal must be submitted using the ACS submission template.

Confidentiality

The safeguarding of our client's confidentiality is mandated by statute. Accordingly, all personally identifying client information must be protected. A researcher or evaluator may not have access to such information except under certain circumstances set by law.

New York State Office of Children and Family Services (OCFS) approval is necessary when any client-specific information is to be obtained from either case records or interviews. The researcher/evaluator must obtain written approval from OCFS) in order to have access to confidential client specific information. Access, when granted by OCFS, is only accorded to the researcher/evaluator and admonishes the researcher not to re-disclose client identifying information.

Release of Research/Evaluation Findings

The proposal must include a description of the plan for dissemination of findings. This should include a statement that the researcher/evaluator agrees to provide the ACS RRC with findings prior to public release, including all relevant materials (e.g. tables, statistics, etc.). Any planned publications should be submitted in draft to the ACS RRC and to OCFS for review before they are sent to publishers.

Support

Include Letters of Support from parties immediately involved in or affected by the research/evaluation (e.g. provider agencies, ACS divisions).

Standards for Research Involving Human Subjects

The research/evaluation protocol must meet the following criteria:

1. poses minimal risk to children and families;
2. assures that the safest procedures will be used and are consistent with sound research design and methodology;
3. assures that appropriate safeguards have been included to protect vulnerable subjects;
4. demonstrates that informed consent, if applicable, is adequate and appropriately documented;
5. assures the privacy rights of children and families and maintains confidentiality of records;
6. where appropriate, makes adequate provision for monitoring the data collected to ensure the safety of subjects; and
7. assures that the subjects will be selected in an equitable manner.

Informed Consent

RRC review or approval does not guarantee consent from contract agencies, nor does approval guarantee that consent will be obtained from children for whom ACS has legal responsibility or from parents or children who are clients of ACS. Responsibility for obtaining consent from subjects lies with the researcher/evaluator.

Research investigators are responsible for obtaining consent to participate from any subject age 18 or older. If the subject is under the age of 18, consent must be obtained from parents who retain guardianship of any child to be involved in the research. If the child is residing with foster parents, they must be informed about the research; however foster parents can never consent for foster children in their care. In the case of children who have been freed for adoption (i.e. parental rights have been surrendered or terminated), consent must be obtained from the Commissioner of ACS, their legal guardian.

The consent form must inform the participant of exactly what his or her participation will involve and the overall length of time he or she will be expected to spend.

The consent form should be written in a language that the participant is fluent in and must be at an appropriate reading level for all participants (or the participant's legally authorized representative); the generally recommended reading level is no higher than 8th grade. The following elements must be included in the consent form: (a) identification of the research project, purposes, duration and procedures; (b) reasonably foreseeable risks or discomforts; (c) reasonably expected benefits to the participant or others; (d) alternative interventions, if any, that might be advantageous to the participant; (e) extent of confidentiality to be maintained; and (f) whom to contact for answers to questions about the research, participant's rights, and research-related injury.

The consent form must state that participation is voluntary and that refusal to participate will not result in any penalty or loss of service. Participants should be informed that they are free to withdraw from the study at any time. The proposal should describe procedures used to determine the participant's understanding of consent.

Note: A written consent form is not necessary in the case of anonymous data collection.

Informed Consent for Non-English Speakers and Persons with Limited Literacy Skills

Those who do not speak English should not be categorically excluded from participating in the study. In such cases, unless the principal investigators are fluent in the language of the participant, a translator must be included in the consent process. The translator must sign his or her name at the end of the consent form. In addition, the participant must be given a translated version of the consent form. If the participant has limited literacy skills, or if no translated consent document in the participant's language is reasonably available, arrangements must be made to obtain verbal consent. Persons with limited literacy skills who understand English may have the consent form read to them and make a “mark” on the participant's signature line. In such situations, signatures of the witness to the consent process and the person conducting the consent interview are required.

Assent of Children

Research studies involving children who are old enough to understand and agree to participate in the study (children 8-17) must include an assent form. This would be in addition to, not in place of, the consent form. The assent form should be written in simple language, appropriate for a child. It should include the purpose of the study, benefits to ACS and the child, risks and discomforts, and procedures of the study. The child should understand that he/she can choose not to be in the study at any time and there will be no punishment for not participating. Whenever possible a verbal assent should be obtained from children younger than age eight.

Additional Considerations for Conducting Research

1. Please be aware that unfounded reports of abuse or neglect and FAR/CARES (NY's alternative Child Protective response cases) cannot be made available for any research purposes.
2. OCFS review is required in order to obtain access to former client information.
3. Interviewing unionized ACS employees necessitates obtaining consent from the employee's labor union.
4. OCFS requires Statewide Central Register of Child Abuse and Maltreatment Clearance (as to the existence of any indicated reports of child abuse and maltreatment) prior to conducting research with children who are clients of ACS).
5. ACS confidentiality agreements are required for projects subject to OCFS approval.

Federal Restrictions

Federal regulations CFR 46.409, include certain restrictions which apply specifically to wards of the State involved in research. These regulations include:

1. Wards of the State cannot be used as subjects in research involving greater than minimal risk in which there is not benefit either directly to the child or to the class of children who are wards. An exception to this rule may be when the majority of the sample does not consist of wards, but the child's school, camp, hospital, or other similar institution that has been selected to participate in research.
2. Wards of the State cannot be selected as the majority of subjects in a study solely on the basis of their convenience to the researcher, regardless of the cost entailed in obtaining subjects from another population

HIV and Drug Program Information

Please be aware that HIV and Substance Abuse Program Information is never accessible unless the researcher obtains consent in writing from the individual participant. Consequently, without the participant's signed authorization, that information will be deleted from the record before it is released to the researcher.

Use of Foster Children in HIV/AIDS Related Research

Information pertaining to confidential HIV related information is protected by New York State Law. Article 27 F of the Public Health Law prohibits further disclosure of this information without specific written consent of the person to whom it pertains, or as otherwise permitted by law. Any unauthorized disclosure in violation of New York State law may result in a fine or jail sentence or both. A general authorization for the release of medical or other information is not sufficient authorization for further disclosure.

Use of Experimental Drugs

In general, ACS will not permit the use of experimental drugs in research. These rules do not apply on an individual case basis. Such case decisions do not fall under the RRC unless the case is part of a research project. The enrollment for ACS approved clinical trials is outlined in Bulletin 98-2/Procedure 101.

Double Blind Studies

The use of double blind studies in medical research are prohibited due to the vulnerable nature of the children and families served by ACS.

Pending Litigation

The release of any information that concerns ACS's pending litigation must be reviewed by the ACS Office of the General Counsel to determine accessibility.

Research Costs

Any services that a client receives as part of a research/evaluation project that are not ordinarily covered in ACS's contracts will not be reimbursable by ACS. Researchers are responsible for all costs associated with their research.

Submission Process

Time Frames and Procedures for Review and Notification

Contact Information

Sara Workman
Executive Director
Office of Research and Analytics
Division of Policy, Planning, and Measurement
150 William Street, 17A2
New York, NY 10038
(212) 341-2839
ResearchReview@acs.nyc.gov

Within a month of receiving a proposal, the RRC will review your submission. Upon review the RRC will work with you to address any gaps or weaknesses in the submission. OCFS approval is necessary when any client-specific information is to be obtained from either case records, surveys, focus groups or interviews. Upon RRC approval, for submissions that require OCFS review, RRC will draft a conditional approval letter to be shared with OCFS. You are responsible for submitting your proposal to OCFS, but OCFS will not approve it without prior ACS conditional approval. Once you have an approval letter from OCFS, you must submit this letter to the RRC before beginning work. Upon receipt of OCFS approval letter, the RRC will issue a final approval letter for your work.

Contact Information

NYS Office of Children and Family Services
Office of Research, Evaluation, and Performance Analytics
Room 323/North Building
52 Washington St
Rensselaer, NY 12144
(518) 474-9426
ocfs.sm.researchproposal@ocfs.ny.gov

Upon RRC approval, for submissions that do not require OCFS review, RRC will issue a final approval letter, Once your project is in process, any method changes must be approved by the RRC and by OCFS if OCFS has issued a confidentiality agreement. ACS and OCFS require that you submit a draft copy of your work to the RRC and OCFS Office of Research, Evaluation, and Performance Analytics for review prior to any type of publication.

Minimal risk must not be greater overall than would be normally encountered in the daily lives, routine medical, or psychological care of a comparable group of New York children for whom ACS is not legally responsible. ACS recognizes that abused, neglected, dependent and other children for whom ACS is legally responsible and their families may already be psychologically or physically disadvantaged compared to the general population of children and families. Therefore, the minimal risk requirements for these children and families may be more stringent than for the general population.