78. Additional DoEd Regulations - Protection of Pupil Rights Amendment (PPRA)

Updated June 23, 2021

PPRA is the abbreviation used for Department of Education (DoEd) regulations (34CFR98) for research involving certain types of surveys, and psychiatric or psychological examinations, and testing or treatment; and applies to all research conducted at schools receiving funds from the DoEd.

Information about PPRA may be found on the US DoEd website as follows:

• Protection of Pupil Rights Amendment (PPRA)
• Model Notification of Rights Under PPRA

NOTE: PPRA may apply to research conducted at schools that do not receive funding from the DoEd when the research questions are about the protected information listed above. In these circumstances, the investigators must complete the following steps:

• Verify the schools or agencies have policies in place that address PPRA requirements and that the policies were developed in conjunction with parents.
• Provide the IRB with written documentation from the school or agency to verify that PPRA requirements are met.
• Provide participating students and their parents with information about the school or agency policies unless the information has already been conveyed by the school or agency.

PPRA Requirements for Parental Permission and Child/Youth Assent

PPRA requires (i) prior consent of the student, if the student is an adult or emancipated minor; or (ii) prior written permission of the parent or guardian and student assent, if the student is not an emancipated minor before a student may submit to research involving surveys, psychiatric or psychological examination, testing or treatment in which the primary purpose is to reveal information concerning any of the following:

• political affiliations or beliefs of the student or the student’s parent;
• mental and psychological problems potentially embarrassing to the student and her or his family;
• sex behavior and attitudes;
• illegal, anti-social, self-incriminating, or demeaning behavior;
• critical appraisals of other individuals with whom the student has close family relationships;
• legally recognized privileged and analogous relationships such as those of lawyers, physicians, and ministers;
• religious practices, affiliations, or beliefs of the student or the student’s parent, or
• income other than that required by law to determine eligibility for participation in a program or for receiving financial assistance.

PPRA Requirements for Parental Access to Surveys and Instructional Materials

For surveys that invoke PPRA, researchers must have provisions to allow parents to review surveys and instructional materials (e.g., teachers' manuals, films, tapes, or other supplementary materials) to be used in connection with any research study. This requirement includes surveys or materials created by a third party.

• Investigators must inform parents about their rights to review research surveys and instructional materials before these are administered to or used by students.
• Investigators must give parents reasonable access within a reasonable period to review research surveys or materials before these are administered to or used by students.
• The IRB must be told how the surveys or instructional materials will be made available to parents and how this availability will be communicated to parents.

PPRA also requires the following:

• Investigators must describe how parents will be notified of the administration of physical examinations or screenings that the school or agency may administer to a student for research.
• Investigators must justify and describe procedures for obtaining and sharing personal information from students when this information will be collected, disclosed, or used for marketing or sale, or provided to others for marketing or sale.
  • The descriptions must address how student privacy will be protected under these circumstances.
  • The descriptions must include information about how parents and students will be informed of the use of students’ personal information for marketing or sale, whether by the investigators or others.