Title IX Reporting Exception for Research

State and Federal law require that University of New Hampshire (UNH) researchers report to the UNH Title IX Coordinator whenever a research subject discloses a Title IX sexual violence incident.  These include sexual harassment, sexual assault, unwanted sexual contact, sexual misconduct, domestic violence, relationship abuse, stalking (including cyber-stalking) and dating violence by or against a UNH student.  UNH researchers also must report to UNH Police if the Title IX sexual violence incident involves criminal conduct, or if a research subject makes a disclosure about hazing, suspected child abuse and/neglect, or abuse/neglect of an incapacitated adult.

UNH Title IX Coordinator

UNH Police

hazing, suspected child abuse and/neglect, or abuse/neglect of an incapacitated adult

UNH is permitting a limited exception to mandatory Title IX reporting when disclosures are made in the context of a research project involving human subjects that is under the oversight of the UNH Institutional Review Board (IRB), and is focused on certain topics, such as sexual violence.  Researchers are excepted from Title IX reporting obligations only for disclosures made during the research project for which a Title IX reporting exception has been approved by the UNH IRB.

UNH researchers contemplating requesting UNH IRB approval of a Title IX reporting exception for a specific research project need to know the following:

  • A Title IX reporting exception is not available for research projects that contemplate the use of subjects who are minors (students under age 18).
  • A Title IX reporting exception for research is only for reporting of student-on-student sexual violence incidents, and will not relieve researchers from other reporting responsibilities, including the duty to report hazing, suspected abuse/neglect of a child or of an incapacitated adult, and any sexual violence incidents potentially perpetrated by an employee against a UNH student.
  • A Title IX reporting exception for research extends to all researchers on a designated project, including UNH faculty, staff and student researchers identified in the IRB application.
  • A Title IX reporting exception for research applies only to disclosures made during the research project.  Disclosures made to research personnel outside of the research protocols (e.g., to faculty during office hours or while providing academic advising) are NOT excepted from reporting requirements.
  • In order to apply to the UNH IRB for approval of a Title IX reporting exception, an applicant must be either a UNH faculty or staff member, or a UNH graduate student.  If an applicant is a graduate student, the faculty advisor who signs the Request for IRB Review form for the project must also sign the Application for a Title IX Reporting Exception for Research form (Word version) (fillable PDF version).
  • The UNH IRB will review all applications that include a request for approval of a Title IX reporting exception at the Full Board level (i.e., at a convened meeting of the IRB).
  • Prior to any data collection, a researcher must make clear to all research participants that disclosures made during interviews are not considered sufficient notice to UNH for purposes of triggering an individual investigation under Title IX.  The consent form approved by the IRB for the project will include language that provides the requisite information to research participants.

Full Board level

The following is the process for requesting UNH IRB approval of a Title IX reporting exception for research:

  1. In order for the UNH IRB to consider a request for approval of a Title IX reporting exception, a UNH researcher must provide as part of the application materials a completed Application for a Title IX Reporting Exception for Research form (Word version) (fillable PDF version) and which is signed by the applicant, and for graduate student applicants, the faculty advisor.
  2. A researcher needs to submit in the application materials a proposed consent form, which includes language specific to the Title IX reporting exception.
  3. A researcher needs to include in the narrative that all study participants will be provided the URL https://www.unh.edu/affirmativeaction/reporting-students as part of the debriefing process.
  4. The UNH IRB will review all applications that include a request for approval of a Title IX reporting exception at the Full Board level (i.e., at a convened meeting of the IRB).
  5. Upon receipt of an application that includes a request for approval of a Title IX reporting exception, Research Integrity Services staff will forward a copy of the application materials to the USNH General Counsel’s Office, the UNH Title IX Coordinator, and the UNH Associate Vice President for Community, Equity and Diversity for their review.  Their review will take place concurrent with the UNH IRB’s review of the application.  The UNH IRB will not issue a final decision about the request for the use of human subjects in research, including the request of a Title IX reporting exception, until it has received from these offices the results of their review.
  6. If a Title IX reporting exception is approved by the UNH IRB as part of the study protocol, the IRB will assign the letter “E” to the IRB four digital identification number to denote that the project has a Title IX reporting exception approved as part of the protocol.

proposed consent form

Full Board level

Please contact Melissa McGeeJulie Simpson, or Theresa Cherouvis in UNH Research Integrity Services at 603/862-2005, 603/862-2003, or 603/862-3536 with any questions about the Title IX reporting exception for research.

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The Knowledge Base contains forms, instruction and training material, policies, guidance, tools, and other resources to support your research efforts by topic area.


CONTACT INFORMATION

Melissa McGee, Compliance Officer
Research Integrity Services
Service Building, Room 106B
51 College Road
Durham, NH 03824
Phone: (603) 862-2005
Email: melissa.mcgee@unh.edu

Julie Simpson, Director,
Research Integrity Services
Service Building Room 107
51 College Road
Durham, NH 03824
Phone: (603) 862-2003
Email: julie.simpson@unh.edu

Theresa Cherouvis
Sr Program Support Assistant
Research Integrity Services
Service Building Room 107
51 College Road
Durham, NH 03824
Phone: (603) 862-3536
Email: theresa.cherouvis@unh.edu