Does this need to be reviewed by the IRB?
The Office Of Human Research Protections (OHRP) has decision charts to help you decide whether an application should be submitted to the IRB and what kind of application it will be [Exempt or Non-Exempt (also known as the Full Board/Expedited Application) ]. We apply the regulations regardless of funding so that step in the decision chart does not apply.
If the decision charts are confusion just let us know. We happy to chat by phone, video chat, or by email.