Does this need to be reviewed by the IRB?
There are several resources to help you with this. We now have a “Human Subjects Research Determination Form” to help you with this question. This form, will ask you a series of questions to help determine whether your project should be reviewed by the IRB.
In addition, 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, expedited, or full board). We apply the regulations regardless of funding so that step in the decision chart does not apply.