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Research Ethics (CITI)

Which of the following activities constitutes engagement in research?

Quick answer

An institution or person is engaged in research when they obtain informed consent, intervene or interact with living subjects for research, or obtain individually identifiable private information for research purposes. Merely funding, writing about, or providing data without identifiers is not engagement.

The answer

Under the OHRP (Office for Human Research Protections) guidance, an institution is engaged in human subjects research when its employees or agents, for the purposes of a research study, do any of the following:

  • Obtain informed consent of human subjects,
  • Intervene or interact with living individuals (e.g., perform procedures, manipulate the environment, or communicate/interact for data collection), or
  • Obtain individually identifiable private information about living individuals.

So among typical MCQ options, the activity that constitutes engagement is the one where staff obtain informed consent and/or interact/intervene with subjects for research purposes, or receive identifiable private data. That triggers the need for IRB oversight and, usually, an assurance (like a Federalwide Assurance) with OHRP.

Why these criteria matter

Engagement is the trigger that pulls an institution under the human-subjects protection regulations (45 CFR 46). If you are engaged, you generally need IRB review and an approved assurance. The definition deliberately centers on direct involvement with subjects or their identifiable data, because that is where the risk to human subjects actually arises.

Why the other options are wrong

Several common distractors describe activities that do not constitute engagement:

  • Providing funding. An institution that only funds a study (for example, awarding a grant) is not engaged, even though its money supports the work.
  • Writing, editing, or reviewing. Authoring a manuscript, serving as a journal reviewer, or performing statistical analysis on a de-identified dataset does not, by itself, constitute engagement.
  • Providing coded/de-identified data or specimens without identifiers. If personnel never receive identifiable private information and do not interact with subjects, they are not engaged.
  • Informing prospective subjects about a study or providing referrals without obtaining consent or performing study procedures generally does not rise to engagement.
  • Permitting use of a facility (letting researchers use space) without staff participating in research activities is not engagement.

The bigger picture

OHRP created the engagement concept so that responsibility for protecting subjects is assigned to the institutions whose people actually touch subjects or their identifiable data. A key nuance: even a single qualifying activity by an employee or agent — such as obtaining consent at a satellite clinic — can make the whole institution engaged. Conversely, an institution can be deeply connected to a project (funding it, hosting it, publishing it) and still not be engaged if its staff never interact with subjects or handle identifiable information. When you evaluate an answer option, ask: does this person, acting as an agent of the institution, obtain consent, interact/intervene with living subjects, or obtain identifiable private information for the research? If yes, it is engagement.

Walk the decision
  1. 1

    Does the activity involve obtaining informed consent from subjects for research?

    If yes → engaged in research.

  2. 2

    Does it involve intervening or interacting with living subjects for research (procedures, surveys, interviews)?

  3. 3

    Does it involve obtaining individually identifiable private information for research?

  4. 4

    Is the role only funding, hosting, publishing, reviewing, or handling de-identified data?

Frequently asked

What does it mean to be engaged in research per OHRP?

An institution is engaged when its employees or agents, for a study, obtain informed consent, intervene or interact with living subjects, or obtain individually identifiable private information. Engagement triggers IRB oversight and typically an assurance with OHRP.

Which activities do NOT constitute engagement in research?

Only funding a study, permitting use of a facility, authoring or reviewing manuscripts, performing analysis on de-identified data, or simply referring/informing potential subjects without obtaining consent or performing study procedures do not constitute engagement.

When is an institution considered engaged in human subjects research?

When at least one of its employees or agents obtains consent, interacts/intervenes with living subjects, or obtains identifiable private information for the research. Even a single qualifying activity by one agent can make the entire institution engaged.

Does obtaining informed consent count as engagement in research?

Yes. Obtaining the informed consent of human subjects for a study is one of OHRP's explicit criteria for engagement, so the institution whose staff obtain consent is engaged and needs appropriate IRB review and assurance.

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