ASPE Research Subject to Institutional Review Board Exemption

03/06/2020

The Common Rule governing Human Subjects Protection allows exemptions to IRB requirements for research that is:

“designed to study, evaluate, improve, or otherwise examine public benefit or service programs, including procedures for obtaining benefits or services under those programs, possible changes in or alternatives to those programs or procedures, or possible changes in methods or levels of payment for benefits or services under those programs. Such projects include, but are not limited to, internal studies by Federal employees, and studies under contracts or consulting arrangements, cooperative agreements, or grants. Exempt projects also include waivers of otherwise mandatory requirements using authorities such as sections 1115 and 1115A of the Social Security Act, as amended.” (45 CFR 46.104)

The regulation further requires that:

“Each Federal department or agency conducting or supporting the research and demonstration projects must establish, on a publicly accessible Federal Web site or as the department or agency head may determine, a list of their research and demonstration projects conducted or supported under this provision. The project must be published on this list prior to commencing the research involving human subjects.”

This web page provides ASPE’s list of research projects supported under this provision of the Common Rule.

Study Title: Freeing Children for Adoption: States’ Use of Exceptions to Federal Requirements on Termination of Parental Rights for Children in Foster Care for Extended Periods

Abstract: This project will examine the extent to which terminations of parental rights (TPR) are conducted for children who have spent at least 15 of the previous 22 months in foster care, freeing them for adoption. This timeline, with certain permissible exceptions, has been part of federal child welfare law since 1997, though recent monitoring results show that few states adhere to the requirement. Under the current phase of the research, a contractor will conduct case studies of several states to explore these states' policies and practices with respect to granting exceptions. State officials, caseworkers, judges, and potentially birth and foster families will be interviewed in study states to gain a perspective on which statutory exceptions are used, the rationales and practices regarding the granting of exceptions, and agencies' and courts' perspectives on the TPR requirement and the value and purpose of exceptions.

Contractor (or Intramural): Mathematica

Period of Performance: September 2019 to August 2020

Study Title: A Model Effective Marginal Tax Rate Calculator for Families and Caseworkers

Abstract: When families increase earnings, they may also experience a change in program benefits and taxes, and the amount of new earnings not retained (on net) is the family’s marginal tax rate. On the road to self-sufficiency, families need to know their own effective marginal tax rate: as families make strides to increase earnings, they need to know which benefits would be reduced, by how much, and when. Yet this vital information is frequently elusive to even caseworkers who advise families on how to use work to achieve self-sufficiency. To address the problem, this contract aims to develop an accurate and comprehensive model marginal tax rate (MTR) calculator for use by both caseworkers and families. The model MTR calculator will accurately reflect program rules applicable at the state and local level, and be comprehensive by including every major program available to families in a particular state or county.

The proposed calculator would address outsized fears of benefit loss that may hold some families back from securing additional earnings. At a basic level, knowledge of how and when benefits change is important for financial planning and reallocating resources for necessities such as food and rent. Without information about benefit reductions, struggling families may guess or even fail to anticipate benefit reductions at all. Unanticipated benefit reductions can deal an emotional blow to families working hard to get ahead. With this accurate and comprehensive calculator, caseworkers would be prepared to help families plan for independence. Results are also likely to be of interest to policymakers who are interested in incentivizing work.

The successful development of a model MTR calculator would serve as a proof of concept for an interactive calculator that other federal, state, and local efforts could follow. The model would be accompanied by a toolkit that would provide the open source code for the web application and lessons learned in working with state/local partners to develop the calculator so that it can be easily replicated by other localities.

Contractor (or Intramural): Manhattan Strategy Group

Period of Performance: September 2019 to June 2021