Hi. You should go back to the definition of research in the regulations (45 CFR 46). Is the goal of the evaluation to develop "generalizable knowledge," then they are conducting research. We face this issue in the medical arena, where we try to distinguish on oging quality assessments and improvement from research. If the goal is "simply" to review data and make in-house improvements to systems and processes, then the activity might be construed as QA or program evaluation. But, if there is any thought about making the outcomes of the QA process known to colleagues through presentations or publications, then we consider it to be research. It is less about the methods being used, and more about the intent and goal. This answer deals more with the question from a human subjects point of view and less with assigning the appropriate indirect cost rate. But, if the project is considered research by the IRB, it would be research for the purposes of indirect costs. Judy Judith Argon Vice President, Research Administration Joseph Stokes Jr., Research Institute Children's Hospital of Philadelphia 135 Abramson Research Center 3615 Civic Center Blvd. Philadelphia, PA 19104-4318 Tel: 215-590-2855 Fax: 215-590-3804 >>> xxxxxx@SVCMCNY.ORG 12/05/05 12:58 PM >>> Hi, All of the methods you mention are research. In the first instance, program evaluation, the investigator is assessing process and/or outcome measures. These would be considered dependent variables, while the "program" is the independent variable. This research would be considered causal field research according to Cook and Campbell. (Quasi-Experimentation: Design and Analysis Issues for Field Settings; 1979") Needs Assessments might fall into the above category, but often times, these use survey designs for data gathering. The needs assessments inform program development. Survey methods are also research. Focus Groups fall into the category of Qualitative Analysis where the research data is gathered from transcripts of groups of people discussing a particular topic with a facilitator. The data is then analyzed using qualitative research techniques to generate hypotheses. Secondary uses of primary data. There are many research methods used for this type of work. Examples are the use of medical charts for case-control or retrospective cohort studies. The use of Medicare or Medicaid data for Cost Benefit/Cost-Effectiveness analyses, and the use of published/unpublished research results for Meta-analyses. All of these are examples of research that fall within the federal definition of research. Steve Steven Lascher, DVM, MPH Vice President, Research Office of Research and Clinical Trials Saint Vincent Catholic Medical Centers 170 W. 12th Street - Staff House New York, NY 10011 (v) 212.604.7470 (f) 212.604-7159 e-mail: xxxxxx@svcmcny.org -----Original Message----- From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On Behalf Of Maureen McMahon Sent: Monday, December 05, 2005 11:12 AM To: xxxxxx@HRINET.ORG Subject: [RESADM-L] Definition of research vs. other sponsored activity Hello All- I am trying to get a read on whether activities such as conducting a program evaluation or a study including activities such as needs assessment, focus groups, and review of secondary data falls within the federal definition of research or would qualify as "other sponsored activity." We have a unit on campus that does quite a bit of this type of activity and insists it falls into the "Other" category. Any insights would be welcome. Thanks, Maureen B. 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