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Letter from J. Richard Udry on Research Impact of Tiahrt Amendment
July 4, 2001
This
letter is to comment on the Tiahrt Amendment
to HR 1 (ESEA Reauthorization) as reflected in the May 23, 2001, Congressional
Record.
The purpose of the amendment is laudable-- to make sure that
parents have a voice in determining the participation of their children in
sensitive surveys administered at school. But the remedy proposed--to require
that the school obtain signed parental consent before permitting children to
participate--has damaging consequences for social research that is important for
policy-making and for scientific knowledge about school-aged children. The
discussion in the Congressional Record indicates that those participating did
not understand
the damage to policy-making that would result from the amendment.
All
such surveys are required to have approval of Institutional Review Boards for
the Protection of Human Subjects (IRBs) at the universities or government agencies initiating them.
Current practice is to allow school
policy to determine whether signed consent is required, but to give parents the
right to opt out their children from participation after informing them of the
surveys. Schools ordinarily allow children to participate unless the parents,
upon being informed in writing about the content of the surveys, tell the school
in writing that they want to exclude their own children. Schools invoke signed
consent only if they decide the survey content is especially
sensitive. Experience in doing surveys in schools indicates that
irrespective of the survey content, when parents are ask to give signed consent
and return it to the school, most parents do not respond. Follow-up research
shows that this is not because most parents object to the survey, but because
they simply never get around to responding. When parents are ask to respond if
they DO NOT want their children to participate, only one or two per cent of the
parents opt their children out.
I
want to share my own experience with school participation in the National
Longitudinal Survey of Adolescent Health (Add Health), for which I am the
Principal Investigator. This is a federally-funded survey of a nationally
representative sample of Adolescents, funded by NICHD. In the initial phase of
the study (in 1994-5) we administered a very innocuous one-period self-administered survey in a representative sample of schools (private,
parochial, and public). Twenty per cent of the selected schools declined to
participate on grounds that they could not give up the class time for the
purpose. In all participating schools, Add Health sent out two letters to the
parents of each child.
One
letter was carried via the child, and the other was addressed to the parent by
post. Of the participating schools, five per cent required signed consent, even
though we considered that there were few if any questions
on the survey on topics enumerated in the Tiahrt Amendment.
In those schools, only 25 to 40 per cent of parents returned signed consent
forms. In the schools only requiring signed response to opt out of
the survey, only about one per cent of the parents opted their children out.
When 25 to 40 per cent of the children participate, the results become very
biased, and the validity of the survey is undermined. Had Add Health been
required to use signed consent for participation, the research would have been
impossible, because we could not have believed the results on account of bias in
participation.
Add
Health is a very prominent study, and has been important in policy-making
circles in helping to identify the risks of adolescence and formulate policies
to increase the health of youth. But many other surveys using school
questionnaires play an important role. Among these are the Youth Risk Behavior
Survey (YRBS), a periodic government survey under the administration of CDC. The
YRBS tracks trends in risk behavior in a national sample of American schools,
and is important in informing lawmakers and program administrators of problems
that are emerging or improving. But the YRBS, along with several other school
surveys, would not be credible were it required to use the rules laid down in
this amendment, and would have to be cancelled.
Therefore
I believe that the best policy is for Congress to leave this issue alone, and
trust the good judgment of local school officials to implement the sensible
policies now in place at the local level.
Sincerely,
J.
Richard Udry
Kenan
Professor of Maternal and Child Health/Sociology
Carolina
Population Center
University
of North Carolina at Chapel Hill
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