Should Capstone Activities Be Subject to the Human Subjects Review Process?

Like many schools of public policy and management, New York University's Wagner School offers a capstone course in which teams of MPA students provide consultation to client organizations, This year, as the they began to assign students to teams, some members of the faculty sounded an alarm. Several of the projects might involve interviewing service recipients about sensitive issues. Other projects would give teams access to confidential information. Faculty members experience with their university human subjects review board knew that such projects, where they to be undertaken in a research context, would require lengthy and cumbersome review. Did the capstone projects need to go through the human subjects review process? If the answer was yes, the program would come to a grinding halt, given the open-endness of a capstone assignments and the bureaucratic nature of the committee application and approval process.