In 2006, the American Association of University Professors filed a Freedom of Information Act request for a list of all U.S. colleges and universities whose Federalwide Assurances (FWAs) did not check the box on the form pledging to apply federal regulations to all human subjects research, regardless of funding. The list contained 174 entries, though 12 of those were duplicates. (See "IRB Documents" for these lists._
In March 2010, I reported that OHRP estimated that 26 percent of U.S. institutions had unchecked their boxes, up from only about 10 percent in the late 1990s. Curious about this trend, I requested an updated list, and in April 2010 I received a spreadsheet showing all institutions (including hospitals, health departments, commercial labs, and other health institutions) with unchecked boxes.
Making sense of this list took some processing, which accounts for the delay between my receiving the spreadsheet and this post. I did my best to extract institutions of higher learning, and came up with a list of 207 colleges and universities. Then I compared that list to the 2006 list sent to the AAUP.
Only 60 institutions appear on both the 2006 and 2010 lists. One hundred and two had unchecked boxes in 2006 but not 2010, while 147 unchecked their boxes between 2006 and 2010.
Major research universities appear on both lists. Between 2006 and 2010, William & Mary, Johns Hopkins, Princeton, and the University of Connecticut, went from unchecked to checked. Meanwhile, those unchecking boxes included Arizona, Boston University, Brandeis, Emory, George Washington University, Illinois at Urbana-Champaign, Indiana, Michigan State, Minnesota, Northwestern, Notre Dame, Ohio State, University of Pennsylvania, Texas at Austin, Tufts, UCLA, and the University of Southern California. This suggests that the trend is for major research institutions to uncheck. (Apologies to major universities not mentioned; this is my eyeball list, not an effort to correlate the list to Carnegie rankings or anything.)
An unchecked box minimizes a university's exposure to federal oversight and sanction. It does not, however, necessarily change anything for a university's researchers. My own institution, George Mason University, unchecked its box sometime between 2006 and 2010, but the administration has told faculty that it intends to apply all federal regulations to all research, regardless of funding. I imagine the same is true at many of the institutions that have unchecked their boxes.
Update, 15 May 2012, to fix link to "IRB Documents."