Life after the WGU approval letter: continuing review, reports, and closure
The letter arrives and the branch keeps going. WGU's policy is explicit that approval opens a period of oversight rather than ending one: the board monitors work it has approved and reviews it again on a cycle. Three things run through that period — a review that comes round, a duty to report certain events without waiting for it, and a moment when the project is genuinely finished and the file is closed.
Approval covers a period, and WGU's board reviews approved work again on a cycle. Certain events go to the board at once instead of waiting for that cycle. The file is closed when nothing identifiable about people is still being gathered or analysed.
What does WGU do after it approves a capstone project?
WGU's published policy states that once a proposal is approved, the board monitors the work and carries out continuing reviews at least annually, or more often where that is warranted. Alongside that cycle sits a standing obligation on the person running the project: unanticipated risks to participants are reported promptly, and needed changes to the approved plan go to the board before they are put into practice.
Worth knowing, because it explains a common confusion: the federal framework was amended so that continuing review is not automatically required for work eligible for review by the lighter procedures, unless the board decides otherwise. Plenty of published material written for other institutions repeats that carve-out. WGU's own statement describes a board that keeps reviewing, so what governs your capstone is WGU's current handbook or IRB portal together with the dates on your own letter — never a general position quoted from elsewhere.
Practical consequence: read the letter for its dates and its conditions the day it arrives, put the review point in your own calendar, and treat any reminder from the office as a courtesy rather than the mechanism. Federal guidance is blunt that supplying what the board needs for its review, in time, belongs to the person running the project.
What is a continuing review asking you to show?
Not an essay. A board re-reading a project is testing whether the arrangement it approved is still the arrangement in operation, and whether the balance it struck still holds. Federal guidance on continuing review sets out what that means in practice, and it is a short list.
- Consistency. Does what you report match the approved plan? Where it does not, the board may hold re-approval and ask what happened.
- How many joined. The approved plan carried an expected number; a wide gap either way invites questions about whether the project can still answer its question.
- Who left, and why. Withdrawals and their reasons, where known, because a pattern in them can indicate a burden nobody predicted.
- Anything reported since. Problems, complaints, changes already cleared.
- What remains. Whether collection continues, or only analysis is left.
Boards also reconfirm the original approval criteria at this point: risks still minimised, selection still fair, consent still genuinely sought, privacy and confidentiality provisions still adequate. Nothing new is being asked; the same criteria are being tested against a project that has now met reality.
What happens if the approval period ends first?
Approval expires on its stated date, and federal guidance is unambiguous that the regulations make no provision for a grace period. If the review has not happened by that date, all activity involving people stops. Nobody new may be brought into the project after expiry, and analysis of identifiable material is part of what stops.
There is one carve-out, and it protects people rather than projects: participation may continue for those already taking part where stopping would itself be against their interests — a judgement the person running the project may make first, in consultation where appropriate, but which must then go to the board for confirmation as soon as possible.
For a capstone this is worth reading twice, because the shape of capstone work invites a lapse. Collection finishes, months of analysis and writing follow, an approval date passes unnoticed while identifiable material is still being worked on, and nobody realises until a chapter is being defended. The prevention costs nothing: know your date, and either seek review in good time or close the file honestly when the project is genuinely finished with people.
Which events must be reported without waiting for the review?
Some things do not wait for a cycle. Federal guidance defines the reportable category tightly: an unanticipated problem is an incident that is unexpected given what your approved documents described and the people you are studying, that is related or possibly related to taking part, and that suggests participants or others face a greater risk of harm — physical, psychological, economic or social — than was previously recognised. All three tests together.
| What happened | Obligation |
|---|---|
| An unencrypted file of identifiable responses is lost or a laptop is stolen | Report. Guidance treats exactly this as reportable even where no one is visibly harmed, because exposure raises social and psychological risk above what was recognised |
| A participant is distressed by an interview question in a way the file did not anticipate | Report, and expect the board to consider whether wording, consent text or support arrangements should change |
| You discover collection has drifted beyond what was approved | Stop the drifting activity, report what occurred, and ask how the board wishes the material handled |
| A complaint reaches you, or a facility withdraws its permission | Report; the approved arrangement no longer matches the ground |
| You want to add a site, question, route or handler | Not a report — clearance first, as changing an approved project sets out |
| Recruitment is slower than hoped | Ordinary difficulty. It belongs in the next review, not in an urgent report |
Behind the duty sits the board's authority to suspend or terminate approval of work not being conducted as required, with reasons stated and reported onward. That authority is used rarely and reads far worse when a board discovers a problem than when it is told about one.
When is a project finished, and who says so?
Federal guidance draws the line by activity rather than by feeling finished. A project still involves people for as long as data is being obtained through interaction or intervention with them, or identifiable private information about them is being collected, received, used, studied or analysed. Once all of that has stopped — for instance when the only work left is analysis of aggregate material carrying no individual identifiers — the project no longer needs continuing review, and the board can formally close its file and tell you it has done so.
Two practical corollaries follow. Holding identifiable material without working on it is not, in itself, a continuing project. And whether a closing report is required, and what it must contain, is decided by the institution rather than by the regulations, so the answer for a WGU capstone lives in WGU's current handbook or IRB portal and is worth asking your capstone instructor about before you assume either way.
Closing well is a small courtesy that protects you later. A closed file with a dated confirmation is the clean end of the branch; an approval quietly left open is an obligation that outlives the project.
What should you keep once it is closed?
- The approval letter, with its dates and any conditions written on it.
- Every approved document at the version that was approved, plus every cleared change and its date.
- Correspondence with the board, including anything you reported and what was said back.
- Confirmation that the file is closed.
- Your data, held and destroyed exactly as the approved security plan promised — the promise outlives the approval, and the destruction trigger you wrote is a commitment to participants.
The consent text people signed is part of that record too; if you are still drafting one, what the consent file has to carry is the piece to read next.
Where does this desk fit?
The desk that built and filed a package keeps it: approved versions, dates, cleared changes and the review point in a calendar, so a continuing review is a short conversation rather than an archaeology project, and so closure happens on purpose. This practice is independent of Western Governors University. Your project and your findings are yours; approval, re-approval and closure are the board's. The eight stations describe the engagement, and the questions page answers the rest.
What to do next
Holding an approval letter and unsure what it obliges — whether a review is due, whether something that happened should have been reported, whether the project can now be closed? Send the letter and a short note on where the work stands. The reading is free and will tell you what the dates mean and what the board is owed. Request the free application review. Where the letter in hand is a return instead, start with reading the return.
Sources
- WGU policy handbook, Institutional Review Board (IRB) — monitoring of approved work, the continuing review cycle, prompt notice of unanticipated risks and of needed changes before implementation: cm.wgu.edu (WGU Knowledge Center, IRB policy)
- OHRP guidance on continuing review (2010) — the progress information a board considers, the absence of any grace period, what stops when approval expires, the interests of those already taking part, and the point at which a file may be closed: hhs.gov OHRP continuing review guidance
- OHRP, Guidance on Reviewing and Reporting Unanticipated Problems (2007) — the three-part definition and the worked examples, including loss of identifiable data: hhs.gov OHRP unanticipated problems guidance
- 45 CFR 46.109 — review of approved work at intervals matched to risk, and the amended position on when such review is not required: Cornell LII, section 46.109
- 45 CFR 46.113 — suspension or termination of approval, with reasons stated: Cornell LII, section 46.113
An approval you cannot date is an approval you cannot rely on.
Send the letter and a line about where the work stands. The free reading covers what is due, what should have been reported, and whether the project can be closed.
Request the free application review- approved versions and their dates
- every cleared change
- the review point, and the closure