Some policies state that program evaluation falls within the domain of administrative research that does not require review by an ethics review board. We propose that some health promotion program evaluations include at least one element of research and can be distinguished from quality assurance. Although American and Canadian evaluation societies provide important guidelines and standards for evaluation practitioners, processes for accountability to the public are provided by research ethics boards. The field of health promotion is, by its nature, replete with challenges to existing research ethics boards. Given the dearth of published literature on the ethics of health promotion evaluation or practice, the field could benefit from the open debate that reviews of proposals would encourage.