My understanding is that for the eleven published projects involved in this enquiry, Crawley produced a single earlier letter from her ethics committee saying that ethical approval was not required for a specific but unconnected service evaluation involving the blinded analysis of anonymised forms [relating, if recall correctly, an evaluation of a service for adults].
This suggests that the question of whether ethical approval was or was not required was circumvented in all these studies by the production of this single unconnected letter. The lead researchers created the misleading impression that the exemption of these studies had each been formally agreed, which was not the case. This means there were worrying problems with the approval process, regardless of whether or not they could be regarded as service evaluation and therefor exempt from ethical approval.
The most controversial of the eleven studies is the School Absence study, and it was only because of the wider concerns about this study that this abuse of process became apparent. For reasons discussed in various forums, including here, there are many arguments for this study being research, indeed it was published by the journal as such, but even if these arguments turned out to be incorrect some the ethical consideration of a pilot service screening all school non attenders for ME/CFS regardless whether or not there were any health concerns surely requires some specific consideration. It was never acceptable for it to avoid any ethical scrutiny, not even discussion of whether it was service evaluation or research, on the basis a letter written several years before relating to a completely different project.