SOP: IRB Meeting Preparation



1. PURPOSE

1. This procedure establishes the process to document the informed consent process in writing.

2. The process begins when a subject agrees to take part in a research study.

3. The process ends when the consent process is documented in writing to the extent required by this standard operating procedure.

2. REVISIONS FROM PREVIOUS VERSION

1. Clarifications about policies and procedures regarding the informed consent process with non-English speaking subjects.

2. Added information regarding documentation of consent process in medical record.

3. POLICY

1. In this SOP “investigator” means a principal investigator or an individual authorized by the principal investigator to obtain consent for the specific protocol, such as a co-investigator, research assistant, or coordinator.

2. In this SOP “subject/representative” means:

1. The subject when the subject is an adult capable of providing consent.

2. Legally authorized representative when the subject is an adult unable to give consent.

3. One or both biologic or adoptive parents when the subject is a child or in the absence of a parent, a person authorized under applicable law to consent on behalf of the child to the child’s general medical care.

3. For a subject who is capable of providing consent, but incapable of providing a signature on the consent document, the following options would have the legal equivalence of a signature on a consent document in New York State:

1. The subject is incapable of writing, but is able to “make a mark” on the consent document, and the circumstances of the situation are recorded on the consent document. An impartial witness must be present for the entire consent discussion and marking of the consent, and the consent form and research record must document their presence for these actions.

2. The subject is incapable of writing or making a mark on the consent document, but can demonstrate understanding and consent to participation in some other fashion (e.g. verbal agreement, electronic, eye-blinking) in the presence of an impartial witness. The method used for communication and the specific means by which the prospective subject communicated agreement to participate must be recorded on the consent document and research record.

3. The subject is incapable of writing or making a mark on the consent document and designates an individual to sign the consent document on his/her behalf. The circumstances of the situation must be recorded on the consent document and research record. An impartial witness must be present for the entire consent discussion and signing of the consent, and the consent form and research record should document their presence for these actions.

4. The impartial witness may be a family member or friend. If a family member of friend of the potential subject is not available, the impartial witness may be a staff member who is not on the study team. The impartial witness may not be a person involved in the design, conduct, or reporting of the research study.

4. If the subject cannot speak English:

1. The IRB must have approved the enrollment of subjects unable to speak English.

2. If the IRB required translation of the consent document for non-English speaking subjects, the most recent IRB-approved version of the translated consent document must be used.

3. The subject/representative should be given a copy of the consent document written in a language understandable to them. In general, the language of the consent conversation should match the written consent document.

4. Ad hoc translation of the consent document may not be substituted for a written translation, when it is required by the IRB.

4. RESPONSIBILITIES

1. The principal investigator is responsible to ensure these procedures are carried out.

5. PROCEDURE

1. If the consent process will be documented in writing with the long form of consent documentation:

1. Verify that the consent document is in language understandable to the subject/representative.

2. Print the name of the following individuals on the consent document:

1. Subject/representative

2. Person obtaining consent

3. Have the subject/representative sign and personally date the consent document.

4. If assent will be documented in writing, note on the signature block one of the following:

1. Assent of the child was obtained.

2. Assent of the child was not obtained because the capability of the child is so limited that the child cannot reasonably be consulted.

5. Have the person obtaining consent personally sign and date the consent document.

6. If the subject/representative is capable of providing consent but has a physical disability that prevents him/her from personally signing and dating the consent document:

1. Ask the subject/representative to “make a mark” on the consent document if they are able.

2. If making a mark on the consent document is not possible, determine what method of communication of understanding and agreement is possible for the subject (e.g. verbal agreement, electronic, eye-blinking). Have the subject demonstrate their understanding and consent to participation in the designated fashion (e.g. verbal agreement, electronic, eye-blinking). Document on the consent document and research record the method used for communication and the specific means by which the prospective subject communicated agreement to participate.

3. If the above methods are not possible, the subject/representative may designate another individual to sign the consent document on his/her behalf. Document the circumstances on the consent document.

7. If there was an impartial witness was part of the consent process:

1. Print the name of the impartial witness on the consent document.

2. Have the impartial witness personally sign and date the consent document to attest that the information in the consent document and any other information provided was accurately explained to, and apparently understood by, the subject, and that consent was freely given.

8. Provide a copy of the signed and dated consent document to the subject/representative. This may be accomplished either by making a photocopy or by having the above individuals sign and date two copies of the consent document.

2. If the consent process will be documented in writing with the short form of consent documentation:

1. Verify that the short consent form is in language understandable to the subject/representative.

2. Print the name of the following individuals on the short form consent document and the summary:

1. Subject/representative

2. Person obtaining consent

3. Impartial witness

3. Have the following individuals personally sign and date the short form consent document and the summary:

1. Subject/representative

2. Person obtaining consent

3. Impartial witness

4. If the IRB required written documentation of assent, note on the signature block on the short consent document, one of the following:

1. Assent was obtained.

2. Assent was not obtained because the capability of the subject is so limited that he/she cannot reasonably be consulted.

3. If the requirement for written documentation of the consent process has been waived by the IRB and the IRB determined that subject/representative had to be offered the opportunity to document his or her consent is writing, offer the subject/representative the option to document his or her consent is writing.

1. If the subject declines, take no further action.

2. If the subject accepts, follow the process to document consent in writing with the long or short form of consent documentation

4. Place the signed and dated documents in the subject’s binder.

5. For clinical trials, the case history for each individual subject should document that informed consent was obtained prior to participation in the study.

6. For interventional studies, patient clinical care providers need to know that the patient is enrolled in a research study and what drugs/devices may be involved. Therefore, and in accordance with Joint Commission Standard PFR.9.6, the consent process must be documented in the patient’s medical record and a copy of the signed informed consent document must be made part of the medical record.

6. MATERIALS

1. If the consent process will be documented in writing with the long form of consent documentation:

1. Consent document

2. If the consent process will be documented in writing with the short form of consent documentation:

1. Short consent document

2. Summary (same as the English consent document used for long form of consent document)

3. Medical Record

7. REFERENCES

1. Hospital Policy on Informed Consent

2. 21 CFR 50.27

3. 45 CFR 46.117

4. 21 CFR 312.62 (b)

5. Joint Commission International Accreditation Standards for Hospitals Standard PFR.9.6

6. ICH GCP E6. Definition of Impartial Witness: A person, who is independent of the trial, who cannot be unfairly influenced by people involved with the trial, who attends the informed consent process, and who reads the informed consent form and any other written information supplied to the subject.

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