Informed Consent: A Monthly Review
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September 2023 :: Issue 57

This digest aggregates and distills key content addressing informed consent from a broad spectrum of peer-reviewed journals and grey literature, and from various practice domains and organization types including international agencies, INGOs, governments, academic and research institutions, consortiums and collaborations, foundations, and commercial organizations. We acknowledge that this scope yields an indicative and not an exhaustive digest product.

Informed Consent: A Monthly Review is a service of the Center for Informed Consent Integrity, a program of the GE2P2 Global Foundation. The Foundation is solely responsible for its content. Comments and suggestions should be directed to:

Editor
Paige Fitzsimmons, MA
Associate Director, Center for Informed Consent Integrity
GE2P2 Global Foundation
paige.fitzsimmons@ge2p2global.org

PDF Version: Center for Informed Consent Integrity – A Monthly Review_September 2023

Upcoming Calls For Public Consultation

We will selectively include calls for public consultation from multilateral agencies, governments, INGOs and other sources where there is a clear intersection with consent/assent. This might be obvious from the title of the draft guidance, regulations, etc., but more often, it will be a thematic area or topic – if properly addressed at all. If you would like to explore participation with our working group developing submissions for these calls, please contact us [david.r.curry@ge2p2global.org].

Public Consultation: ICH E6(R3) [GCP] Principles, Annex 1 and Annex 2
ICH – The E6(R3) EWG is working on the revision of the E6(R2) Guideline “Good Clinical Practice” (GCP) with a view to addressing the application of GCP principles to the increasingly diverse trial types and data sources being employed to support regulatory and healthcare related decision-making on drugs, and provide flexibility whenever appropriate to facilitate the use of technological innovations in clinical trials.
   Public consultation dates:
ANVISA, Brazil – Deadline for comments by 31 August 2023
EC, Europe – Deadline for comments by 26 September 2023
FDA, United States – Deadline for comments by 5 September 2023
HSA, Singapore – Deadline for comments by 30 September 2023
Health Canada, Canada – Deadline for comments by 20 October 2023
MHLW/PMDA, Japan – Deadline for comments by 9 September 2023
MHRA, UK – Deadline for comments by 31 August 2023
NMPA, China – Deadline for comments by 31 August 2023
Swissmedic, Switzerland – Deadline for comments by 26 September 2023
TFDA, Chinese Taipei – Deadline for comments by 31 August 2023 

Public consultation on WHO guidance for best practices for clinical trials
WHO -19 July 2023
Call for consultation: Deadline 15 Sep 2023

WHO launches a global stakeholder survey on solutions for strengthening clinical trial infrastructure and capacity
This global stakeholder survey will be open until 10th September 2023.
   The outcomes of the public consultation and the global survey will guide the WHO in a series of upcoming regional and global consultations with Member States and non-State-actors towards the implementation of the WHA resolution 75.8 on clinical trials.

Symposia/Conferences

We will selectively include information on major symposia and conferences which address issues, evidence, analysis or debates involving consent/assent. This listing will include [1] meetings already concluded but which are posting presentations/recordings, etc.; [2] future meeting which have  posted registration/logistics information, and [3] meetings which have announced calls for abstracts/panels, etc.

17th World Congress of Bioethics
3-6 June 2024
Doha, Qatar
  The WCB 2024 theme is “Religion, Culture, and Global Bioethics”. This theme aims to engage bioethics researchers from a broad range of fields and disciplines and to take full advantage of hosting the WCB in the Arab-Muslim world and the Middle East
Call for Abstracts now open, deadline September 30, 2023.
Editor’s Note: We are certainly aware of the continuing, active debate in the bioethics community and beyond about the site selection for this meeting. The Foundation is reviewing its options regarding participation, submitting abstracts, etc.  

8th World Conference on Research Integrity (Hybrid)
2-5 June 2024
Megaron Athens International Conference Centre (MAICC)
Athens, Greece
The biannual WCRIs cater to all disciplinary fields, all professional ranks, and all career stages, and involve all stakeholders in research integrity, including universities, research institutes, research funders, publishers, and governments. Each WCRI emphasises a specific theme, but all cater for the whole range of research integrity issues and responsible research practices. The 8th WCRI will put thematic emphasis on: Catalysing the translation of research into trustworthy policy and innovation.
Call for Abstracts now open, deadline October 17, 2023.

Spotlight Articles

In this issue’s Spotlight section we include two recent articles analyzing the structure and components of ICFs [informed consent forms].

In Characterization of Key Information Sections in Informed Consent Forms Posted on ClinicalTrials.gov published in the Journal of Clinical Translational Science the authors assess the presence, length, readability and other parameters of KIs [key information sections] in ICFs posted on ClinicalTrials.gov in alignment with the revised Common Rule. The authors argue that “…widely adopted guidelines could also facilitate compliance analyses that are currently challenged by the broad subjectivity in interpreting the KI requirement [in the revised Common Rule].”

In the Perspectives in Clinical Research article Redefining informed consent form in cell and gene therapy trials, Dalal et at. address the need to adapt the informed consent process and ICFs to the unique context of gene therapy trials [see Fig 3 below] as well as the  cultural contexts in which the trials are implemented.

 

Characterization of Key Information Sections in Informed Consent Forms Posted on ClinicalTrials.gov
Luke Gelinas, Walker Morrell, Tony Tse, Ava Glazier, Deborah A. Zarin, Barbara E. Bierer
Journal of Clinical and Translational Science, 14 August 2023
Abstract
Introduction
Recent revisions to the United States Federal Common Rule governing human studies funded or conducted by the federal government require the provision of a “concise and focused” key information (KI) section in informed consent forms (ICFs). We performed a systematic study to characterize KI sections of ICFs for federally-funded trials available on ClinicalTrials.gov.
Methods
We downloaded ICFs posted on ClinicalTrials.gov for treatment trials initiated on or after the revised Common Rule effective date. Trial records (n=102) were assessed by intervention type, study phase, recruitment status, and enrollment size. The ICFs and their KI sections, if present, were characterized by page length, word count, readability, topic, and formatting elements.
Results
Of the 102 trial records, 76 had identifiable KI sections that were, on average, 10% of the total length of full ICF documents. KI readability grade level was not notably different than other sections of ICFs. Most KI sections were distinguished by section headers and included lists but contained few other formatting elements. Most KI sections included a subset of topics consistent with the basic elements of informed consent specified in the Common Rule.
Conclusion
Many of the KI sections in the study sample aligned with practices suggested in the preamble to the revised Common Rule. Further, our results suggest that some KI sections were tailored in study-specific ways. Nevertheless, guidelines on how to write concise and comprehensible KI sections would improve the utility and readability of KI sections.

Redefining informed consent form in cell and gene therapy trials
Review Article
Varsha Dalal, Geeta Jotwani, Munna Lal Yadav
Perspectives in Clinical Research, 28 July 2023
Abstract
Informed consent is a foundation of the ethical conduct of research involving human participants. Based on the ethical principle of respect for persons, the goal of informed consent is to ensure that participants are aware of the risks and potential benefits and make a voluntary decision about participating in clinical trial research. The extraordinary scientific advances happening globally have demonstrated the potential of regenerative therapies in transforming the health of the nation by providing a therapeutic option for diseases that were previously considered incurable. These therapies, which include cells and gene therapy (GT) labeled as Advanced Therapeutic Medicinal Products globally, have complex mechanisms of action. Owing to their highly personalized and intricate nature of these therapies, developing the latter often presents unique challenges above and beyond those encountered for small molecule drugs. We recently looked through some cell and GT clinical trials and realized the lacunae in the informed consent form (ICF) provided by the investigators. Especially in a country like India, where the general understanding and perception of patients is limited regarding clinical trials, it is felt that any lapses in the consent process may jeopardize the informed decision‑making and safety of the participants and tarnish the reputation of India globally. The present article highlights the need for appropriate patient and public education on the various aspects of cell and gene therapies and aims to address all the elements of ICF in light of the challenges associated with these innovative therapies.

 

Consent document translation expense hinders inclusive clinical trial enrolment

Consent document translation expense hinders inclusive clinical trial enrolment
Maria A. Velez, Beth A. Glenn, Maria Garcia-Jimenez, Amy L. Cummings, Aaron Lisberg, Andrea Nañez, Yazeed Radwan, Jackson P. Lind-Lebuffe, Paige M. Brodrick, Debory Y. Li, Maria J. Fernandez-Turizo, Arjan Gower, Maggie Lindenbaum, Manavi Hegde, Jenny Brook, Tristan Grogan, David Elashoff, Michael A. Teitell, Edward B. Garon
Nature, 2 August 2023
Abstract
Patients from historically under-represented racial and ethnic groups are enrolled in cancer clinical trials at disproportionately low rates in the USA. As these patients often have limited English proficiency, we hypothesized that one barrier to their inclusion is the cost to investigators of translating consent documents. To test this hypothesis, we evaluated more than 12,000 consent events at a large cancer centre and assessed whether patients requiring translated consent documents would sign consent documents less frequently in studies lacking industry sponsorship (for which the principal investigator pays the translation costs) than for industry-sponsored studies (for which the translation costs are covered by the sponsor). Here we show that the proportion of consent events for patients with limited English proficiency in studies not sponsored by industry was approximately half of that seen in industry-sponsored studies. We also show that among those signing consent documents, the proportion of consent documents translated into the patient’s primary language in studies without industry sponsorship was approximately half of that seen in industry-sponsored studies. The results suggest that the cost of consent document translation in trials not sponsored by industry could be a potentially modifiable barrier to the inclusion of patients with limited English proficiency.

Advance Consent In Acute Stroke Trials: Survey Of Canadian Research Ethics Board Chairs

Advance Consent In Acute Stroke Trials: Survey Of Canadian Research Ethics Board Chairs
Manuscript
Rena Seeger, Ubong Udoh, Brian Dewar, Stuart Nicholls, Mark Fedyk, Robert Fahed, Jeff Perry, Michael D Hill, Bijoy Menon, Richard H Swartz, Alexandre Y Poppe, Sophia Gocan, Jamie Brehaut, Katie Dainty, Victoria Shepherd, Dar Dowlatshahi, Michel Shamy
24 July 2023 [Cambridge University Press]
Abstract
Advance consent could allow individuals at high risk of stroke to provide consent before they might become eligible for enrollment in acute stroke trials. This survey explores the acceptability of this novel technique to Canadian Research Ethics Board (REB) chairs that review acute stroke trials. Responses from 15 REB chairs showed that majority of respondents expressed comfort approving studies that adopt advance consent. There was no clear preference for advance consent over deferral of consent, although respondents expressed significant concern with broad rather than trial-specific advance consent. These findings shed light on the acceptability of advance consent to Canadian ethics regulators.

Continuous quality improvement: reducing informed consent form signing errors

Continuous quality improvement: reducing informed consent form signing errors
Research
Tsui-Wen Hsu, Chi-Hung Huang, Li-Ju Chuang, Hui-Chen Lee, Chih-Shung Wong
BMC Medical Ethics, 4 August 2023; 24(59)
Open Access
Abstract
Background
Adherence to ethical guidelines and regulations and protecting and respecting the dignity and autonomy of participants by obtaining a valid informed consent form (ICF) prior to participation in research are crucial; The subjects did not add signatures next to the corrections made to signatures or dates on the ICF, Multiple signatures in other fields, ICF missing/missing signature, Incorrect ICF version Signed after modification, Correction tape used to correct signature, Impersonated signature, Non-research-member signature, however, ICFs are often not properly completed, which must be addressed. This study analyzed ICF signing errors and implemented measures to reduce or prevent these errors.
Methods
We used the plan–do–check–act (PDCA) cycle to help improve the correctness and validity of ICF signing.
Results
Interim and final reports from January 2016 to February 2020 including 363 ICFs were studied. The total proportion of correct ICF signatures (200, 83.3%) following the PDCA intervention was significantly higher than that before the intervention (P < 0.05). Analysis of the types of signing error demonstrated that signature errors were significantly reduced after the intervention, particularly for subjects did not add signatures next to the corrections made to signatures or dates on the ICF (16, 6.7%) and impersonated signature (0; P < 0.05).
Conclusions
The proportions of other error types—multiple signatures in other fields, missing or unsigned ICF, incorrect signature order, incorrect ICF version, use of correction tape to correct signature, and non-medical profession members signing the ICF—did not differ significantly.

Physician-Investigator, Research Coordinator, and Patient Perspectives on Dual-Role Consent in Oncology A Qualitative Study

Physician-Investigator, Research Coordinator, and Patient Perspectives on Dual-Role Consent in Oncology A Qualitative Study
Stephanie R. Morain, Dorit Barlevy, Steven Joffe, Emily A. Largent
JAMA Network Open, 25 July 2023; 6(7)
Abstract
Importance
Classic statements of research ethics generally advise against dual-role consent in which physician-investigators seek consent for research participation from patients with whom they have preexisting treatment relationships. Yet dual-role consent is common in clinical oncology research, as studies are often conducted in close relationship with clinical care.
Objective
To explore key stakeholders’ perspectives on dual-role consent in clinical oncology trials.
Design, Setting, and Participants
This qualitative study with 43 participants was conducted at a National Cancer Institute–designated comprehensive cancer center from 2018 to 2022. Semistructured qualitative interviews of physician-investigators, research coordinators, and patients were performed. Respondents were recruited from 3 populations: (1) physician-investigators engaged in clinical oncology research; (2) research coordinators engaged in clinical oncology research; and (3) patients, with and without prior clinical trial experience, who had received a new cancer diagnosis at least 2 months prior to enrollment in this study.
Main Outcomes and Measures
Interviews were audio recorded and professionally transcribed. A thematic analysis approach was used to develop a codebook that included both theory-driven, a priori codes and emergent, inductive codes. Two authors double-coded all transcripts and met regularly to compare coding, discuss discrepancies, refine the codebook, and draft memos describing relevant themes and their frequency.
Results
Among the 43 respondents, 28 (65.1%) were female; 9 (20.9%) were African American, 8 (18.6%) were Asian, 6 (14.0%) were Hispanic, and 21 (48.8%) were White; 15 were physician-investigators (6 [40.0%] with 6-10 years of experience, 4 [26.7%] with at least 20 years of experience), 13 were research coordinators (5 [38.5%] with 0-5 years of experience, 5 [38.5%] with 6-10 years of experience), and 15 were patients (9 [60.0%] aged 46-64 years). Four main themes were found: interviewees (1) perceived greater potential for role synergy than for role conflict; (2) reported dual-role consent as having mixed effects on the consent process, increasing prospective participants’ understanding and likelihood of agreement while also challenging voluntariness; (3) preferred a team-based approach to the consent process in which physician-investigators and research coordinators share responsibility for communicating with prospective participants and safeguarding voluntariness; and (4) offered strategies for managing tensions in dual-role consent.
Conclusions and Relevance
This qualitative study found that concerns about dual-role consent in clinical oncology, while valid, may be outweighed by corresponding advantages, particularly if appropriate mitigation strategies are in place. These findings support a team-based approach to informed consent, in which physician-investigators and research coordinators promote both the understanding and voluntariness of prospective participants.

Dynamic consent, communication and return of results in large-scale health data reuse: Survey of public preferences

Dynamic consent, communication and return of results in large-scale health data reuse: Survey of public preferences
Sam Ha Muller, Ghislaine Jmw van Thiel, Menno Mostert, Johannes Jm van Delden
Digit Health, 16 August 2023
Open Access
Abstract
Dynamic consent forms a comprehensive, tailored approach for interacting with research participants. We conducted a survey study to inquire how research participants evaluate the elements of consent, information provision, communication and return of results within dynamic consent in a hypothetical health data reuse scenario. We distributed a digital questionnaire among a purposive sample of patient panel members. Data were analysed using descriptive and nonparametric inferential statistics. Respondents favoured the potential to manage changing consent preferences over time. There was much agreement between people favouring closer and more specific control over data reuse approval and those in favour of broader approval, facilitated by an opt-out system or an independent data reuse committee. People want to receive more information about reuse, outcomes and return of results. Respondents supported an interactive model of research participation, welcoming regular, diverse and interactive forms of communication, like a digital communication platform. Approval for reuse and providing meaningful information, including meaningful return of results, are intricately related to facilitating better communication. Respondents favoured return of actionable research results. These findings emphasize the potential of dynamic consent for enabling participants to maintain control over how their data are being used for which purposes by whom. Allowing different options to shape a dynamic consent interface in health data reuse in a personalized manner is pivotal to accommodate plurality in a flexible though robust manner. Interaction via dynamic consent enables participants to tailor the elements of participation they deem relevant to their own preferences, engaging diverse perspectives, interests and preferences.

Treatment without consent in adult psychiatry inpatient units: a retrospective study on predictive factors

Treatment without consent in adult psychiatry inpatient units: a retrospective study on predictive factors
Giulia Meroni, Othman Sentissi, Stefan Kaiser, Alexandre Wullschleger
Frontiers of Psychiatry, 10 August 2023
Abstract
Background
Coercion is one of the most important challenges in mental health. In Switzerland, forced medication can be applied during an emergency (Art. 435 of the Civil Code) or over a longer period in case of endangerment of others or oneself (Art. 434). We aimed to analyze the predictors of this specific treatment without consent.
Methods
Forced medication prescriptions in the Division of Adult Psychiatry of the Geneva University Hospitals between 2018 and 2021 were retrospectively analyzed. Medication under Article 434 was the main outcome variable. Age, gender, admission mode, main diagnosis, and the Health of the Nation Outcome Scales (HoNOS) score at admission were considered as potential predictors. T-test and Pearson’s chi-square test were used to compare continuous and categorical variables. A logistic regression was performed to find significant predictors of forced medication.
Results
Seventy-one out of 4,326 inpatients were subjected to forced medication under Art. 434. HoNOS global scores at admission were not significantly different in the forced medication group compared to the control group. Aggressive behavior was lower in the former at the univariate level. Forced medication was associated at the multivariate level with female gender, involuntary admission, and psychosis.
Conclusion
Women suffering from psychosis are more at risk of receiving involuntary and repeated medication. The risk of deterioration in psychosocial functioning or behavioral disorganization seems to be the main argument for this coercive measure. Future studies should focus on the patient’s perception of this coercion to prevent it and improve adherence to care. Follow-up after discharge might be useful to evaluate a long-term benefit.