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Update to Informed Consent January 26, 2011

Posted by Michael Hamrell in Regulatory Thoughts.

The FDA has published a final regulation to amend the informed consent regulations effective in March 2011. This rule will require that a statement be added to all informed consent forms to inform subjects that information regarding the study is available in a public registry database at clinicaltrials.gov .  Although the rule goes into effect in March 2011, it has an implementation date of March 2012 for all trials that are initiated on or after that date.  In addition, for any trial that has been initiated prior to that date, it will not be necessary to revise the informed consent form or reconsent subjects to comply with this new regulation.  In other words, it will not be applied retroactively.  Instead it only applies prospectively to new trials initiated on or after the implementation date.  Once the regulation is effective, even if a consent form is modified for other reasons and subjects are reconsented, compliance with this regulation will not be required.

The regulation goes into some detail to describe what FDA means by an study that has already been initiated. Basically, if the study has been approved by any IRB or other such committee it is considered initiated.  This also applies to multicenter trials.  If the trial has been initiated at any site, the whole study is considered initiated.  FDA acknowledges that as a result there will be a gap for some time period before all studies have this language, but they do not consider this to be a problem since the requirement for clinical trial registration has actually been in place since 2007 and many investigators verbally inform subjects of such access already or subjects have themselves figured it out.


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