Guidance for Writing an Informed Consent Document version 2/26/2021
• The consent process should inform participants of the protections and limitations of the CoC. This
language is usually in included in the Confidentiality section of the consent form; see the example
CoC language on the IRB website under Forms and Templates.
• NOTE: All studies funded in whole or in part by the NIH are issued a CoC as part of the terms of
the award. Other studies may request a CoC from an HHS agency as an additional measure of
protection for participants.
• If part of the study cohort was recruited prior to issuance of the Certificate (i.e., prior to being
awarded an NIH grant), but are no longer actively participating in the study, NIH does not expect
participants consented prior to the change in authority, or prior to the issuance of a Certificate,
to be notified that the protections afforded by the Certificate have changed, or that participants
who were previously consented to be re-contacted to be informed of the Certificate, although
the IRBs may determine whether it is appropriate to inform participants.
Is your study a clinical trial? See the additional requirements below:
• A researcher may ask a participant who is withdrawing whether the participant wishes to provide
continued follow-up and further data collection subsequent to their withdrawal from the
interventional portion of the study. Under this circumstance, the discussion with the participant
distinguishes between study-related interventions and continued follow-up of associated clinical
outcome information, such as medical course or laboratory results obtained through non-invasive
chart review, and address the maintenance of privacy and confidentiality of the participant's
information.
• The researcher must obtain the participant’s consent for this limited participation in the study
(assuming such a situation was not described in the original consent document). The IRB must
approve the consent document.
• If a participant withdraws from the interventional portion of a study and does not consent to
continued follow-up of associated clinical outcome information, the researcher must not access
for purposes related to the study the participant's medical record or other confidential records
requiring the participant's consent. However, a researcher may review study data related to the
participant collected prior to the participant's withdrawal from the study, and may consult public
records, such as those establishing survival status.
• If the study meets the New Rule or FDA definition of a clinical trial, the consent form must include
the following statement verbatim: “A description of this clinical trial will be available on
http://www.ClinicalTrials.gov, as required by U.S. Law. This Web site will not include information
that can identify you. At most, the Web site will include a summary of the results. You can search
this Web site at any time.”
After writing your consent form:
• Read it out loud to yourself.
• Let someone else read, preferably someone in your target audience demographic, to see if they
understand it. (However, this should not be someone you are actually planning to consent.)
Links to help with readability and lay language:
• Readability Toolkit—this is a great overall tool for writing consent forms with or without medical
terms:
https://irb.research.chop.edu/sites/default/files/documents/prism_readability_toolkit.pdf