Regulatory Open Forum

 View Only
  • 1.  Re-consenting subjects from previous cohorts

    This message was posted by a user wishing to remain anonymous
    Posted 06-Feb-2017 09:11
    This message was posted by a user wishing to remain anonymous

    Hello: If the ICF was revised to include higher dose and higher payment for cohort 2 (for example), do subjects in cohort 1 need to be re-consented? Cohort 1 was complete prior to revising the ICF. The reason for increasing the payment was due to difficulty in recruitment. The IRB does not provide specifics regarding this topic.
    Thanks a lot.


  • 2.  RE: Re-consenting subjects from previous cohorts

    Posted 07-Feb-2017 08:25
    Hi.  As a person who served as a member of an IRB for several years in a prior job, I would actually not generally expect you to re-consent all of cohort 1 unless you were going to involve them in the study in a manner that did not appear or apply to the original consent.  If your IRB has approved the increased payment and they have no requirements/instructions for your to complete before they finalize their approval, then your issue is a "cohort 2 only" issue in my mind.

    Obviously I am a single voice on this but this would be my interpretation.  So unless you are going to do something different with the samples from cohort 1 or you are going to require them to become part of the test set for additional data or sampling, I would say that you only need to worry about cohort 2 in your scenario.  I will be interested to see if any other colleagues have a different opinion on this point.

    ------------------------------
    Victor Mencarelli
    Director - Regulatory Affairs
    Hain Celestial Group
    United States
    ------------------------------