View: 10-3. Informed Consent Waiver
Section: 10. Informed Consent
10-3. Informed Consent Waiver
10-3.1* This request is for:
Select all that apply:
Waiver – General - ALL of the project
10-3.1.1 If this request is for PART of the project, identify the specific research procedures
(e.g., screening interview) and/or the specific subject populations (e.g., parents of child-
subjects) involved.
10-3.1.2 Explain any requested alterations to the informed consent process.
10-3.2* Check below to affirm that this study meets each of the criteria for waiver or alteration
of informed consent and explain how:
(i) The research involves no more than minimal risk to the subjects.
Explain
Clinical / Physical / psychological / social / reputation / financial Risk
- Likelihood: None
- There will be no care interventions, no process changes, no documentation changes, and no
alterations to a patient's clinical experience. Providers will not experience any changes in their roles,
responsibilities, or care. A limited dataset will be extracted months AFTER the clinical care episode is
complete. The database servers employed are not production servers and no application
performance changes will be experienced
Privacy Risk
- Likelihood: None to Extremely Rare
- Theoretically, since patient data is being extracted, there exists a non-zero privacy risk. However,
since the data extraction process is automated and the data structures involved separate patient
identifiers from the data being extracted, the likelihood is EXTREMELY rare. Patient identifiers (DOB,
Name, MRN, Insurance account numbers, SSN) are NOT stored or transmitted at any point during
the data extraction or transmittal process.
- To further mitigate this risk, all data extraction processes are automated to eliminate the possibility
of human error. No research personnel are required to 'match' or review identifiers.
- All database work is performed on UMHS-MCIT approved and secured servers that are physically
located in the UMHS computing environment and maintained by MCIT security standards
- No patient identifiers will ever be stored or transported on portable computing devices (laptops, USB
drives, CD, DVD, etc) that can be lost or misplaced
(ii) Research could not practicably (i.e., feasibly) be carried out without the waiver or alteration.
Explain
There are two major reasons the research would not be feasible:
1) selection bias introduced by a consenting or opt-out process. Because of the low frequency nature
of the events being studied, the selection bias introduced by a signed informed consent or
informational sheet would make the research impossible to perform. For example, some of the events
we hope to study have an incidence of 0.16% and require the collection of data on 15,000 patients to
observe only 37 events. A single patient opting out would significantly impact the ability to gain new
knowledge in such clinical areas. More importantly, the patients most likely to opt out may be focus of
specific rare event research (eg, uncontrolled postoperative pain in chronic pain patients)
2) Secondly, it is not practicable to consent the hundreds of thousands of patients required to study
these conditions. Acquiring written consent, documentation of consent, or opt-out capability for
several hundred thousand patients would eliminate the ability to perform research on these low-
frequency events. Because it is unknown which patients will have an event prior to the event
occuring, all perioperative patients must be included in the dataset. The events and situations being
evaluated are often extremely low incidence (ie, < 1%), making prospective enrollment prohibitive.
The infrastructure necessary to manage even a simple informational sheet / addition to surgical
consent would be massive and manual. If the patient has the ability to opt-out (assumed if there is an
informational sheet / surgical consent change), then a manual process to record the medical record
number, date of service, etc would have to be created. Study personnel would have to deployed 24 x
7 in the operative suite (since all surgeries are being evaluated) and a manual process to record the
opt-outs would have to be funded. Furthermore, the manual recording of opt-outs would increase the
privacy risk of the patient.
(iii) If the research involves identifiable private information or biospecimens, the research could
not be practicably carried out without using such information or biospecimens in an identifiable
format.
Explain
The only identifiers in the MPOG repository are the date-of-service. No other PHI is included.
(iv) The waiver or alteration will not adversely affect the rights and welfare of the subjects.
Explain
The welfare of the patient is not be adversely affected whatsoever.
The rights of the patient will not be adversely affected because the risk of the right to privacy is
extremely low. In fact, creating an informed consent (written or informational sheet) process would