REVIEWER CHECKLIST FOR RESEARCH INVOLVING CHILDREN Study Title: To be approved by the IRB, pediatric research must comply with all of the items in one of the following categories. Please indicate which category you believe the research falls under, and document if all requirements have been met by checking the appropriate Yes/No boxes. Note: the minutes/records must document protocol-specific information that justifies each determination. Please be prepared to present at the IRB meeting or list below so that the minutes/records may reflect that information. Research not involving greater than minimal risk. (45 CFR 46.404 & 21 CFR 50.51) Yes No The research is of no greater than minimal risk to the children. Adequate provisions are made for soliciting the assent of the children. (See additional checklist below.) Select one: The permission of both parents are required unless one parent is deceased, unknown, incompetent, or not reasonably available, or when only one parent has legal responsibility for the care and custody of the child. The permission of one parent is sufficient even if the other parent is alive, known, competent, reasonably available, and shares legal responsibility for the care and custody of the child. Comments: Research involving greater than minimal risk but presenting the prospect of direct benefit to the individual subjects. (45 CFR 46.405 & 21 CFR 50.52) Yes No The intervention or procedure holds out the prospect of direct benefit for the individual subject or the monitoring procedure is likely to contribute to the subject’s well-being. The risk is justified by the anticipated benefit to the subjects. The relation of the anticipated benefit to the risk is at least as favorable to the subjects as that presented by available alternative approaches. Adequate provisions are made for soliciting the assent of the children. (See additional checklist below.) Select one: The permission of both parents are required unless one parent is deceased, unknown, incompetent, or not reasonably available, or when only one parent has SC 501-B v. 4/29/08 legal responsibility for the care and custody of the child. The permission of one parent is sufficient even if the other parent is alive, known, competent, reasonably available, and shares legal responsibility for the care and custody of the child. Comments: Research involving greater than minimal and no prospect of direct benefit to the individual subjects (45 CFR 46.406 & 21 CFR 50.53) Yes No The risk represents a minor increase over minimal risk. The intervention or procedure presents experiences to subjects that are reasonably commensurate with those inherent in their actual or expected medical, dental, psychological, social, or educational situations. The intervention or procedure is likely to yield generalizable knowledge about the subject’s disorder or condition, which is of vital importance for the understanding or amelioration of the subjects’ disorder or condition. Adequate provisions are made for soliciting the assent of the children. (See additional checklist below.) Adequate provisions are made for soliciting the permission of both parents/guardians unless one is deceased, unknown, incompetent, or not reasonably available, or when only one parent has legal responsibility for the care and custody of the child. SC 501-B v. 4/29/08 If the research involves children who are wards (i.e. placed in the legal custody of the State or any other agency, institution, or other entity consistent with applicable federal, state or local laws)… The research is: Related to their status as wards. OR Conducted in schools, camps, hospitals, institutions, or similar settings in which the majority of the children involved as subjects are not wards. An advocate will be appointed for each child who is a ward, in addition to any other individual acting on behalf of the child as guardian or in loco parentis. (Please note: An individual may serve as an advocate for more than one child). 1. The advocate will be an individual who has the background and experience to act in, and agrees to act in, the best interests of the child for the duration of the child’s participation in the research. 2. The advocate will not be associated in any way (except in the role as advocate or member of the IRB) with the research, the investigator(s), or the guardian organization. Comments: Research not otherwise approvable which presents an opportunity to understand prevent, or alleviate a serious problem affecting the health or welfare of children. (45 CFR 46.407 & 21 CFR 50.54) Yes No Adequate provisions are made for soliciting the permission of both parents/guardians unless one is deceased, unknown, incompetent, or not reasonably available, or when only one parent has legal responsibility for the care and custody of the child. This research should be referred to the Secretary of DHHS and/or the Commissioner of FDA for appropriate action. SC 501-B v. 4/29/08 If the research involves children who are wards… The research is: Related to their status as wards. OR Conducted in schools, camps, hospitals, institutions, or similar settings in which the majority of the children involved as subjects are not wards. An advocate will be appointed for each child who is a ward, in addition to any other individual acting on behalf of the child as guardian or in loco parentis. 1. The advocate will be an individual who had the background and experience to act in, and agreed to act in, the best interests of the child for the duration of the child’s participation in the research. 2. The advocate will not be associated in any way (except in the role as advocate or member of the IRB) with the research, the investigator(s), or the guardian organization. Comments: Other Considerations – These questions should be answered about all pediatric studies under review. Yes No Have appropriate studies been conducted on animals and adults first? If NO, is the lack of appropriate studies conducted on animals and adults justified? Are there special problems that call for the presence of a monitor or advocate during the consenting process? Are there any special problems such as confidentiality and reporting that might arise in sensitive research about child abuse or sexual practices of teenagers? Should the child be re-consented when he/she reaches 18 years of age? Is the proposed payment/compensation to the parent/guardian and/or child appropriate? SC 501-B v. 4/29/08 Has the IRB determined that the research protocol is designed for conditions or for a subject population for which parental or guardian permission is not a reasonable requirement to protect the subjects (for example, neglected or abused children)? If yes, the IRB may waive the consent requirements, provided an appropriate mechanism for protecting the children who will participate as subjects in the research is substituted, and provided further that the waiver is not inconsistent with federal, state, or local law. The choice of an appropriate mechanism would depend upon the nature and purpose of the activities described in the protocol, the risk and anticipated benefit to the research subjects, and their age, maturity, status, and condition. The IRBs deliberation and determination must be documented in the meeting minutes. Comments: ASSENT checklist – These questions should be answered about all pediatric studies in which assent of the child is to be solicited. Assent is a requirement of: All children. Some children. Indicate which ones do not have to assent: _______________________ None of the children. If assent is not a requirement of some or all children, indicate why by checking one of the following boxes: The children are not capable of providing assent based upon their age, maturity, or psychological state. The capability of the children is so limited that they cannot reasonably be consulted. The intervention or procedure involved in the research holds out a prospect of direct benefit that is important to the health or wellbeing of the children, and is available only in the contact of the research. The assent can be waived using the criteria for waiver of the consent process. Does assent need to be documented? YES / NO If YES, describe the process to document assent. SC 501-B v. 4/29/08 WAIVER OF PARENTAL PERMISSION Yes No Yes No b) The waiver of parental permission will not adversely affect the rights and welfare of the subjects. Yes No c) It is not practicable to conduct the research without the waiver/alteration. Yes No d) Is the investigator’s response regarding the dissemination of additional pertinent information after the subject’s participation appropriate? Yes No e) The research is not FDA-regulated. Yes No Yes No Yes No Has a waiver of parental permission or a waiver of the permission procedure requirement to include all or alter some or all of the elements of informed consent [45 CFR 46.116(d)] been requested by the investigator? For each of the determinations, minutes or records have to document protocol-specific information that justifies each determination. If Yes, please respond to each of the following statements: a) Will the research in its entirety involve no more than minimal risk? YES must be answered to all of the conditions for the waiver of parental permission to be granted. If a waiver is granted under the above conditions, documentation of parental permission is also waived. The IRB may require the researcher to provide subjects (parents) with an information sheet (written summary) about the research. Do you feel that an information sheet should be provided to the subjects? Do you feel that a waiver of informed consent is appropriate? Primary Reviewer SC 501-B Date v. 4/29/08