IRB-02:

Behavioral/NonMedical  Institutional Review Board
Research & Graduate
Programs University of Florida

IRB-02 Institutional Review Board

Submitting Protocols with Special Populations/Concerns

Special Population: Children

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Consent / assent issues

  • Parental/guardian consent
    • The informed consent must clearly explain what is required of child as well as what is asked of the parent. The document should also clearly state if there is to be future contact with the family or if there will be any observations or interactions with the child while the parent is not present.
  • Child Assent
    • Since children cannot give legal consent to participate in research, we speak of parents giving consent, but their children give their assent, where appropriate. Children can only be approached for assent after parental consent has been given. The assent is usually a scripted interaction, though with older minors it can be a document. The assent must be in age-appropriate language, explaining that their parents have consented to have them participate, but they do not have to participate if they don't want to. If appropriate, the assent should state that the research study is not school and will not affect grades or teacher interaction. The assent should state if they will miss any activities from the regular school day, and how that will be made up. The script should also clearly state what the child is being asked to do, where,  for how long, and with whom, and the nature of any compensation; explain that they can stop participating at any time and still receive part of that compensation for their time; and the extent that their responses will be confidential.
  • Group assent
    • The IRB discourages group assenting procedures (asking children in a classroom setting to raise their hand if they do/do not wish to participate). This creates social pressure that may sway judgment.  If at possible, it is preferable to ask children in a one-on-one setting or devise a system of passing out papers and having the child decide and covertly mark the paper individually.
  • Opt-Out Consents
    • The IRB does not approve “opt out” “consent” procedures. IRB does not recognize “passive consent” as such; you’re requesting a waiver of (parental) consent. 
  • Waiver or Parental Consent
    • The IRB can waive parental consent under current regulations ( under 45CFR, both 46.408(b) / 46.116(d)), if the study is minimal risk, not practicable without the waiver, and waiver won’t affect the participants' risk or rights, and if appropriate efforts are made to inform the parents about the work. Arguments that these conditions are met should be included in the protocol submission. The IRB tends to be very conservative in approving this unless the survey is benign and anonymous. If this consent method is sought, the researchers much also submit a letter from the school indicating their approval for the procedure in the absence of parental consent.

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Asking children to evaluate their peers or family

  • Some studies are interested in peer social interactions, resulting in a need to have identified children evaluate other identified children, for example to correlate what one says about oneself to others’ views of them. This creates some difficulty, however, because the the named classmates are participants in the research, as the regulations [45 CFR 46.102(f)(2)] define human subject as a person “about whom an investigator obtains identifiable private information.”  The consequence is that researchers will need to get parental consent and child assent both for children who are evaluating others and those classmates who are being evaluated. 
    • If the evaluation of others is intended only to inform you about the views of the respondents, then there may be no need to obtain/maintain identifiers for the classmates. If that’s the case, the procedures to keep any information about those who are being evaluated anonymous should be made clear in the protocol and consent forms. 
  • See Special Populations: Students for more information about classroom studies.
  • When researchers wish to ask children about their family environment or the behaviors that they witness from their family members,  the family members are similarly participants in the study. In such cases, there may be significant risks to the family members if information about financial status, emotional well-being, illegal behaviors or other sensitive topics were disclosed. Their consent must be sought, or the researcher needs to explain why their consent should be waived. 

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Asking parents / guardians / teachers to report on the behavior of children

  • As when children are asked to report on the behavior of peers and parents (see above), assent may be needed from the true subjects of the study, in this case, the children, when parents are being asked  to report about their child's behavior.  This requirement is particularly important when the child can be identified, and the topics are sensitive ones.  The IRB will consider the particular circumstances to determine if assent is needed in all such third-party interviews.

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Mandatory reporting of abuse

  • If the researcher or their staff obtains credible evidence that a child being evaluated for research purposes shows signs of abuse, it is mandated by state law that the researcher must report that information to the Florida Abuse Hotline. Research that, because of the topics explored (for example, parental discipline) or because of the population to be studied (for example, children with mood disorders or other at-risk groups), is more likely to uncover evidience of abuse, the consent and/or assent scripts should state explicitly that any evidence of abuse must be reported to a state hotline. 
  • This is the web page detailing the use of the abuse hotline, 1-800-96-ABUSE. http://www.dcf.state.fl.us/abuse/

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Asking children for information about behavior unknown to parents / illegal behavior

  • Some studies ask children about behavior unknown to the parents; this often concerns sensitive areas such as drug use, sexual practices, or criminal behaviors. It is not necessary that this information be shared with the parents, and often it is critical that it be withheld from parents. However, researchers must let parents and children know in the informed consent that they will ask about certain behaviors, and that the parents will not be able to find out their children’s answers.
  • If this information could be brought into a court of law or otherwise disclosed, the data should have potential identifiers as soon as possible, either when collected, or when coded, so that it cannot be connected to participants. (These include direct identifiers like social security numbers, drivers license numbers, etc., as well as indirect information that could uniquely identify a person, such as a combination of demographic and descriptive information). A Certificate of Confidentiality may provide further protection from such disclosure. For more information, see Special Situations: Illegal Behavior

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Children who are not under their parents’ care (wards of the state, foster children, etc)

  • Consent and assent must still be obtained when studying children who are not under their parents' care. 
    • It is the researchers’ responsibility to determine who is legally responsible for the participant (who could consent to have medical treatment done to the children?). 
    • Information about who is legal guardian for the group of interest, and the source for this information, should be included in the protocol.
  • It is important to note that children may have been removed from the care of their parents for a  reason that makes them particularly vulnerable, such as abuse/neglect. How this vulnerable population will be protected must also be addressed in the protocol. 

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Children with compromised mental/communicative capacities

See the section on Special Populations: Mentally Challenged / Communicative Challenged Participants

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Sample assent scripts

[Older children]

Hello [child’s name].  My name is [examiner’s name] and I am a student at the University of Florida. I am trying to learn about how students think, learn, and behave in school. I will be working with several students at [name of school or after-school program]. If you decide to participate, you will be asked to do a series of activities, including some reading, writing, and math activities, and answering some questions about your feelings and emotions.  We will spend about an hour and a half working in a group with other students and we will spend another hour and a half working on tasks individually. There are no known risks to participation, and most students actually enjoy the tests. You do not have to be in this study if you don’t want to and you can quit the study at any time. Other than the researchers, no one will know your answers, including your teachers or your classmates. If you don’t like a question, you don’t have to answer it and, if you ask, your answers will not be used in the study.  I also want you to know that whatever you decide, this will not affect your grades in class. Your [parent / guardian] said it would be OK for you to participate. Would you be willing to participate in this study?

[Younger children]

Hi, my name is [examiner's name], and I'm from the University. I'd like to tell you a few little stories and ask you some questions about them. Your [teacher / mom] said it was OK. We'll do it in the conference room, and it takes about 15 minutes. Would you like to come do this?


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Updated:  07/02/2007