An investigator received an updated informed consent form (ICF) from the sponsor for a study closed to enrollment. Subjects are only in long-term follow-up. The change related to frequent radiation imaging at screening, with no change to drug safety profile. Who must the investigator notify first?
Suggested Answer: C
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21 CFR 56.109(a): IRBs must review all changes to informed consent before implementation.
ICH E6(R2) 4.8.2: If new information could affect willingness to continue, consent forms must be revised and approved by the IRB.
Even though screening is closed, the IRB/IEC must review the updated form before any subject re-consenting.
12 comments · newest first
AL
Albina
3 months ago
True, but since it's closed to enrollment, the IRB/IEC is the priority. They oversee the study's compliance.
LA
Lachelle
3 months ago
I agree, but what about the participants? They should know about the radiation imaging.
DO
Doyle
3 months ago
I think the investigator should notify the IRB/IEC first. They need to approve any changes.
HO
Hollis
3 months ago
I thought participants should be notified too, though.
CA
Carmelina
3 months ago
Seems like a no-brainer to inform the IRB first.
CH
Cheryll
4 months ago
Wait, why would they need to notify anyone if the study's closed?
CA
Casey
5 months ago
Totally agree, it's all about compliance!
LO
Lorean
5 months ago
Gotta notify the IRB/IEC first, right?
JA
Jackie
6 months ago
I’m a bit confused. If the study is closed to enrollment, does that change who needs to be notified? I thought it was just the IRB.
ED
Edmond
6 months ago
This seems similar to a practice question we did about protocol amendments. I feel like the IRB is usually the first point of contact.
KA
Kandis
6 months ago
I'm not entirely sure, but I remember something about keeping participants informed. Wouldn't they need to be notified too?
TR
Truman
6 months ago
I think the investigator should notify the IRB/IEC first since they oversee the ethical aspects of the study.