Creating Effective
   Pediatric Assent Forms:
Overcoming Common Obstacles

   Elizabeth Jay, RN, MA, CCRA
         Clinical Manager II
      Premier Research Group
            03 May 2011
Disclosure



  I have no relevant financial relationship in
       relation to this educational activity
Objectives
• Identify common obstacles to solicitation
  of effective assent

• Apply basic tools to construct effective and
  appropriate pediatric assent forms

• Attain methods to solicit meaningful,
  age-appropriate pediatric assent
Historical Perspective on Assent
                                                        2000
                                          Children’s Health Act
                          1978
        DHW proposed regulations
   to implement recommendations
           of National Commission



                                                         1998
                                                         NIH Policy
                                                         and Guidelines
                             1977
                             American Academy of Pediatrics
                             published its first “Guidelines for the
                             Ethical Conduct of Studies to Evaluate
                             Drugs in Pediatric Populations”
               1974
               National Research Act
               created National Commission
Obstacles to Effective Assent
1) Perception of assent as an afterthought
2) Inadequate direction from sponsors and/or IRBs
3) Failure to address differences in developmental
   ages and reading grade levels
4) Difficulty of creating readable forms that
   adequately explain elements of assent
5) Not planning ahead: logistics of assenting process
Obstacle # 1
Perception of assent as an afterthought
Why is Meaningful Pediatric Assent Important?

• Encourages shared decision-making, active
  participation of research subject

• Supports ethical standard of respect for all
  persons

• Alleviates feelings of powerlessness
Unguru et al, Pediatrics 2010
• Studied what children aged 7 to 18 with
  cancer understood about their research-
  related treatment and their preferences for
  inclusion in decision-making
• 100% wanted to be involved in decision-
  making, but 49% did not have or recall having
  a role in decision to enroll and 38% did not
  feel free to dissent to enrollment
Obstacle # 2
Inadequate direction from sponsors
and/or IRBs regarding assent
Such as….
• Not specifying number of forms to be used or
  not requiring separate assent form at all

• Not providing training for pediatric
  researchers and staff

• Not giving guidance about the minimum age
  to give assent
IRB Responsibilities in Pediatric Research

     Review and approve research protocols involving
     minors


     Ensure adequate provisions are made for soliciting the
     permission of each child's parents or guardian


     Determine whether children in study are capable of
     providing assent and if so, confirm that adequate
     provisions are made for soliciting their assent
Minimum Age of Assent
1979: Belmont Report (report by National
Commission)
• Recommended age 7 for age of assent

1977, 1995, 2010: AAP Committee on Bioethics
and AAP Committee on Drugs
• Recommends age 7 as minimum age of assent
  for medical decision-making including research
Real Life Experience: Cohort Group
8 pediatric studies conducted under IND applications at 96
sites between 2004 and 2009
Study   Indication                         Clinical Setting                  Age Range
  1     Bipolar Disorder Type 1            Outpatient                        7-17 years
  2     Spasticity due to Cerebral Palsy   Outpatient                        2-16 years
  3     Sedation                           Inpatient (Intensive Care Unit)   3 months – 18 years
  4     Status Epilepticus                 Inpatient (Emergency Room)        3 months – 18 years
  5     Status Epilepticus                 Inpatient (Emergency Room)        3 months – 18 years
  6     Blood Pressure Control             Inpatient (Operating Room)        0-17 years
  7     Blood Pressure Control             Inpatient (Intensive Care Unit)   0-17 years
        Suspected or Complicated
  8                                        Inpatient (Intensive Care Unit)   Neonates (0-91 days)
        Intra-abdominal Infections
Cohort Group and Assent
• Pediatric assent waived at 37 sites and
  within two of the 8 studies due to condition
  under treatment
• Remaining 59 sites solicited pediatric
  assent as they/their IRB deemed
  appropriate
Cohort Group and Assent
40 of 59 sites required and approved one or
more separate assent forms (total of 55 forms)
Cohort Group and Assent
19 of 59 sites had no separate assent form
(child or adolescent signed parental permission)
• Minimum age to sign ICF not stated at 9 sites
• Other 10 sites listed minimum age to sign ICF
  anywhere from 7 to 15 years old
• Likelihood of child as young as 7 comprehending
  parental consent form?
Obstacle # 3
Failure to address differences in
developmental ages and reading grade
levels
At what grade level does the average
adult read and comprehend information?

a) 12th grade or higher
b) 10th – 11th grade
c) 8th – 9th grade
d) 6th – 7th grade
e) 4th – 5th grade
Creating Forms
One size doesn’t fit all!
• Determine whether your IRB has specified minimum age
  to give assent
• Consider ages of children involved and how many forms
  will be needed
• Write and rewrite as needed until each form is written at
  the reading grade level of the youngest person who will
  sign but still contains all relevant information
Forms Should be Easy to Comprehend

  The information that is given to the subject or the
  representative shall be in language understandable
  to the subject or the representative.     (45 CFR 46.116)


Readability is defined as the quality of written language
that makes it easy to read and understand
• Equates to grade reading level
• Readability Statistics give you information about grade
  level and ease of reading
Readability Statistics
Flesch Reading Ease and Flesch-Kincaid Grade Level
• Common method to check readability statistics
• Spelling & Grammar function of Microsoft Office Word
• Reading Ease gives index from 0 (hardest) to 100 (easiest)
• Grade Level assesses reading grade level*




*Older versions of Word don’t assess levels higher than 12th grade
Using Word 97-2003 for Checking Readability Stats
1) Under the Tools menu,
   chose Options which will open a
   pop-up menu.

2) On the Spelling & Grammar tab,
   check the Show Readability
   Statistics box and click OK

3) On the Standard toolbar,
   click on Spelling & Grammar icon
   to run the readability statistics for
   your form
Using Word 2007 for Checking Readability Stats
1) Click on the Microsoft
   Button and then Word
   Options which will open
   a pop-up menu.

2) On Proofing tab, check the
   Show Readability Statistics
   box and click OK

3) On the Review ribbon,
   click on Spelling & Grammar
   to run the readability statistics
   for your form
Sample Passage Comparison:
Assent Form for Ages 7–11
Sample 1                                   Sample 2
To take blood samples, we will have        To test your blood, we will give you a
to insert a needle into your veins.        needle stick in your arm. We will try
We will try not to hurt you and will try   not to hurt you. We will try to put a
to put in a plastic tube that stays in     soft plastic tube in your vein so we
your vein so we don’t have to stick        don’t have to give you another
you with a needle again. We will           needle stick for other blood tests.
also try to give you a medicine that       First we will put a special numbing
will numb the pain. Even though we         cream on your arm so the needle
will try not to hurt you, there may be     stick does not hurt so much. Even
some pain with the blood samples.          though we will try not to hurt you, it
Remember that you can say no at            might hurt when we do the blood
any time and we will not try to stick      tests. You can say no at any time.
you more than three times for any          We will not try to stick you more
sample or to place the catheter.           than three times for any test or to
                                           put in the tube.
Readability Results
Sample 1              Sample 2
Hints to Increase Reading Ease
• Use smaller words with fewer syllables

• Use at least 12 point font

• Use shorter sentences

• Decrease number of passive sentences
Hints to Increase Reading Ease
Use simple terms rather than medical terms:

– Medication or medicine → Drug or study drug
– Investigator or physician → Study Doctor
– Participate → Take part
– Bacteria → Germ
– Catheter → Tube
– Intravenous → In your vein
Assent Form
Readability Exercise
Obstacle # 4
Difficulty of creating readable forms that
adequately explain elements of assent
Elements of Assent in Research
AAP: Goal is to help child achieve developmentally
appropriate awareness including:
• Overview of basic study procedures

• Disclosure that participation is voluntary

• Explanation that what child is being asked to
  agree to is research (not medical care)
Researcher Responsibilities in Assent
• Be aware of approving IRB’s SOPs regarding
  assent and be prepared to follow them

• Ensure that child/adolescent has clear
  understanding of what it means to be in the
  study
  - Create forms that address all elements
  - Use of comprehension checklist can help
    evaluate level of understanding
Financial Disclosure


AAP recommends not disclosing any
financial information to child until study
participation ends to avoid possible
coercion
Obstacle # 5
Neglecting to address logistics of
assenting process
Practical Issues
• Who will conduct discussion?
• Will parent(s) be present?
• Where will discussion take place?
• Will information be written or read to child?
• How will process be documented?
• What happens if child/adolescent refuses?
Confirm Adequate Provisions for Soliciting Assent

• Know whether approving IRB has any specific
  requirements or guidelines regarding assenting
  procedure

• If not, develop your own process in advance
  (who, where, when and how) and follow it

• Consistency is key

• Practice, practice, practice!
Documentation

  When the IRB determines that assent is required, it
  shall also determine whether and how assent must be
  documented.                            (45 CFR 46.408)



How often is a separate note about the assenting
process written?
Recommendations on Documentation
Note should contain:
• Date and time of discussion
• Names/roles of those present including who
  actually conducted the assenting discussion
• Information about whether form was read to
  child/adolescent or they read it themselves
• Notation that any question(s) subject had were
  addressed
• Comment that assent was obtained prior to
  any study-related procedure being performed
Summary: Questions to Consider
• How many different forms will be needed and for
  which age groups?
• At what minimum age does the approving IRB
  specify that assent be solicited?
• What is the readability level of each form? Does
  the readability level match the minimum age
  specified on the form?
• Does each form contain the required elements?
Summary: Questions to Consider
• If the study involves compensation, does this
  information appear in the assent form? If not,
  when is the child told about the compensation and
  is this consistent with guidelines of the approving
  IRB?
• Where will assenting process take place?
• Who will obtain assent?
• Will parent(s) be present?
• How will the assenting process be documented?
Acknowledgement

The pediatric studies referenced in this presentation
were conducted by the Eunice Kennedy Shriver
National Institute of Child Health and Human
Development (NICHD) as part of the Best
Pharmaceuticals for Children Act (BPCA) of 2002 and
2007 and have been funding in whole or in part with
Federal funds from the NICHD, National Institutes of
Health, Department of Health and Human Services,
under Contract No. NO1-HD-3-3351.
References
• Code of Federal Regulations
   – 45 CFR 46:117. Federal Policy for the Protection of Human Subjects (Subpart A).
     Washington, DC: United States Department of Health and Human Services; 1991.
   – 45 CFR 46:404-408. Additional Protections for Children Involved as Subjects in
     Research (Subpart D). Washington, DC: United States Department of Health and
     Human Services: 1991.
   – 21 CFR 50:51-53. Additional Safeguards for Children in Clinical Investigations
     (Subpart D). Washington, DC: United States Department of Health and Human
     Services: 1991.
• Committee on Bioethics. Informed Consent, Parental Permission and Assent in Pediatric
  Practice. American Academy of Pediatrics. Pediatrics. 1995;95:314‐317.
• Committee on Drugs. Guidelines for the Ethical Conduct of Studies to Evaluate Drugs in
  Pediatric Populations. American Academy of Pediatrics. Pediatrics. 2010;125:850-860.
• Kirsch I, Jungeblut I, Jenkins L, Kolstad A. Adult Literacy in America: a first look at the
  findings of the National Adult Literacy Survey. U.S. Department of Education: 1993.
  NCES publication 93275.
• Korn AA. Assent in Pediatric Research. Pediatrics, 2006;117:1806-1810.
References
• National Commission for the Protection of Human Subjects of Biomedical and
  Behavioral Research. The Belmont report: Ethical Principles and Guidelines for the
  Protection of Human Subjects of Research. 1979. Available at:
  http://ohsr.od.nih.gov/guidelines/belmont.html.
• Research Involving Children: Report and Recommendations of the National Commission
  for the Protection of Human Subjects in Biomedical and Behavioral Research. Federal
  Register. 1978; 43:31785‐31794.
• Unguru Y, Sill A, Kamani N. The Experiences of Children Enrolled in Pediatric Oncology
  Research: Implications for Assent. Pediatrics, 2010: 125:876-883.
• US Department of Health and Human Services, Office for Human Research Protections.
  Protections for Children in Research: A Report to Congress in Accord with Section 1003
  of P.L. 106‐310, Children’s Health Act of 2000. 2001. Available at
  http://www.hhs.gov/ohrp/reports/ohrp502.pdf.
• US Department of Education. Institute of Education Sciences., National Center for
  Education Statistics (NCES). National Assessment of Adult Literacy (NAAL).
  Washington, DC: NCES; 2003.
• Whittle A, Shah S, Wilford B, Gensler G, Wendler D. Institutional Review Board
  Practices Regarding Assent in Pediatric Research. Pediatrics. 2004;113:1747-1752.
Speaker Contact Information


Elizabeth Jay, RN, MA
Clinical Manager II
Email: elizabeth.jay@premier-research.com
Phone: (727) 470-9878

www.premier-research.com

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Creating Effective Pediatric Assent Forms: Overcoming Common Obstacles

  • 1. Creating Effective Pediatric Assent Forms: Overcoming Common Obstacles Elizabeth Jay, RN, MA, CCRA Clinical Manager II Premier Research Group 03 May 2011
  • 2. Disclosure I have no relevant financial relationship in relation to this educational activity
  • 3. Objectives • Identify common obstacles to solicitation of effective assent • Apply basic tools to construct effective and appropriate pediatric assent forms • Attain methods to solicit meaningful, age-appropriate pediatric assent
  • 4. Historical Perspective on Assent 2000 Children’s Health Act 1978 DHW proposed regulations to implement recommendations of National Commission 1998 NIH Policy and Guidelines 1977 American Academy of Pediatrics published its first “Guidelines for the Ethical Conduct of Studies to Evaluate Drugs in Pediatric Populations” 1974 National Research Act created National Commission
  • 5. Obstacles to Effective Assent 1) Perception of assent as an afterthought 2) Inadequate direction from sponsors and/or IRBs 3) Failure to address differences in developmental ages and reading grade levels 4) Difficulty of creating readable forms that adequately explain elements of assent 5) Not planning ahead: logistics of assenting process
  • 6. Obstacle # 1 Perception of assent as an afterthought
  • 7. Why is Meaningful Pediatric Assent Important? • Encourages shared decision-making, active participation of research subject • Supports ethical standard of respect for all persons • Alleviates feelings of powerlessness
  • 8. Unguru et al, Pediatrics 2010 • Studied what children aged 7 to 18 with cancer understood about their research- related treatment and their preferences for inclusion in decision-making • 100% wanted to be involved in decision- making, but 49% did not have or recall having a role in decision to enroll and 38% did not feel free to dissent to enrollment
  • 9. Obstacle # 2 Inadequate direction from sponsors and/or IRBs regarding assent
  • 10. Such as…. • Not specifying number of forms to be used or not requiring separate assent form at all • Not providing training for pediatric researchers and staff • Not giving guidance about the minimum age to give assent
  • 11. IRB Responsibilities in Pediatric Research Review and approve research protocols involving minors Ensure adequate provisions are made for soliciting the permission of each child's parents or guardian Determine whether children in study are capable of providing assent and if so, confirm that adequate provisions are made for soliciting their assent
  • 12. Minimum Age of Assent 1979: Belmont Report (report by National Commission) • Recommended age 7 for age of assent 1977, 1995, 2010: AAP Committee on Bioethics and AAP Committee on Drugs • Recommends age 7 as minimum age of assent for medical decision-making including research
  • 13. Real Life Experience: Cohort Group 8 pediatric studies conducted under IND applications at 96 sites between 2004 and 2009 Study Indication Clinical Setting Age Range 1 Bipolar Disorder Type 1 Outpatient 7-17 years 2 Spasticity due to Cerebral Palsy Outpatient 2-16 years 3 Sedation Inpatient (Intensive Care Unit) 3 months – 18 years 4 Status Epilepticus Inpatient (Emergency Room) 3 months – 18 years 5 Status Epilepticus Inpatient (Emergency Room) 3 months – 18 years 6 Blood Pressure Control Inpatient (Operating Room) 0-17 years 7 Blood Pressure Control Inpatient (Intensive Care Unit) 0-17 years Suspected or Complicated 8 Inpatient (Intensive Care Unit) Neonates (0-91 days) Intra-abdominal Infections
  • 14. Cohort Group and Assent • Pediatric assent waived at 37 sites and within two of the 8 studies due to condition under treatment • Remaining 59 sites solicited pediatric assent as they/their IRB deemed appropriate
  • 15. Cohort Group and Assent 40 of 59 sites required and approved one or more separate assent forms (total of 55 forms)
  • 16. Cohort Group and Assent 19 of 59 sites had no separate assent form (child or adolescent signed parental permission) • Minimum age to sign ICF not stated at 9 sites • Other 10 sites listed minimum age to sign ICF anywhere from 7 to 15 years old • Likelihood of child as young as 7 comprehending parental consent form?
  • 17. Obstacle # 3 Failure to address differences in developmental ages and reading grade levels
  • 18. At what grade level does the average adult read and comprehend information? a) 12th grade or higher b) 10th – 11th grade c) 8th – 9th grade d) 6th – 7th grade e) 4th – 5th grade
  • 19. Creating Forms One size doesn’t fit all! • Determine whether your IRB has specified minimum age to give assent • Consider ages of children involved and how many forms will be needed • Write and rewrite as needed until each form is written at the reading grade level of the youngest person who will sign but still contains all relevant information
  • 20. Forms Should be Easy to Comprehend The information that is given to the subject or the representative shall be in language understandable to the subject or the representative. (45 CFR 46.116) Readability is defined as the quality of written language that makes it easy to read and understand • Equates to grade reading level • Readability Statistics give you information about grade level and ease of reading
  • 21. Readability Statistics Flesch Reading Ease and Flesch-Kincaid Grade Level • Common method to check readability statistics • Spelling & Grammar function of Microsoft Office Word • Reading Ease gives index from 0 (hardest) to 100 (easiest) • Grade Level assesses reading grade level* *Older versions of Word don’t assess levels higher than 12th grade
  • 22. Using Word 97-2003 for Checking Readability Stats 1) Under the Tools menu, chose Options which will open a pop-up menu. 2) On the Spelling & Grammar tab, check the Show Readability Statistics box and click OK 3) On the Standard toolbar, click on Spelling & Grammar icon to run the readability statistics for your form
  • 23. Using Word 2007 for Checking Readability Stats 1) Click on the Microsoft Button and then Word Options which will open a pop-up menu. 2) On Proofing tab, check the Show Readability Statistics box and click OK 3) On the Review ribbon, click on Spelling & Grammar to run the readability statistics for your form
  • 24. Sample Passage Comparison: Assent Form for Ages 7–11 Sample 1 Sample 2 To take blood samples, we will have To test your blood, we will give you a to insert a needle into your veins. needle stick in your arm. We will try We will try not to hurt you and will try not to hurt you. We will try to put a to put in a plastic tube that stays in soft plastic tube in your vein so we your vein so we don’t have to stick don’t have to give you another you with a needle again. We will needle stick for other blood tests. also try to give you a medicine that First we will put a special numbing will numb the pain. Even though we cream on your arm so the needle will try not to hurt you, there may be stick does not hurt so much. Even some pain with the blood samples. though we will try not to hurt you, it Remember that you can say no at might hurt when we do the blood any time and we will not try to stick tests. You can say no at any time. you more than three times for any We will not try to stick you more sample or to place the catheter. than three times for any test or to put in the tube.
  • 26. Hints to Increase Reading Ease • Use smaller words with fewer syllables • Use at least 12 point font • Use shorter sentences • Decrease number of passive sentences
  • 27. Hints to Increase Reading Ease Use simple terms rather than medical terms: – Medication or medicine → Drug or study drug – Investigator or physician → Study Doctor – Participate → Take part – Bacteria → Germ – Catheter → Tube – Intravenous → In your vein
  • 29. Obstacle # 4 Difficulty of creating readable forms that adequately explain elements of assent
  • 30. Elements of Assent in Research AAP: Goal is to help child achieve developmentally appropriate awareness including: • Overview of basic study procedures • Disclosure that participation is voluntary • Explanation that what child is being asked to agree to is research (not medical care)
  • 31. Researcher Responsibilities in Assent • Be aware of approving IRB’s SOPs regarding assent and be prepared to follow them • Ensure that child/adolescent has clear understanding of what it means to be in the study - Create forms that address all elements - Use of comprehension checklist can help evaluate level of understanding
  • 32. Financial Disclosure AAP recommends not disclosing any financial information to child until study participation ends to avoid possible coercion
  • 33. Obstacle # 5 Neglecting to address logistics of assenting process
  • 34. Practical Issues • Who will conduct discussion? • Will parent(s) be present? • Where will discussion take place? • Will information be written or read to child? • How will process be documented? • What happens if child/adolescent refuses?
  • 35. Confirm Adequate Provisions for Soliciting Assent • Know whether approving IRB has any specific requirements or guidelines regarding assenting procedure • If not, develop your own process in advance (who, where, when and how) and follow it • Consistency is key • Practice, practice, practice!
  • 36. Documentation When the IRB determines that assent is required, it shall also determine whether and how assent must be documented. (45 CFR 46.408) How often is a separate note about the assenting process written?
  • 37. Recommendations on Documentation Note should contain: • Date and time of discussion • Names/roles of those present including who actually conducted the assenting discussion • Information about whether form was read to child/adolescent or they read it themselves • Notation that any question(s) subject had were addressed • Comment that assent was obtained prior to any study-related procedure being performed
  • 38. Summary: Questions to Consider • How many different forms will be needed and for which age groups? • At what minimum age does the approving IRB specify that assent be solicited? • What is the readability level of each form? Does the readability level match the minimum age specified on the form? • Does each form contain the required elements?
  • 39. Summary: Questions to Consider • If the study involves compensation, does this information appear in the assent form? If not, when is the child told about the compensation and is this consistent with guidelines of the approving IRB? • Where will assenting process take place? • Who will obtain assent? • Will parent(s) be present? • How will the assenting process be documented?
  • 40. Acknowledgement The pediatric studies referenced in this presentation were conducted by the Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD) as part of the Best Pharmaceuticals for Children Act (BPCA) of 2002 and 2007 and have been funding in whole or in part with Federal funds from the NICHD, National Institutes of Health, Department of Health and Human Services, under Contract No. NO1-HD-3-3351.
  • 41. References • Code of Federal Regulations – 45 CFR 46:117. Federal Policy for the Protection of Human Subjects (Subpart A). Washington, DC: United States Department of Health and Human Services; 1991. – 45 CFR 46:404-408. Additional Protections for Children Involved as Subjects in Research (Subpart D). Washington, DC: United States Department of Health and Human Services: 1991. – 21 CFR 50:51-53. Additional Safeguards for Children in Clinical Investigations (Subpart D). Washington, DC: United States Department of Health and Human Services: 1991. • Committee on Bioethics. Informed Consent, Parental Permission and Assent in Pediatric Practice. American Academy of Pediatrics. Pediatrics. 1995;95:314‐317. • Committee on Drugs. Guidelines for the Ethical Conduct of Studies to Evaluate Drugs in Pediatric Populations. American Academy of Pediatrics. Pediatrics. 2010;125:850-860. • Kirsch I, Jungeblut I, Jenkins L, Kolstad A. Adult Literacy in America: a first look at the findings of the National Adult Literacy Survey. U.S. Department of Education: 1993. NCES publication 93275. • Korn AA. Assent in Pediatric Research. Pediatrics, 2006;117:1806-1810.
  • 42. References • National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research. The Belmont report: Ethical Principles and Guidelines for the Protection of Human Subjects of Research. 1979. Available at: http://ohsr.od.nih.gov/guidelines/belmont.html. • Research Involving Children: Report and Recommendations of the National Commission for the Protection of Human Subjects in Biomedical and Behavioral Research. Federal Register. 1978; 43:31785‐31794. • Unguru Y, Sill A, Kamani N. The Experiences of Children Enrolled in Pediatric Oncology Research: Implications for Assent. Pediatrics, 2010: 125:876-883. • US Department of Health and Human Services, Office for Human Research Protections. Protections for Children in Research: A Report to Congress in Accord with Section 1003 of P.L. 106‐310, Children’s Health Act of 2000. 2001. Available at http://www.hhs.gov/ohrp/reports/ohrp502.pdf. • US Department of Education. Institute of Education Sciences., National Center for Education Statistics (NCES). National Assessment of Adult Literacy (NAAL). Washington, DC: NCES; 2003. • Whittle A, Shah S, Wilford B, Gensler G, Wendler D. Institutional Review Board Practices Regarding Assent in Pediatric Research. Pediatrics. 2004;113:1747-1752.
  • 43. Speaker Contact Information Elizabeth Jay, RN, MA Clinical Manager II Email: elizabeth.jay@premier-research.com Phone: (727) 470-9878 www.premier-research.com