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Donor’s Written Statement of Understanding. Beth H. Shaz, MD Chief Medical Officer New York Blood Center Clinical Associate Professor Emory University School of Medicine. Transfusion. 2009 Jun;49(6):1136-45. Blood collection. Is done under the supervision of a licensed physician
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Donor’s Written Statement of Understanding Beth H. Shaz, MD Chief Medical Officer New York Blood Center Clinical Associate Professor Emory University School of Medicine
Blood collection Is done under the supervision of a licensed physician Has known risks
What guidelines exist AMA Code of Ethics AABB Code of Ethics AABB Standards for Blood Banks and Transfusion Services CMS Guidelines for Informed Consent FDA CBER Guidance for Industry: Informed Consent Recommendations for Source Plasma Donors Participating in Plasmapheresis and Immunization Programs FDA Guidance for Institutional Review Boards and Clinical Investigators: A Guide to Informed Consent
Informed consent process Informed consent is more than simply getting a patient to sign a written consent form. It is a process of communication between a patient and physician that results in the patient's authorization or agreement to undergo a specific medical intervention. In the communications process, you, as the physician providing or performing the treatment and/or procedure (not a delegated representative), should disclose and discuss with your patient: The patient's diagnosis, if known; The nature and purpose of a proposed treatment or procedure; The risks and benefits of a proposed treatment or procedure; Alternatives (regardless of their cost or the extent to which the treatment options are covered by health insurance); The risks and benefits of the alternative treatment or procedure; and The risks and benefits of not receiving or undergoing a treatment or procedure. In turn, your patient should have an opportunity to ask questions to elicit a better understanding of the treatment or procedure, so that he or she can make an informed decision to proceed or to refuse a particular course of medical intervention. http://www.ama-assn.org/ama/pub/physician-resources/legal-topics/patient-physician-relationship-topics/informed-consent.page#
AABB Standards for Blood Banks and Transfusion Services, 27th edition Standard 5.2 Information, Consents and Notifications Elements of the donation procedure shall be explained to the prospective donor in understandable terms. The explanation shall include information about risks of the procedure, tests performed to reduce the risks of transmission of infectious diseases to the allogeneic recipient and requirements to report donor information, including test results, to state or local health departments. The donor shall have an opportunity to ask questions and have them answered and to give or refuse consent for donation. In the case of a minor or a legally incompetent adult, consent shall be addressed in accordance with applicable law.
Major elements of informed consent process Disclosure Sharing material information Comprehension Ability to understand information Voluntariness Freedom to make decisions Competence Ability to make decisions Consent Decision and authorization Arch Pathol Lab Med 2008;132:947-951
Four essential elements of informed consent The reason for, the nature and purpose of, the risks and potential consequences of, the benefits from, and any feasible alternatives to the procedure; The extent, limits, and mechanisms used to maintain confidentiality; Who to contact with questions; and That participation is voluntary and discontinuation is possible at any time without penalty. http://www.fda.gov/oc/ohrt/irbs/informedconsent.html
What are the risks of whole blood donation TRANSFUSION2008;48:1809-1819.
Goal of study Investigate use, nature and content of informed consent and related materials for whole blood donation Transfusion. 2009 Jun;49(6):1136-45.
Materials and methods Collection of informed consents and related documents Blood collection establishments were identified by the AABB and America’s Blood Centers’ Web sites as of 12/1/2007 Random selection was used to contact establishments Documents also obtained from the internet or requested Transfusion. 2009 Jun;49(6):1136-45.
Definitions Informed consent form (ICF): Paper document that was signed by the prospective donor prior to donation Parental consent form (PCF): Paper document the parent or guardian signed to establish proof of permission for the minor to donate General information forms (GIF): Any paper documents that were specifically referred to for reference purposes in the ICF or PCF Transfusion. 2009 Jun;49(6):1136-45.
Scoring of documents Based on guidance by the FDA and CMS on informed consent for surgical procedures, research subjects and source plasma donors, we determined which elements should be contained All forms were scored independently and differences were reconciled If a single blood establishment used the same forms in multiple states, the forms were only scored once Transfusion. 2009 Jun;49(6):1136-45.
Guidance and guidelines https://www.cms.gov/SurveyCertificationGenInfo/downloads/SCLetter07-17.pdf
Common essential elements The four common essential elements to all consent forms included: 1) the reason for, the nature and purpose of (2 points), the risks and potential consequences of (4 points- 1 point for each of the four most common adverse events, including vasovagal reactions, hematoma and bruising, fatigue, and infection at the site of puncture), the benefits from (2 points), and any feasible alternatives to (as there are no alternatives for blood donation, this element was not scored, 0 points), the procedure; 2) the extent, limits and mechanisms used to maintain confidentiality (4 points total and only 2 points if confidentiality is solely mentioned in the context of infectious disease testing); 3) who to contact with questions (4 points), and 4) that participation is voluntary (2 points) and discontinuation is possible at any time without penalty (2 points). These elements were scored (total 20 points) on ICFs and PCFs and their related GIFs. Transfusion. 2009 Jun;49(6):1136-45.
Specific blood donation elements An additional set of elements included: 1) description of the procedure: pre/post donation (1 point), donor eligibility/ donor screening (1 point), and estimated time for donation (1 point); 2) infectious disease testing: general statement regarding infection disease testing (1 point), testing for HIV/AIDS (1 point), testing for hepatitis B and C (1 point), reporting positive result to the donor and/or parent (1 point); 3) contact information to report injury (1 point); 4) information regarding donor deferral (1 point); 5) information regarding potential additional medical expenses and/or treatment (1 point); and 6) documentation of the consent by parent/guardian or donor signature on the consent (1 point). These elements were scored (total 11 points) on ICFs and PCFs and their related GIFs. Transfusion. 2009 Jun;49(6):1136-45.
Unique minor age donor elements PCFs should have a number of related and likely important elements such as permission to allow outside medical treatment or emergency transport in the event of a serious reaction. Thus, the authors sought to determine if some of the standard elements of a school field trip consent form that could relate to the blood donation itself or the blood donation process were included in the PCFs under investigation. By identifying and reviewing a number of school field trip consent forms on the internet, a list of the critical components for PCFs was created by the authors. These specialized aspects, which are exclusive of the elements listed for scoring above, include 3 key elements: 1) explanation of the duration of consent (1 point if a consent included a statement such as “this consent is no longer required on your child’s 18th birthday”); 2) parent contact number at the time of donation (1 point), and 3) authorization for medical treatment in case of an emergency (1 point). Transfusion. 2009 Jun;49(6):1136-45.
Results • 58 different informed consents with related materials were included • 21 ICFs and 37 PCFs • 9 hospital-based, 39 community-based and 10 multistate blood collection centers • ICFs and PCFs were collected from 48 states • Blood establishment forms surveyed represented >90% collected in the US Transfusion. 2009 Jun;49(6):1136-45.
Common essential elements Transfusion. 2009 Jun;49(6):1136-45.
Specific blood donation elements Transfusion. 2009 Jun;49(6):1136-45.
Unique minor age elements Transfusion. 2009 Jun;49(6):1136-45.
Study limitations A number of limitations include that: 1) the investigators were not blinded to the blood center name when evaluating ICFs and PCFs; 2) the scoring system used was subjective and not previously employed in others studies or validated; 3) the investigators could not evaluate the entire informed consent process; 4) some of the informed consents were downloaded from the internet and therefore may not be accurate or the most current version used at the blood center; and 5) the use of the research informed consent essential elements as the model for the essential elements for whole blood donation. Some of the elements of the research consent may not directly applicable to whole blood donation. These elements include the individual will not have direct benefit (which at times is true in the research setting), and there are not alternatives to whole blood donation (with the possible exception of blood component collection by apheresis). Nonetheless, the investigators believe that the data are important and timely, and that key conclusions can be drawn and recommendations made.
Study recommendations Most parental consent forms and informed consent forms with the related general information forms do not contain the majority of the common essential or specific blood donation elements Recommend an intervention to remedy this, such as nation-wide task force to make recommendations