Another complication in the consent process is obtaining parental
consent for minors. Online, there is noway to knowif aminor is providing
consent on behalf of a parent without the parent's knowledge. Similarly,
it is difficult to verify a person's identity online,where anonymity
is often valued and “trolls” may pose as someone else as a way to incriminate
or discredit that person.
InMarch 2015, the FDA issued a draft guidance on “Use of Electronic
Informed Consent in Clinical Investigations,” providing recommendations
for clinical investigators, sponsors, and IRBs on the use of electronic media
and informed consent for FDA-regulated clinical investigations ofmedical
products. The plan is for OHRP to consider the language and for the two
agencies to issue a joint FDA-OHRP final document (http://www.fda.
gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/
Guidances/UCM436811.pdf).