342. Informed Consent and Incomplete Disclosure or Deception

Updated July 1, 2021

The principle of respect for persons demands that participants enter the research voluntarily and with adequate information. When deceptive methodologies are used, participants are given incomplete or misleading information about what to expect during the study activities which compromises their ability to give fully informed consent. Ordinarily, research proposals failing to adhere to the principle of respect for persons by compromising the consent process would not be approved. However, in unique circumstances where the study design requires omission of details that might alter the participant’s responses that are being investigated, vital information about the study or study activities can be withheld from participants until after their participation.

Deception and incomplete disclosure can be valuable research methods, and studies involving the use of deception have resulted in significant contributions to science. However, the use of deceptive methodologies places a special burden of responsibility on researchers to provide scientific justification for the deception. Researchers must also provide the appropriate additional safeguards, beyond those safeguards normally in place, to protect the rights and welfare of participants. Investigators are urged to explore the literature within and outside of their field in order to fully understand the history and critical issues related to deceptive methods.

The IRB recognizes that incomplete disclosure/deception is sometimes necessary for human research.

Incomplete disclosure applies when information about the real purpose or nature of the research is withheld from participants.
Deception in the context of human research refers to providing false information to prospective participants.

Incomplete disclosure or deception may NOT be used in greater than minimal risk research. Only study procedures that involve minimal risks (as determined by the IRB) can include deception or incomplete disclosure. Please note that studies involving deception will not be considered for exempt category 1 (research conducted in established or commonly accepted educational settings) because deception is not a “normal educational practice.” In addition, exemption 3 is not applicable unless the participant authorizes the deception through a prospective agreement to participate in research in circumstances in which the participant is informed that he/she/they will be unaware of or misled regarding the nature or purposes of the research.

Use of deception or incomplete disclosure must be justified by its impact on the potential scientific value to the research. Investigators should clearly state that the study involves deception and/or incomplete disclosure Investigators using incomplete disclosure/deception must provide sufficient information in the IRB application to make it clear that the incomplete disclosure/deception:

is necessary for the conduct of the research, and
does not increase risks beyond what participants would agree to had they been fully informed about all aspects of the research.

When Research May Require Use of Incomplete Disclosure or Deception

Incomplete disclosure/deception may be used when the study purpose is to measure behaviors or responses that are likely to be different if participants were fully informed about the project.

Examples of Incomplete Disclosure

Participants are given general information about the study purpose but the information is not detailed enough to reveal the researcher's main or specific objective.
Participants are given truthful information about a study procedure but are not fully informed about the expected findings.
Participants are asked to take a quiz for research but they are not told that the research question involves how background noise affects their ability to concentrate.

Examples of Deception

Participants are given a cover story that provides a feasible but slightly inaccurate account of the study purpose.
The study includes a confederate: an individual who is working on behalf of the research but poses as a participant. The confederate's actions are components of the experimental design.
Participants complete a quiz, and are falsely told that they did very poorly, regardless of their actual performance.
Participants are asked to read a list of words or view a series of images but are not told that their memory will be tested.

Informed Consent in Studies Involving Incomplete Disclosure or Deception

In general, deception is not acceptable if, in the judgment of the IRB, the participant may have declined to participate had they been informed of the true purpose of the research. Investigators may be vague as to the purposes of the study or omit information in consent materials in order to maintain the incomplete disclosure or deception necessary for the research.

Rarely, it is necessary to continue the deception by providing false or misleading information in consent materials. Investigators must justify the inclusion of false/misleading information in consent materials. The IRB will evaluate the effects of the continued deception on participant risk, and will determine if continuing the deception in the consent materials is warranted.

The use of incomplete disclosure/deception means one or more of the basic elements for informed consent are being withheld or distorted. Consequently, the use of incomplete disclosure/deception requires the IRB to approve an alteration of informed consent.

Requirements for IRB approval of an Alteration of Consent for Incomplete Disclosure/Deception

The research involves no more than minimal risk to participants:
Investigators and the IRB must ensure incomplete disclosure/deception are only used in minimal risk research and do not increase risks beyond what participants would agree to had they been fully informed about the research.
The waiver or alteration will not adversely affect the rights and welfare of participants:
Investigators and the IRB must ensure incomplete disclosure/deception do not compromise participants' privacy, interests, or well-being.
The research could not practicably be carried out without the waiver or alteration:
Investigators must provide sufficient information for the IRB to determine that the research questions could not be answered without the use of incomplete disclosure/deception.
Whenever appropriate, participants are to be provided with additional pertinent information after participation:

This criterion generally applies to research involving incomplete disclosure/deception. Participants should be debriefed after participation unless doing so would harm them. In the latter case, the investigator must explain why it would not be appropriate to provide additional information after participation. The IRB must weigh the harms that may result from debriefing with the ethical concerns of not fully informing participants about the research after their participation.

Sample Language for Consent Materials

Ideally and when feasible, investigators include a statement in the consent materials to let participants know that some information about the research is being withheld and they will be debriefed after their participation has concluded. When such information may affect the research results (i.e., may influence participant behavior), it may be omitted but the omission must be justified. Examples of such language include:

We have described the general nature of what you will be asked to do but the full intent of the study will not be explained to you until after [your participation] [the completion of the study]. At that time, we will give you more information about the study and give you an opportunity to ask questions.
Due to the nature of the study, we are not able to disclose the purpose of this research at this time. However, we will hold a debriefing session to answer questions and tell you about the study after your participation.
The full purpose of this research cannot be disclosed before you participate, but will be told to you at the end.
The purpose of this research project is to examine how decisions are made in negotiation. We are not able to provide you all details about the study at the beginning of the study, but we will provide more information during/after your participation.

Debriefing Participants in Studies Involving Incomplete Disclosure/Deception

When investigators use incomplete disclosure or deception, they must include a process for informing participants about the incomplete disclosure/deception unless debriefing is not possible or would cause unacceptable risk to the participants. Debriefing must include the rationale for the study design, the study purpose, and a description of the information that was false or incomplete. Considering that participants may feel a range of emotions at different intervals about being deceived, a process for continuous or staged debriefing may be needed.

The debriefing process should:

inform participants that incomplete disclosure/deception was used, specify what information was withheld or falsified, align with the details and risks of the study,
explain why it was necessary to use incomplete disclosure/deception, and
provide participants the opportunity to ask questions about the new information.

After the debriefing, investigators may ask participants to refrain from talking to others about the incomplete disclosure/deception to minimize the possibility that results may be skewed if subsequent participants knew in advance that incomplete disclosure/deception was being used in the study.

Providing Participants the Option to Withdraw Their Data Post-Debriefing

Although not a requirement, investigators may wish to allow individual participants to withdraw their data after learning of the incomplete disclosure/deception, and the true purpose/goals of the research.

This may be a reasonable option when participant data contain personal identifiers or codes that are linked to a master key, or the debriefing and option to withdraw are provided before a participant submits her/his/their data. This option is not feasible when data are collected without participant identifiers or links to identifiers.

Investigators wishing to exercise this option should provide clear instructions for participants to withdraw their data.

IRB Approval of Research Involving Incomplete Disclosure/Deception

For the IRB to approve incomplete disclosure/deception, the use

must be scientifically necessary,
must be ethically justified, and
may NOT adversely affect participants' rights and welfare.

IRB Approval of an Alteration of Informed Consent

The nature of incomplete disclosure/deception mean that the consent process/materials do not include the eight basic elements required for informed consent. Consequently, the IRB must determine if the research meets the criteria for IRB approval of an alteration of the consent process.

Documentation of the IRB's Determinations

Review worksheets are used to document the IRB's review and determinations, including approval of waiver/alteration of informed consent or waiver of signed consent. Completed worksheets are added to the related submissions in IRBNet.