Vulnerable Populations - Impaired Consent Capacity Adults

Research Involving Adults with Impaired Consent Capacity ("Form T")

There are additional issues that need to be addressed when a research protocol involves adults who may be unable to provide legally effective informed consent because of impairment in consent capacity.  

The IRB requests completion of form T for research protocols that target populations with known impairment as well as studies in which the illness or situational factors could impact consent capacity or produce fluctuations in consent capacity.   If you are proposing research with the potential to enroll one or more adults with consent capacity impairment, please mark the Impaired Consent Capacity Adults attribute under the Subject Demographics section of your E-IRB application, answer the assessment question relative to potential recruitment, and upload a completed "Form T" if applicable [HTML].

In conducting its review, the IRB will assess three dimensions of risk: (1) Research risk; (2) Likelihood that the target population for the study has impaired consent capacity; and (3) The likelihood that consent capacity might change over time. Based on the overall assessment, the IRB has determined recommended obligations and duties of the investigator in regard to capacity assessment and safeguards. 

To facilitate this process, the online version of Form T allows the investigator to self-assess the dimensions relative to his/her protocol.  The Form T calculates a composite score and launches a hard copy plan (printable "Form T") with IRB recommended assessment options and suggested safeguards.  You (the investigator) may use the recommended assessment or provide rationales for alternative protections.  Upon completion, you must save and print hard copies of Form T for inclusion in the IRB submission.   

Some of the assessment options for studies with high composite scores recommend adaptations or use of validated tools.  The following provides information regarding use and access to validated consent capacity assessment tools:

    1. The MacArthur Competence Assessment Tool for Clinical Research (MacCAT-CR; Appelbaum & Grisso, 2001)
      1. Semi-structured interview, tailored to protocol
      2. Administration takes 15-30 minutes, and substantial training is required for valid administration and interpretation
      3. Available from
    2. The University of California, San Diego Brief Assessment of Capacity to Consent (UBACC; Jeste et al., 2007) is available on line
      1. 10-item scale; may be tailored to protocol
      2. Less than 5 minutes to administer, minimal training needed
      3. AMA terms of use for the UBACC

If you do not wish to utilize the online version of Form T, he/she should refer to the University of Kentucky IMPAIRED CONSENT CAPACITY POLICY [PDF] Table 1 Research Dimensions and Categories.  Select the categories appropriate to the study population for (1) Research risk; (2) Likelihood that the target population for the study has impaired consent capacity; and (3) The likelihood that consent capacity might change over time.  Upon request, the ORI will provide you with a manual copy of Form T pre-populated with the composite score and IRB recommendations.  Complete the manual form and include with the IRB application.  Send request for manual copies of Form T to: Belinda Smith at or Judi Kuhl at

For additional information, review the University of Kentucky Impaired Consent Capacity Policy [PDF] and/or the presentation handout “Assessing Consent Capacity in Clinical Research: New Directions” [PDF] or contact the Office of Research Integrity at 859-257-9428.