SACHRPSecretary's Advisory Committee on Human Research Protections
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Moreover, in order to remain consistent with the Common Rule, SACHRP and the Institute of Medicine (IOM) have both recommended that HHS allow researchers to seek consent for future research if there is enough description of possible future uses in the document to allow for informed consent.
However, SACHRP does not endorse the assertion that biospecimens are inherently identifiable.