Do I Need to Obtain Informed Consent for Exempt Research?
Yes, for exempt research that involves interaction with subjects, there usually should be a process to ask subjects to participate and confirm their agreement. However, signed consent is not required for most exempt research, and the consent process and documents can be much simpler than those required for non-exempt research.
Verbal or implied consent may be sufficient for exempt research that involves interaction with subjects. For some purely observational research, consent may not be necessary.
You will need to ask for a waiver of documentation of consent in your IRB application.