What is the CCAR expectation regarding documentation of informed consent for disclosures?

• A. Document consent only verbally.
• B. Document consent informally without details.
• C. Document consent clearly, specify what may be disclosed, to whom, under what circumstances, and the duration; update as needed.
• D. Do not document consent; rely on memory.

Answer: (C)

Clear, thorough documentation of informed consent for disclosures is required. The record should spell out exactly what information may be disclosed, to whom, under what circumstances, and for how long the consent remains in effect. It should also note any conditions, limitations, or revocation rights, and be updated if the scope or recipients change.

This level of detail protects the client’s privacy, ensures they understand and control what is shared, and provides a defensible audit trail for compliance. Relying on verbal agreement or informal notes without specifics can lead to misunderstandings and unauthorized disclosures, and not documenting at all creates significant regulatory and ethical risk. An up-to-date, clearly documented consent helps align practice with ethical and legal expectations and supports ongoing coordinated care.