Screening for HIV in the emergency department (ED) is recommended by the Centers for Disease Control and Prevention. The relative importance of efforts to increase consent among those who currently decline screening is not well understood. We compared the risk characteristics reported by patients who decline risk-targeted, opt-in ED screening with those who consent. We secondarily recorded reasons for declining testing and reversal of the decision to decline testing after prevention counseling. Of 199 eligible patients, 106 consented to testing and 93 declined. Of those declining, 60 (64.5%) of 93 completed a risk assessment. There were no differences in HIV risk behaviors between groups. Declining patients reported recent testing in 73.3% of cases. After prevention counseling, 4 (6.7%) of 60 who initially declined asked to be tested. Given similarities between those who decline and those who consent to testing, efforts to increase consent may be beneficial. However, this should be tempered by the finding that many declined because of a recent negative test. Emphasizing risk during prevention counseling is not a promising strategy for improving opt-in consent rates.