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Specification Plug-and-play starting point Clinical & GCP

Specification: eConsent and DCT User Requirements (URS)

A plug-and-play user requirements specification for an eConsent and decentralized-trial platform: numbered, testable requirements for consent version control, signatures, ePRO windows, audit trail, identity, retention, and integrations, with risk tags and a filled specimen.

Document type: Specification

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use user requirements specification (URS) for an eConsent and decentralized clinical trial (DCT) platform. Each requirement is numbered, testable, and risk-tagged, so it can be traced to a test case in the validation protocol. Replace every <<FILL: ...>> placeholder and add or remove requirements to match your study. A filled specimen requirement follows. This content is general educational reference, not legal or regulatory advice.

Document control

FieldEntry
Document number<<FILL: URS-DCT-###>>
System<<FILL>>
Version / date<<FILL>>
Author (business/clinical SME)<<FILL>>
Approver (QA)<<FILL>>

How to read this URS

Each requirement has an ID, a statement written as a testable “shall,” a risk level (High / Medium / Low), and a source (the regulation or business need it comes from). High-risk requirements are the ones that protect the participant or the integrity of the endpoint, and they get the most rigorous testing. Write every requirement so a tester can prove it pass or fail without interpretation.

IDRequirement (shall)RiskSource
URS-101The system shall present every required element of informed consent under 21 CFR 50.25 for each ICF variantHigh21 CFR 50.25
URS-102The system shall serve only the IRB-approved ICF version for the participant’s site and languageHigh21 CFR 56; eConsent guidance
URS-103The system shall provide comprehension support (knowledge checks, glossary, contact for questions)MediumeConsent guidance
URS-104The system shall record time spent and knowledge-check responses in the audit trailMediumPart 11 11.10(e)

2. Signature and identity

IDRequirement (shall)RiskSource
URS-201The system shall capture the participant’s electronic signature with signer name, date/time, and the meaning of the signatureHigh21 CFR 11.50
URS-202The system shall bind each signature to the specific ICF version signed and prevent reuse or transferHigh21 CFR 11.70
URS-203The system shall verify the identity of a remote signer and record the verificationHigheConsent guidance; Part 11 11.100/11.200
URS-204The system shall capture the person-obtaining-consent and investigator signatures where required, with the same metadataHigh21 CFR 50.27
IDRequirement (shall)RiskSource
URS-301On an ICF amendment, the system shall serve the new version to the correct population and block the superseded version at signingHigheConsent guidance; GCP
URS-302The system shall prompt re-consent where an amendment requires it and record who re-consented under which version and whenHighGCP; Part 11
URS-303The system shall maintain a retrievable mapping of each participant to the ICF version they consented underHighPart 11 11.10(b)/(c)

4. Participant copy and records

IDRequirement (shall)RiskSource
URS-401The system shall generate and deliver a copy of the signed ICF to the participantMedium21 CFR 50.27
URS-402The system shall produce accurate human-readable and electronic copies of records for inspectionHigh21 CFR 11.10(b)
URS-403The system shall retain and allow retrieval of records throughout the retention period, including after vendor changeHigh21 CFR 11.10(c)

5. ePRO / eCOA data capture (where in scope)

IDRequirement (shall)RiskSource
URS-501The system shall present the validated instrument exactly (item wording, response options, recall period, skip logic, scoring)HighPRO measurement validity
URS-502The system shall open and close diary entries in the defined windows and flag or prevent out-of-window entriesHighGCP data integrity
URS-503The system shall use a controlled, server-authoritative timestamp and log any device-clock deltaHighPart 11; data integrity
URS-504The system shall bind each entry to the correct participant and device, including on BYODHighALCOA+ attributable
URS-505The system shall render the instrument identically across the supported device matrixHighMeasurement equivalence

6. Audit trail, access, and change

IDRequirement (shall)RiskSource
URS-601The system shall maintain a secure, computer-generated, time-stamped audit trail that is independently reviewable and tamper-evidentHigh21 CFR 11.10(e)
URS-602The system shall enforce role-based access with least privilege and support periodic access reviewHigh21 CFR 11.10(g); 11.300
URS-603The system shall place any change to the production configuration under sponsor-controlled change managementHighAnnex 11; change control

7. Data flow and integrations

IDRequirement (shall)RiskSource
URS-701The system shall transmit data to <<FILL: downstream systems>> completely and reconcilably (counts in equal counts out)HighData integrity
URS-702The system shall preserve original captured data (the signed ICF as served; the raw sensor stream where it is the original)HighALCOA+ original
URS-703The system shall reconcile offline entries correctly on sync, preserving original entry timeHighData integrity

8. Acceptance criteria for the URS

The URS is complete when: every regulatory obligation for the in-scope components maps to at least one requirement; every requirement is testable and risk-tagged; and no requirement is a vague aspiration (“user-friendly”, “compliant”) that a tester cannot prove. Each requirement must trace forward to a test case in the validation protocol with no orphans in either direction.


Filled specimen requirement

The following shows one high-risk requirement expanded to the level a tester and a reviewer both need. Details are illustrative.

FieldEntry
IDURS-301
StatementOn approval of an ICF amendment, the system shall serve the new version to participants at the affected sites/languages and shall block signing of the superseded version
RiskHigh (version control is the most common eConsent finding)
Source2016 FDA/OHRP eConsent guidance; GCP
AcceptanceWith v3.1 pushed, an attempt to sign v3.0 is blocked and v3.1 is served; re-consent is prompted where required; the switch is audit-logged
Traces toTest case TC-09 in the eConsent validation protocol
Verification methodScripted test with screen capture and audit-trail export

Written this way, the requirement cannot be signed off on someone’s opinion that “the vendor handles amendments.” It forces a scripted test with objective evidence, which is exactly what an inspection expects for the highest-risk function in the system.

Common inspection findings this specification prevents

  • Requirements too vague to test (“Part 11 compliant”), so nothing is actually proven.
  • A regulatory obligation with no requirement behind it, and therefore no test.
  • Requirements with no risk tag, so testing effort is spread evenly instead of concentrated on participant-protecting functions.
  • Orphan requirements that trace to no test, or tests that trace to no requirement.

How to adapt this specification

  1. Delete the ePRO or sensor sections if those components are out of scope for your study, and add sections for televisit or logistics components that are in scope.
  2. Set the risk level from your own risk assessment; the tags shown are a starting point.
  3. Point URS-701 and URS-403 at your real downstream systems and retention obligations.
  4. Build the traceability matrix from this URS to the validation protocol before execution begins.
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