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Our regulatory position papers and whitepapers on digital health technologies in clinical trials. Three download without an account; a free account opens the rest after email confirmation and personal approval, usually within one business day. No sales calls attached.

43 papers in Position papers
Regulatory Impact Assessment (RIA) for Devices and Systems in Clinical Trials Position papers Free 16 pages

Regulatory Impact Assessment (RIA) for Devices and Systems in Clinical Trials

Why a device’s role and triggers — not the hardware — determine whether an RIA is required

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The Smartphone in Digital Endpoints Position papers Free 10 pages

The Smartphone in Digital Endpoints

Indispensable conduit, immature instrument — the phone’s role in capturing, processing and submitting digital endpoint data

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Digital Trials and the Device Perimeter: A Regulatory Primer Position papers Free 6 pages

Digital Trials and the Device Perimeter: A Regulatory Primer

A plain-language entry point to the regulatory questions raised by the devices and systems a clinical trial relies on — wearables and sensors, home and point-of-care instruments, apps and eCOA platforms, clinical systems, and the phones and tablets that connect them

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When the Instrument Is Their Own Phone Position papers Free 7 pages

When the Instrument Is Their Own Phone

A paper about the participant’s position on a bring-your-own-device trial — written for the sponsor, sites and vendors who must discharge the obligations that anchor to them

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What the Trial Needs From the Handset Maker Position papers Free 6 pages

What the Trial Needs From the Handset Maker

A companion reading from the phone manufacturer / OEM (original equipment manufacturer) seat — what the trial needs from you, and why none of it is your obligation

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Your Device, and the System It Joins Position papers Free 6 pages

Your Device, and the System It Joins

A companion reading from the wearable / biosensor manufacturer seat — your own obligations, and the system the bridge creates

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The Sponsor’s Accountability Map Position papers Free 6 pages

The Sponsor’s Accountability Map

A companion reading from the sponsor’s seat — what you can delegate the work of, and what you answer for regardless

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The eCOA / ePRO Vendor’s Hidden Obligations Position papers Free 7 pages

The eCOA / ePRO Vendor’s Hidden Obligations

A companion reading from the vendor’s seat — where your build and release choices place you inside the perimeters

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The Provisioning Chain’s Inherited Duties Position papers Free 6 pages

The Provisioning Chain’s Inherited Duties

A companion reading from the logistics / provisioning vendor seat — how sourcing and configuration draw operator and end-of-life duties

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Where the Data Actually Travels Position papers Free 5 pages

Where the Data Actually Travels

A companion reading from the connectivity provider seat — what routing and egress do, and do not, do to a trial’s data-protection position

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The Control Plane Is Part of the Trust Position papers Free 5 pages

The Control Plane Is Part of the Trust

A companion reading from the device-management vendor seat — what the control plane must evidence, and when constraining a device is someone else’s regulatory problem

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The Update You Ship Is a Trial Event Position papers Free 5 pages

The Update You Ship Is a Trial Event

A companion reading from the OS / firmware vendor seat — why your release is the sponsor’s change event, and what only you can tell them about it

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The Handoff Is in Validation Scope Position papers Free 5 pages

The Handoff Is in Validation Scope

A companion reading from the clinical-systems vendor seat — why the integration boundary, not the device, is where the regulated record is made

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Where the Evidence Is Actually Made Position papers Free 5 pages

Where the Evidence Is Actually Made

A companion reading from the CRO and site seat — which duties are yours, which are the sponsor’s, and which control belongs to neither of you

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What an Ethics Committee Can Require Position papers Free 6 pages

What an Ethics Committee Can Require

A companion reading on the ethics-committee lens — written for the sponsors, CROs and study teams who prepare the submission

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The Inspection Lens Position papers Free 6 pages

The Inspection Lens

A companion reading on what an inspection of a digital trial actually examines — and where the evidence has to be built long before it

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Harder Populations, Higher Bar — Paediatric and Vulnerable Participants Position papers Free 8 pages

Harder Populations, Higher Bar — Paediatric and Vulnerable Participants

A cross-cutting reading of the series — the perimeters do not change, but the evidence each one demands rises, and every rise has a rule behind it

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Digital Health Technologies in Clinical Trials — A Regulatory Position-Paper Series Position papers 11 pages

Digital Health Technologies in Clinical Trials — A Regulatory Position-Paper Series

One device, several perimeters: a framework for assessing the regulatory impact of the technologies a trial relies on.

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Who Is the Manufacturer? Economic-Operator Roles in DHT Supply Chains Position papers 9 pages

Who Is the Manufacturer? Economic-Operator Roles in DHT Supply Chains

How provisioning, importing, kitting and modifying a device assign manufacturer, importer and distributor duties — often by operation of law.

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You Can Delegate the Work, Not the Accountability: Vendor Qualification and Oversight under ICH E6(R3) Position papers 9 pages

You Can Delegate the Work, Not the Accountability: Vendor Qualification and Oversight under ICH E6(R3)

The sponsor’s duty to qualify and oversee its DHT vendors — distinct from who holds the economic-operator role.

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The Trigger Register: A Controlled Instrument for Digital-Trial Compliance Position papers 7 pages

The Trigger Register: A Controlled Instrument for Digital-Trial Compliance

Turning the per-stakeholder assessment into a living, inspection-ready artefact in the technical file, the validation plan and the TMF — grounded in the risk-based quality management GCP already expects.

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Change Is the Risk: Managing App, OS and Firmware Updates Across a Live Trial Position papers 8 pages

Change Is the Risk: Managing App, OS and Firmware Updates Across a Live Trial

A feature added in a routine update can cross a perimeter mid-study. Why change is a regulated event — and how to tell which changes are material.

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Predetermined Change Control Plans (PCCP) for AI/ML in Trial DHTs Position papers 8 pages

Predetermined Change Control Plans (PCCP) for AI/ML in Trial DHTs

Why an evolving on-device model needs a pre-agreed change plan — and why the regulatory timeline is the part most easily misjudged.

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Vigilance and Post-Market Surveillance for Trial DHTs Position papers 12 pages

Vigilance and Post-Market Surveillance for Trial DHTs

Why the reporting route turns on what the device is — and why meeting one route never discharges another.

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QMS Integration: Embedding DHT Controls across Sponsor and Vendor Quality Systems Position papers 9 pages

QMS Integration: Embedding DHT Controls across Sponsor and Vendor Quality Systems

Why the seam between GCP, ISO 13485 and software-lifecycle quality systems is where DHT control is won or lost.

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Data Residency and Cross-Border Transfer in Decentralised Trials Position papers 10 pages

Data Residency and Cross-Border Transfer in Decentralised Trials

Where clinical data physically travels — and why the device, the connectivity layer and the controller question, not just the cloud, decide it.

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Designed for the Hand That Holds It: Human Factors and Use-Safety in Trial DHTs Position papers 8 pages

Designed for the Hand That Holds It: Human Factors and Use-Safety in Trial DHTs

Why usability and use-error are regulated concerns for participant-facing devices — and why the population, and the risk, set the bar.

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Consent on a Screen: The Regulatory Anatomy of eConsent Position papers 9 pages

Consent on a Screen: The Regulatory Anatomy of eConsent

Why electronic informed consent sits across electronic signature, data protection and GCP / ethics — all at once — and why acceptance is not universal.

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The End of the Device: Decommissioning, Retention and Disposal in Digital Trials Position papers 9 pages

The End of the Device: Decommissioning, Retention and Disposal in Digital Trials

Recovering, wiping, retaining and disposing of trial devices and the data they hold — the lifecycle stage the assessment forgets.

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Qualification of Digital Endpoints for Regulatory Decision-Making Position papers 9 pages

Qualification of Digital Endpoints for Regulatory Decision-Making

Why validation produces the evidence — and qualification is the separate regulatory decision that the evidence is fit for a defined context of use.

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Labelling, UDI and Supply-Chain Transparency for Trial DHTs Position papers 10 pages

Labelling, UDI and Supply-Chain Transparency for Trial DHTs

Why the labelled article is the software, the supplied unit or the sensor — never the phone, tablet or gateway that carries it — and why BYOD makes identification harder, not exempt

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Risk-Based Monitoring and Device Telemetry in Decentralised Trials Position papers 8 pages

Risk-Based Monitoring and Device Telemetry in Decentralised Trials

Why the device is a monitorable data source — and why its telemetry belongs in the risk-based monitoring plan, not outside it

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Global Reconciliation: FDA, EU, PMDA, NMPA and UK Requirements for DHTs Position papers 11 pages

Global Reconciliation: FDA, EU, PMDA, NMPA and UK Requirements for DHTs

Why the shared requirements carry across markets and the local differences do not — and how to decide when a per-jurisdiction assessment is actually needed.

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Continuous Monitoring, Consent and Participant Burden Position papers 10 pages

Continuous Monitoring, Consent and Participant Burden

Why always-on data collection reshapes consent, withdrawal and data minimisation — and why convenience is not the same as proportionality

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Integrating DHTs with EHRs and Clinical Systems Position papers 9 pages

Integrating DHTs with EHRs and Clinical Systems

Why the boundary between the device and the clinical system is the regulated unit — and why provenance must survive the handoff

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Diversity, Representativeness and Equitable Access in DHT Deployment Position papers 8 pages

Diversity, Representativeness and Equitable Access in DHT Deployment

Why who a device can reach is a data-validity question — and why the durable regulatory anchor is the representativeness of the enrolled population.

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Sensor-Based DHTs Cleared by FDA: A Landscape Annex Position papers 7 pages

Sensor-Based DHTs Cleared by FDA: A Landscape Annex

A structured view of the sensor-based digital health technologies FDA has authorised — what they measure, who makes them, how they connect, and what the list does not tell a sponsor

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Validating Sensor-Derived Endpoints in Clinical Trials Position papers 10 pages

Validating Sensor-Derived Endpoints in Clinical Trials

Why a sensor reading is only as good as its verification, analytical, clinical and usability validation — and the interpretation threshold that makes it an endpoint.

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When the Device Thinks: AI/ML in Trial DHTs and the Stacking of Obligations Position papers 9 pages

When the Device Thinks: AI/ML in Trial DHTs and the Stacking of Obligations

How an on-device model adds an AI overlay on top of the device rules — and why the 2028 application date is a trap, not a reprieve.

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Securing the Trial Device: Cybersecurity Obligations for Clinical DHTs Position papers 9 pages

Securing the Trial Device: Cybersecurity Obligations for Clinical DHTs

A networked device holding clinical data is a security artefact — and security is a data-integrity obligation, not optional hygiene.

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Inspection-Ready: What FDA, EU and MHRA Inspectors Look For in DHT Evidence Position papers 9 pages

Inspection-Ready: What FDA, EU and MHRA Inspectors Look For in DHT Evidence

In qointa’s experience the first inspection sets the baseline. What digital-trial evidence inspectors expect, what it is grounded in — and why it must exist before they ask.

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ALCOA+ on the Device: Device-Side Data Integrity in GCP Position papers 8 pages

ALCOA+ on the Device: Device-Side Data Integrity in GCP

When a device captures trial data — a handset, a wearable, a home instrument or the gateway that relays them — attribution, time and protection against alteration are decided on the device, and no validated database can decide them later.

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When the Phone or Gateway Is the Hub: Interoperability and Connected-Device Systems Position papers 9 pages

When the Phone or Gateway Is the Hub: Interoperability and Connected-Device Systems

When a hub — the participant’s phone, a tablet or a provisioned cellular gateway — bridges a sensor, wearable, spirometer or CGM, the combined system, and the device-to-device boundary, becomes the regulatory unit.

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