About the author
Mackenzie De Jesus, DHSc, MS, Head of Clinical Research. Mackenzie De Jesus leads clinical research at Reputable Health, where she designs and runs decentralized studies that pair wearable data with validated participant-reported outcomes. She holds a Doctorate of Health Science from A.T. Still University and a master’s degree in experimental psychology from Nova Southeastern University. Her background spans health science, experimental psychology, and clinical research, including experience designing and executing clinical trials in functional medicine and digital health.
A clinical trial management system (CTMS) is software that records how a study is running: who has enrolled, which milestones are due, which documents are current, and which partner owns each task. For a brand or ingredient manufacturer, the harder question is whose CTMS to rely on.
Sponsors running one or two studies a year can often rely on a partner’s system instead of licensing their own. Every sponsor needs to see what the system records, since responsibility for the study stays with the sponsor.
Below: when to buy, when to borrow, and what to require in writing.
The short answer
- A CTMS tracks operations. Enrollment, milestones, documents, safety events, and partner tasks live there; outcome data sits in a separate system.
- Responsibility stays with you. Under international good clinical practice, a sponsor can hand trial work to a partner but keeps ultimate responsibility for it.
- Low volume rarely needs a license. A sponsor with one outsourced study at a time can usually oversee it through the partner’s system.
- Remote studies need other features. Product shipping, wearable syncing, and electronic consent matter more than site visits.
- Write the specification first. List the reports, access, and audit trail you need before you compare partners.
See how your study would run
Bring the product or ingredient, the outcome you hope to claim, and the date you need answers. We’ll walk you through the design and the progress updates you’d receive while it runs.
What a clinical trial management system tracks
Most definitions of a CTMS list features. A sponsor needs a different lens: what each function records, and what that record tells you about your own study.
If you want the general definition first, start with the basics of a CTMS. The table below reads the same functions from the sponsor’s side of the desk.
IRB stands for Institutional Review Board, the independent ethics committee that reviews a study before it starts and while it runs.
A CTMS manages the study. Electronic data capture systems (EDC) hold the study data itself: survey answers, lab values, wearable readings. Keep the two apart when you ask a partner what you will be able to see.
Decide whether you need your own CTMS
The international good clinical practice guideline, ICH E6(R3) from the International Council for Harmonisation, lets a sponsor transfer some or all of its trial work to a service provider, such as a contract research organization (CRO). Ultimate responsibility for participants’ safety and for reliable data still rests with the sponsor (section 3.6.6).
Owning software does not change that duty. Seeing the right records, at the right time, is what meets it.
Reputable runs studies end to end for sponsors, so we’ve noted where licensing your own system is the better fit.
License your own CTMS when you run several studies at once across more than one partner, you have clinical operations staff who will keep the system current, or leadership needs one view of a portfolio that no single partner can provide.
Use your partner’s system when one partner runs the study end to end, nobody on your team has time to maintain software, and the agreement spells out the reports and access you receive. Many brands and ingredient manufacturers without in-house research staff sit here.
Hold off on any system when the research question is still open. Software can track a study well and still have nothing useful to track. Define the research question first, then choose the design, and only then decide how you will watch it run.
If you license one, check these five points
A license pays off only when someone on your team opens the system every week. Test these points in a demo before you sign.
- Integration with your data system. Confirm the CTMS exchanges enrollment and visit data with your EDC system and your electronic trial master file (eTMF), the archive of essential study documents, without manual re-entry.
- Remote workflows. Ask to see product shipping, device sync status, and electronic consent set up in the demo, rather than reading about them on a feature list.
- Audit trail and user roles. Check that change logs cannot be turned off, and that access can be granted by role and removed the day someone leaves.
- Setup and upkeep. Ask how long configuration takes, who builds each new study, and how many hours a week your team will spend keeping records current.
- Exit terms. Agree how your records leave the system, and in what format, if you change providers or stop licensing.
Specify what your partner’s system must show you
ICH E6(R3) gives the sponsor access to relevant information about a provider, performance metrics included (section 3.6.8). The same section asks for oversight of the important work a provider takes on, including anything that provider passes to a subcontractor (section 3.6.9).
Turn those two lines into a written list before the contract is signed. Each report below should arrive with a definition attached, because the same word means different things to different teams.
Here is a common example. On Reputable’s studies, participant compliance means completing daily check-ins, keeping the wearable synced, and finishing required surveys on most study days; whether a participant actually took the product is tracked separately as adherence.
A single “engagement” score that blends adherence, compliance, and completion can look healthy while product use quietly falls. Ask for each number on its own line.
Then agree when each report arrives. At Reputable, sponsors can receive progress updates, such as enrollment and adherence, at points agreed in the study plan. Operational reports describe how the study is running; the analysis at the end is where you learn whether the product made a difference.
Plan the oversight alongside the design
A controlled study starts with a protocol, an analysis plan, and a reporting schedule your team agrees to before enrollment. See how a full study is set up, from the first call to the final report.
Check the system against decentralized study needs
Many CTMS feature lists center on site work: site rosters, monitoring visits, and investigator payments. A study where participants take part from home needs a different set, because decentralized clinical trials move the activity to the participant.
The Food and Drug Administration (FDA) describes these needs in its September 2024 guidance on trials with decentralized elements, written for drug, biologic, and device trials. Its section on electronic systems names the functions below, and each one maps to a wellness study run at home.
- Product shipping and receipt. The system should log product sent to each participant’s home and confirm it arrived.
- Device data syncing. A sync log shows when each participant’s wearable last uploaded, so gaps in continuous wearable data surface while there is still time to fix them.
- Electronic consent records. The approved consent version, the IRB approval behind it, and each signed form belong in one place.
- Remote reports. Results from at-home lab kits and other off-site assessments should be stored with the date they arrived.
- Scheduling by study day. Check-ins, surveys, and product use are planned around each participant’s timeline, since there is no site visit to anchor them.
- Participant communication. A record of contact between the study team and participants, so questions and issues are documented. Sponsors see study data with participants de-identified.
FDA’s guidance also recommends that a data management plan describe where each data stream originates and how it reaches the sponsor. Ask your partner for that map. One page showing which system holds which record will answer most of your later questions.
Ask the compliance questions that apply to your study
Vendor guides often present 21 CFR Part 11, FDA’s rule on electronic records and electronic signatures in the Code of Federal Regulations (CFR), as a requirement for every CTMS. The rule’s own scope is narrower than that.
Under section 11.1(b), Part 11 covers electronic records kept under an FDA records requirement, plus electronic records submitted to the agency. Whether your study falls inside that scope depends on the product, the records involved and any planned submission.
Put these five questions to your partner, and to your counsel where noted.
- Is any record in scope for Part 11? Ask counsel before enrollment, with the protocol and any planned FDA submission in hand.
- Is the audit trail switched on? ICH E6(R3) section 4.2.2 expects a system to keep the first entry and each later change, with the reason where appropriate, and says audit trails should stay enabled.
- Is there a list of the systems in use? ICH asks sponsors to keep a record of the important computerized systems they deploy, what each does and who manages it, scaled to how much each system matters (section 3.16.1). Ask your partner for the equivalent list covering their own systems.
- Who can see and change the data? Request the user list, each person’s role, and how access is removed when someone leaves the study.
- What comes back at the end? Agree on the format of the final operational records alongside the dataset, so the history of the study stays with you.
Requirements differ by product type and by what you plan to do with the results, so confirm your answers with qualified regulatory counsel.
What a CTMS cannot do for your study
A good system makes a study easier to watch. Some problems sit outside what any system records.
- Repair a design. A well-tracked study of the wrong question still answers the wrong question.
- Stand in for outcome data. Enrollment and adherence show how the study ran. Whether the product changed anything comes from the analysis plan set before enrollment.
- Support a claim by itself. Whether findings can support a claim depends on the design, the analysis, and the full body of relevant, reliable research. A positive finding is not guaranteed.
- Replace a reviewer. A report nobody reads catches nothing. Name the person on your team who reviews each one.
Where Reputable fits
Reputable Health is a full-service decentralized CRO for health and wellness brands and ingredient manufacturers. The guidance above applies to whichever partner you choose.
- Offerings. Two offerings: a pilot study and a full clinical study, and the scope follows your question.
- Model. Remote participation and data collection, with study design, timelines, and costs tailored to the research question.
- Compared with site-based studies. Decentralized studies remove the need for clinic visits, which often makes them quicker to enroll and less costly to run.
- Operations. One team handles protocol design, IRB submission, enrollment, data capture, analysis, and reporting. Reputable coordinates product shipping to participants, tracks adherence, and reports safety and adverse events.
- Measurement. Consumer wearables (Oura, WHOOP, Apple Watch, Garmin, Fitbit), validated surveys, and at-home lab kits processed through CLIA-certified partner laboratories. (CLIA is the federal Clinical Laboratory Improvement Amendments program for lab testing.)
- Review. Studies go through independent Institutional Review Board review, and the review pathway follows the study design.
- Scope. Every study is scoped to your product or ingredient, your claims, and your budget.
Two figures: Reputable reports for its own work:
Frequently Asked Questions
Five questions brand and ingredient teams ask when they plan how a study will be tracked.
The bottom line
A clinical trial management system is a record of how a study runs. Whether you license one or rely on a partner’s, the responsibility for the study and its data stays with your team.
Before you request proposals, write a one-page reporting specification: the numbers you want kept apart, how often you see them, who can change data, and what comes back at the end. Then ask each partner to show you how they’d meet it, line by line.
Bring your reporting checklist
Tell us about the product or ingredient, the claim you want to evaluate, and what you need to see while the study runs. We’ll show you how we’d run it and which updates you’d get along the way.