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What Computer Software Assurance actually changes

Computer Software Assurance, CSA, is FDA guidance that pushes validation effort toward risk based, critical thinking testing instead of scripting every function regardless of how minor it is. It does not remove the need for evidence. It changes how much evidence a given system actually needs.

The shift in plain terms

Under the older, heavily scripted approach, a team would write a detailed test script for nearly every function, execute it step by step, and file a screenshot for each step, whether the function was safety critical or cosmetic. CSA asks teams to reserve that level of rigor for the features where a failure would actually matter, and use lighter, unscripted testing for the rest.

Where this catches teams out

Some vendors market CSA as a reason to skip documentation altogether, which is a misreading. The guidance still expects a documented rationale for why a given test approach was chosen and evidence that the testing happened. What changes is the format and depth, not whether evidence exists at all.

What a compliance leader should ask a vendor

Ask whether the vendor's testing approach distinguishes between high risk and low risk functionality, or whether every feature gets the same treatment by default. A platform that cannot show that distinction has not actually adopted CSA thinking, whatever the marketing page says.

Questions we hear often

Does CSA replace 21 CFR Part 11?

No. Part 11 covers electronic records and signatures. CSA is guidance about how much and what kind of testing effort a system's features need. The two operate on different layers of the same validation problem.

Is CSA final guidance yet?

FDA has been developing CSA guidance over several release cycles. Check FDA's own site for the current status before citing a specific version in an audit response, since guidance documents move through draft and final stages on their own timeline.

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