Sorry to resurrect an old thread, but I am in this position at the moment and figured adding to this was more beneficial than starting a new thread.
Having a CoGs requirement definitely educates your design, however the other consequence of this is that if it is in a user or system requirement, per the FDA, you need to either validate or verify this requirement. It feels like there should be a "business needs" document that is separate for these types of requirements. Is this a common practice in organizations? Or do people just ignore the requirement in their V&V stages?