The FDA Center for Devices and Radiological Health (CDRH) recently published new guidance for medical device priorities in 2023. The FDA CDRH guidance looks to evolve away from the COVID-19 pandemic and transition toward digital health, medical device software and regulated software as a medical device (SaMD).
Cybersecurity for Medical Devices
Among topics the FDA guidance considers “A-List” priorities is cybersecurity for medical devices. Two initial priorities of the FDA guidance will include a deeper study of quality system (QMS) considerations and premarket submission (PMA) content.
Additional FDA software guidance was published earlier this year (September 2022) that described how software functions meet the definition of a medical device and risks to the public. The change industry should keep an eye on is FDA product specific guidance that applies to regulating software development that impacts risk to patient safety.
Quality Management System
Quality management system regulation currently falls under 21 CFR 820, so it will be interesting to see how new updates are developed based on discussion with industry. Every medical device manufacturer is required to have a compliant QMS system that includes the necessary QMS documentation for regulatory approval.
As digital healthcare integrates the physician-patient relationship, FDA continues to scrutinize device software functions and healthcare mobile apps. Lastly, these insights may provide additfeedback on software functions not subject to FDA regulatory requirements relevant to a QMS audit.
Remanufacturing Medical Devices
FDA is taking a deeper look at reusable medical devices and how preventive maintenance increases the life of a medical device. Currently, there are separate regulations for both industry manufacturers and 3rd party service companies. FDA will look to clarify the differences between “servicing” and “remanufacturing”, and the impact on medical device safety for either. This will likely impact the regulatory responsibilities of companies who perform these activities for health care providers.
Premarket Authorization (PMA)
Software as a medical device continues to grow across the health care industry. Updated premarket authorization guidance will focus on software devices with consideration to how the software is delivered to the end user. This can include factory-installed healthcare software or platforms installed by a third-party vendor.
Equally important, new information is anticipated for different types of firmware and software-based control of medical devices. Industry employees should also anticipate greater clarity for stand-alone software applications and general purpose computers. Leadership at FDA has included subtle hints that accessories to medical devices that include software may also be included in future FDA guidance for industry.
COVID-19 Emergency Use Authorization (EUA)
There has been discussion around the 180-day timeline proposed for notice of ending a medical device EUA due to COVID-19. Final guidance should be available in 2023 that provides more detail about on the appropriate transition period. FDA is considering industry recommendations that avoid disruptions to product shortage and supply chain.
Further, consideration is also being given to medical device manufacturer and healthcare providers to adjust from policies adopted during the public health emergency (PHE). For example, an EUA issued under section 564 of the FD&C Act will remain in effect. Primary changes will be based on if FDA chooses to revoke the EUA because the criteria for issuance is no longer met.
Voluntary Improvement Program
FDA and the Medical Device Innovation Consortium (MDIC) continue to advance their pilot program launched in 2018. Select medical device manufacturing sites were chosen to review key business processes using a series of integrated best practices. The Capability Maturity Model Integration (CMMI) Institute certified select team to conduct and review quality system maturity of these sites.
Additionally, 2023 will likely bring even more data surrounding the MDIC program. This could include public info for industry about continuous improvement through quarterly check-in progress with participating medical device companies. The program is designed to report industry baseline metrics after the check-in and monitor operational excellence.
Breakthrough Devices Program
New information from FDA will arrive in 2023 for updates to the Breakthrough Devices Program. Early updates suggest the guidance will clarify how the program may be more applicable to certain devices than others. FDA breakthrough designation often benefits populations that are more likely to be impacted by health care disparities. New clarity may include breakthrough therapy designations and how medical device companies can educatee sponsors to submit for proposed indications of use.
Finally, an important facet of the breakthrough devices program is the type of evidence needed for FDA approval. Clarity should help to determine whether a device is reasonably expected to increase the treatment or diagnosis efficacy. Moreover, early indications suggest that the intended use of the device, technology and features, and the available standard of care alternatives will all play a role.
About RCA’s Medical Device Consulting Services
The regulatory compliance process surrounding the medical device industry involves a strict adherence to pre/post market information throughout a device’s life cycle. Even a single compliance issue you have can turn into a significant effect on your business. Regulatory Compliance Associates can help guide you through any stage of the medical device consulting process, with capabilities during product development through the regulatory clearance/approval of your product.
Our team of over 500 medical device consulting Experts — including former FDA officials and regulatory compliance leaders in the field of medical device regulation — will work with your company to create a quality assurance and regulatory compliance approach tailored to your products and regulatory needs. Regulatory Compliance Associates works with international Fortune 100 companies, venture capital start ups, and companies of all sizes and shapes. our compliance enforcement solutions for law firms include remediation for warning letters, FDA 483’s, import bans or consent decrees. Very few regulatory compliance services have the same regulatory compliance expertise in a variety of medical fields.
For medical device manufacturers, technology can be a double-edged sword. The innovative technologies that elevate the quality of life for patients can also be used to potentially undermine the organization using the device. The consequences can affect the device itself if Regulatory Compliance Associates medtech consultants do not implement good IoT cybersecurity and FDA cybersecurity protocols.
At Regulatory Compliance Associates, we offer a wide variety of services for medical devices security to help ensure that your product is protected from cyber-attacks. With a well-planned design, along with full visibility of product development and the supply chain, Regulatory Compliance Associates medical device consultant Experts can help strengthen your device’s cybersecurity. We partner with medical device companies in each phase of the design cycle, including protecting inputs from threat exposure and hardening outputs for regulatory compliance & FDA submission approval of your medical technology.
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Regulatory affairs is Regulatory Compliance Associates® backbone, and we handle more submissions in a month than many manufacturers do in a lifetime. Our regulatory compliance consulting Experts have experience working with the FDA, global regulatory bodies and / or agencies, and notified bodies worldwide. Therefore, you can count on us for in-depth and up-to-date insights which increase speed-to-market.
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Regulatory Compliance Associates® Quality Assurance consulting includes quality system assessments, strategy, implementations, and identification of quality metrics to ensure continuous improvement, aligning with your business needs and goals. Each Regulatory Compliance Associates® medical device consultant is a quality expert with experience spanning major corporations and start-ups. We know firsthand how to achieve, maintain, and improve quality, and we excel in transferring this knowledge to your organization.
In the medical devices field, quality assurance (QA) is more than merely ensuring the quality of a finished product. You need the tools to monitor and regulate every process from the design of a new product to continued quality compliance as the device is sent to market. At Regulatory Compliance Associates®, we offer you the quality assurance services you need to monitor these processes and ensure quality compliance every step of the way.
With more than 20 years experience working with medical device consulting companies, Regulatory Compliance Associates® trusted medical device quality assurance consultant team is fully equipped to handle your unique QA needs.
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Regulatory Compliance Associates® is widely recognized within medical device consulting companies & the life science industry for our remediation services & support. Regulatory Compliance Associates® ability to help companies successfully resolve complex regulatory challenges have a proven track record of success. Our medical device consulting services include significant experience with the development of responses to 483 Observations, Warning Letters, Untitled Letters and Consent Decrees.
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Our value goes beyond the initial response by helping companies successfully execute their action plans, develop an improved compliance culture tailored to the needs of their business, and ultimately move beyond the regulatory action to emerge as a stronger business. We negotiate difficult demands of remediation with insight and the clear advantage of our medical device consultant expertise and experience that makes partnering with Regulatory Compliance Associates® a competitive differentiator in the remediation space.
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Whether it’s a strategy, a technical plan, or project, Regulatory Compliance Associates® medical device consultancy can help ensure a successful project. Regulatory Compliance Associates® medical device strategy consulting can deliver your project on time, on budget, and you’re never embroiled in a costly mistake.
Our medical device consultant Experts are industry Experts are here to provide the unique insight you need before an M&A deal, through a staffing crisis and in every area of your product’s development and life cycle. As the trusted medical device manufacturing consultants of thousands of companies around the world, we have the knowledge and expertise needed to deliver exceptional results to your business — no matter your size or unique needs.
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About Regulatory Compliance Associates
Regulatory Compliance Associates® (RCA) provides medical device consulting to the following industries for resolution of life science challenges:
We understand the complexities of running a life science business and possess areas of expertise that include every facet of R&D, operations, regulatory affairs, quality, and manufacturing. We are used to working on the front lines and thriving in the scrutiny of FDA, Health Canada, MHRA and globally-regulated companies.
As your partners, Regulatory Compliance Associates can negotiate the potential minefield of regulatory compliance and regulatory due diligence with insight, hindsight, and the clear advantage of our unique expertise and experience.
- Founded in 2000
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- Acquired by Sotera Health in 2021
About Sotera Health
The name Sotera Health was inspired by Soteria, the Greek goddess of safety, and reflects the Company’s unwavering commitment to its mission, Safeguarding Global Health®.
Sotera Health Company, along with its three best-in-class businesses – Sterigenics®, Nordion® and Nelson Labs®, is a leading global provider of mission-critical end-to-end sterilization solutions and lab testing and advisory services for the healthcare industry. With a combined tenure across our businesses of nearly 200 years and our industry-recognized scientific and technological expertise, we help to ensure the safety of over 190 million patients and healthcare practitioners around the world every year.
We are a trusted partner to more than 5,800 customers in over 50 countries, including 40 of the top 50 medical device companies and 8 of the top 10 pharmaceutical companies.
Commitment to Quality
Our Certificate of Registration demonstrates that our Quality Management System meets the requirements of ISO 9001:2015, an internationally recognized standard of quality.
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