Uncertain FDA Expectations for Encryption Design
At a Glance
- Client: Multinational surgical robotics company
- Challenge: Uncertain FDA expectations for encryption architecture
- Solution: Architecture and encryption review, threat modeling workshops, SOPs & remediation plan
- Impact: Reduced regulatory uncertainty, avoided submission delays
Challenge
- Facing FDA 510(k) submission with encryption architecture
- Significant uncertainty about meeting FDA requirements
- Lacked confidence their approach aligned with FDA expectations
- Risk of costly submission delays, deficiency responses, or outright rejection
Details
Facing an upcoming FDA 510(k) submission, a multinational surgical robotics company confronted significant uncertainty about whether their encryption architecture would meet evolving FDA cybersecurity requirements. The team had invested substantially in their cryptographic design but lacked confidence that their approach aligned with FDA reviewer expectations. Without clear guidance on documentation requirements, key management protocols, and acceptable cryptographic implementations, the company risked costly submission delays, additional deficiency responses, or outright rejection—each outcome potentially delaying market entry by months and impacting competitive positioning.
Expert Architecture Review and Threat Modeling Workshops
At a Glance
- Comprehensive encryption architecture reviews with regulatory expertise
- Former FDA reviewers providing expert guidance
- Threat modeling workshops evaluating cryptographic design
- Tailored standard operating procedures (SOPs) for security management
- Prioritized remediation plan addressing submission risks
Encryption Architecture Review and Threat Modeling
Medcrypt conducted comprehensive encryption architecture reviews combining technical analysis with regulatory expertise from former FDA reviewers. Through structured threat modeling workshops, the team systematically evaluated the cryptographic design against FDA guidance, identifying specific areas requiring strengthening or additional documentation.
SOPs and Remediation Planning
Medcrypt developed tailored standard operating procedures (SOPs) for ongoing security management and created a prioritized remediation plan addressing submission risks before FDA review. The collaborative workshop approach ensured the client team understood not just what to fix, but why—building internal capability for future submissions while addressing immediate 510(k) requirements.
Submission Confidence and Regulatory Clarity
By combining technical expertise with regulatory insight from former FDA reviewers, Medcrypt eliminated submission uncertainty and strengthened the client's 510(k) readiness.
- Reduced regulatory uncertainty by clarifying FDA expectations for encryption design, key management, and cybersecurity documentation through expert guidance from former FDA reviewers and policy makers
- Identified critical improvements in cryptographic implementation and submission materials before FDA review, avoiding costly deficiency cycles and timeline delays
- Empowered internal team with clear understanding of regulatory requirements