We understand how quickly the security landscape is changing, and how important it is to your business and patients to ensure the maximum probability of regulatory approval. Our team of FDA analysts, medical device experts, and cybersecurity engineers are here to help.
The expertise of MedCrypt's specialists can pinpoint gaps and develop a targeted plan to address issues, guaranteeing that the submission meets all requirements for acceptance.
For MDMs who do not pass the FDA Filing Readiness Survey or face an FDA refusal, MedCrypt's experts can help identify gaps and create a prioritized plan to rectify issues, ensuring the submission becomes acceptable.
Our expert threat modeling identifies and reduces security issues that impact your FDA readiness and getting your device to market on time.
In the event of an FDA hold letter, MedCrypt provides immediate guidance to navigate the response process effectively.
Designed for MDMs with submissions either already under FDA review or planned for the near future, this service offers a comprehensive review using MedCrypt's unique five-sector framework (review of threat modeling, post-market management, vulnerability management, security risk assessment, and SBOM processes and outcomes) to ensure cybersecurity compliance
Take a free assessment to gauge your submission readiness with questions aligned with the latest FDA expectations.
You need to start working on your remediation plan today to avoid any unexpected delays. The FDA will issue its final guidance in September. As of October 1, 2023, the FDA will start sending RTA (Refuse to Accept) responses to any medical device manufacturers who have not submitted the requisite strategy and documentation to show that their device is secure today and that they have a plan to maintain that security throughout the lifecycle of the device.
The FDA is moving forward with its authority under the new section 524B of the FD&C act. This means that it is now a requirement for medical device manufacturers to:
Just because a 16 year old gets their license, doesn’t mean they’re a good driver. Just because you passed a FDA submission today, doesn’t mean your security strategy is set up to reach your next milestone.
Using MedCrypt provides a unique advantage for your company and product’s lifecycle regardless of the milestones you have already reached or plan on tackling in the near future. Having a healthcare specific, proactive security solution that scales and supports devices as they’re deployed from design through post-market, reduces costs and technical debt in the future.
Being proactive and choosing to lead with quality through MedCrypt’s products can keep your company not only prepared for your next submission or release, but ahead of changing regulatory requirements.
According to the FDA:
Check the FDA medical device cybersecurity FAQS for more information.
This was pulled from the FDA's Cybersecurity in Medical Devices - Frequently Asked Questions on October 12, 2023:
As provided by the Omnibus, the cybersecurity requirements do not apply to an application or submission submitted to the Food and Drug Administration (FDA) before March 29, 2023. If a cyber device was previously authorized, and the manufacturer is making a change to the device that requires premarket review by the agency, the law would apply for the new premarket submission.
Beginning on October 1, 2023, the FDA expects that sponsors of cyber devices will have had sufficient time to prepare premarket submissions that contain information required by section 524B of the FD&C Act, and the FDA may RTA premarket submissions that do not.
Medcrypt expert tip:
There are some exceptions that you should be aware of:
1) If there is a change to your device that warrants a new pre-market submission (510(k)) or if you have a Class III device, almost all changes must be reviewed. If those changes are not reviewed, all changes must still be reported annually.
2) Post-market requirements for risk management all apply from a Quality System perspective. If you don't follow the guidance in how you manage risk, we strongly suggest that you should. Regardless, you still are required per 820 and 806 (corrections and removals) to deal with post-market issues, to which the post-market guidance applies.
Check the FDA Refuse to Accept Policy for 510s for more information.
Medcrypt’s own FDA expert, Naomi Schwartz, discusses what the new policy means for medical device manufacturers (MDMs) like you.
Watch the webinarGet your secure medical devices to market on or even ahead of schedule, with peace of mind.