Medical Device Regulatory Compliance
Regulated development and commercialization journeys where clinical, quality, and market access align.
Inside this journey
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Pre-Discovery
Align the room on outcomes, decision process, and constraints before deeper discovery.
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Stakeholder Alignment
Confirm decision roles, timelines, constraints, and success criteria across functions.
Alignment Questions
Start Here: The One Thing You Need Us to Know
- In one sentence, what is the single regulatory outcome you most urgently need from this project?
- What is the device type and its current regulatory classification?
- Which markets are you actively targeting with this submission?
- Why now—what event or deadline triggered you to start this engagement?
- How confident are you in the completeness of your current submission-ready package?
What Would a Six‑Month Delay Actually Cost You?
- If this submission were delayed by six months, what concrete business and regulatory consequences would you face?
- Which of the following impacts would be most damaging if delayed (pick the top two)?
- Have you ever experienced a multi‑month delay before? If yes, what caused it and how long did it take to recover?
- How does the leadership team feel about the risk of delay—are they anxious, resigned, or confident?
- On a scale from 1–5, how critical is meeting the current target date for commercial or contractual reasons?
Who Holds the Keys — and Who’s Left Out?
- Who are the decision‑makers that must sign off on regulatory strategy and final submissions?
- Which functional owners are typically consulted late (and cause hold‑ups)—QA, R&D, clinical, manufacturing, others?
- Who will be our primary point of contact day‑to‑day, and how much decision authority do they have?
- How aligned are those stakeholders on timelines, acceptable risk, and required evidence—fully aligned, some disagreement, or deeply divided?
- When decisions stall, what usually causes the blockage—insufficient data, budget fights, conflicting priorities, or lack of reviewer perspective?
Where the Paperwork Trips You Up
- Which specific document or evidence do you most fear will be called out by a regulator?
- Which of these areas currently have clear gaps that would delay submission?
- Do you have recent test reports and device history readily accessible for reviewers to inspect?
- When you run a gap assessment today, how long does it take to produce an actionable remediation plan?
- Who on your team owns document quality and reviewer‑level storytelling (e.g., former-examiner review, structured arguments)?
If Reviewers Could Speak: The Unsaid Expectations
- What recurring comments or deficiency types have you seen from regulators in past submissions?
- Have you previously received an FDA deficiency letter or Notified Body nonconformity—what was the root cause and how long to resolve?
- How often do you conduct an internal 'reviewer perspective' pass before filing?
- Tell us about a submission that cleared quickly—what specifically made it successful?
- Which reviewer-side practices would you be most open to adopting (pick all that appeal)?
What Winning Actually Looks Like
- If this engagement results in a first-cycle clearance/approval, what measurable outcomes change for you in the next 12 months?
- Which of the following are required for you to call this project a success?
- What are your non-negotiable acceptance criteria for deliverables (e.g., evidence level, signing authority, or documentation standard)?
- How will your executive team measure and celebrate success—revenue, market share, risk reduction, or something else?
- Who needs to be present or briefed at key milestone gates for you to consider the project on track?
Tradeoffs: Time, Scope, Budget — Which Do You Give Up?
- If you had to trade one—time, scope, or budget—which would you be most willing to compromise on and why?
- What internal budget range have you allocated (or expect to allocate) for external regulatory support on this submission?
- Would you consider a phased engagement (strategy → docs → submission) to accelerate high‑risk items while deferring lower‑risk work?
- How tolerant is leadership of contingency spending if unexpected gaps appear?
- What would make you comfortable increasing budget to avoid a high‑probability delay?
Let’s Talk Execution — Who Will Do What, and When?
- What keeps projects slipping in the handoff from strategy to execution at your company?
- Which delivery model do you prefer for external support?
- Who will be responsible for providing artifacts and arranging tests—internal RA, QA, R&D, or a mix?
- What cadence of governance and updates do you expect (weekly touchpoint, biweekly steering, monthly executive review)?
- Are there systems or platforms we must use to share documents (e.g., your QMS, VDR, or preferred project tool)? If yes, please name them.
Final Check: Red Flags and Next Steps
- Before we proceed, what is the single biggest unknown that would make you pause on this engagement?
- Which regulatory changes or external forces are you most worried could impact this submission while we work on it?
- How soon would you be ready to proceed if we presented a clear plan and fixed deliverables?
- Would you authorize a rapid gap assessment to give us a candid first-pass view of submission risk and a remediation estimate?
- Who should receive our summary findings and proposed next steps once the gap assessment is complete?
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Current State Mapping
Document existing regulatory posture, active submissions, resource gaps, and failure modes.
Current State
Start Here: Where You Really Stand
- Briefly describe the device(s) or product family this engagement should cover (intended use, device class, and key features).
- Which regulatory markets and pathways are you actively pursuing right now?
- What is the single current submission or activity stage for your priority product?
- How many active submissions or regulatory threads are you managing concurrently for this product family?
- Who on your team will be the primary day-to-day contact for regulatory questions and deliverables?
- How long has your current regulatory strategy for this product been in place?
What's Keeping You Up at Night?
- If a regulator issued a deficiency letter tomorrow, what's the first shortcoming you suspect they'd call out?
- Which of these problems have shown up in past reviews or audits for your products?
- How many prior submissions for this product family received major objections, and what was the typical cause?
- When those issues happened, how long did it typically take to recover and resubmit?
- How does the risk of another rejection affect your launch timing and commercial plans (quantify if possible)?
- Tell us about the emotional or political pressure internally when a submission stalls—who feels it most and how does it manifest?
Which Single Failure Would Break the Chain?
- If you had to name one weakest link today (process, person, document, or supplier), what is it and why?
- How mature are your SOPs and change-control processes for submission-related activities?
- Where do delays most often originate: internal reviewers, testing vendors, suppliers, or agency back-and-forth?
- Do you maintain a shared traceability matrix that ties requirements → verification → risk controls → labeling? If yes, how current is it?
- How long does it typically take your team to implement a corrective action once an issue is identified?
Can You Produce the Papers in Two Weeks?
- Which of these key documents could you provide to a reviewer within two weeks in reviewer-ready form?
- For each of the following documents, select the status that best fits your current state: Design History File.
- Risk Management File status.
- Verification & Validation evidence status (test plans, protocols, reports).
- Clinical evidence / clinical evaluation status.
- Labeling, IFU, and marketing claims—are they aligned with your evidence and intended indications?
- If any document is 'missing' or 'partial', which one would cause the biggest reviewer concern and why?
Who Will Take the Heat?
- If regulators escalate an issue, whose role in your organization would be held accountable and why?
- Which stakeholders must sign off on submissions and who can approve rapid changes if needed?
- Do you have external consultants, testing labs, or notified bodies already engaged? List them and their responsibilities.
- How clear are roles and ownership between regulatory, QA, R&D, and clinical teams when a submission needs rapid remediation?
- When conflicts arise about submission content, what is your escalation path and how long does resolution usually take?
Which Deadline Would Stop Everything?
- Which upcoming regulatory deadline poses the largest risk to your market access or launch plans?
- How firm are those external timelines (agency windows, notified body schedules, clinical site availability)?
- What internal milestones must be hit to meet that external deadline (e.g., finalize V&V, complete clinical analysis)?
- Do you have resource coverage (people, budget, testing capacity) to meet the critical milestones in the next 90 days?
- If a deadline slips, what is the realistic delay impact on launch or market access (weeks/months/market loss)?
- Have you budgeted for contingency actions (e.g., additional testing, third-party reviewer time) if issues arise?
If Reviewers Signed Off First Time, What Changed?
- Imagine the reviewer accepted your submission on the first cycle—what would have been the single biggest change compared to today?
- What specific acceptance criteria or reviewer concerns would you want us to guarantee we address?
- Which measurable signals would tell you the submission is ready (e.g., complete traceability, 100% V&V coverage, clinical evidence threshold)?
- Who needs to explicitly approve the final package before filing (list names/titles)?
- Do you have prior submissions or reference packages we should model after? If yes, how similar are they?
- What would give your executive team confidence to greenlight a first-cycle filing?
What Can We Fix in 30 Days to Reduce Risk?
- If we focus on one high-impact mitigation over the next 30 days, what should it be (document, test, stakeholder alignment, or other)?
- How quickly can your team make subject-matter experts and documents available for an urgent gap assessment?
- Which of these quick actions would you be willing to commit to in the next month to lower failure risk?
- What communication cadence works best for rapid alignment (daily standup, twice-weekly sync, weekly checkpoint)?
- Who should we include in a 30-day rapid-response group (names/titles or functions)?
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Customer Discovery
Clarify target regulatory outcomes, critical deadlines, stakeholders, and success signals.
Discovery Questions
Opening: What's Top of Mind Right Now?
- Which submission or regulatory priority would you like us to focus on today?
- What is your current target date for filing or clearance/recertification?
- Who on your team is directly responsible for delivering this submission right now (name and role)?
- How confident are you that your existing materials could clear on a first review?
- Briefly list the top three known risks or open issues you already expect for this filing.
If This Slides, What Breaks for the Business?
- What would be the real business consequences if this submission were delayed by 6–12 months?
- Which specific markets or customer segments are most at risk if timing slips?
- Has your leadership modeled the financial impact of a delayed clearance (e.g., P&L or runway changes)?
- When you think about that potential delay, what keeps you up at night emotionally or strategically?
- Have you faced external pressure (investors, partners, distributors) tied to the regulatory timeline? If so, how urgent is that pressure?
Who’s Steering the Ship (Even When No One Says So)?
- Who will ultimately override technical recommendations and choose the regulatory path for this program?
- Please map the key approvers and influencers we should engage (name, role, and decision authority).
- How well-defined is your internal RACI for regulatory submissions right now?
- How do you prefer governance and status updates during a project?
- Are there recent reorganizations, resource constraints, or political dynamics that could affect timely signoff?
When Reviews Turn Down: Tell Me That Story
- Think of the most painful deficiency or rejection you've received — what specific reviewer concerns came up repeatedly?
- Which sections of your last rejected submission drew the heaviest scrutiny? (select all that apply)
- How long did remediation take and who led the remediation effort?
- What were the root causes — late test reports, unclear predicate, insufficient clinical evidence, QMS gaps, or something else?
- Would you be comfortable sharing the previous submission package with a reviewer-for-hire for a candid diagnostics session?
Imagine Perfect: Clearance on the First Pass
- If you could guarantee first-cycle acceptance, what would that let your team accomplish in the next 12 months?
- Which objective is highest priority after clearance?
- What measurable success metrics should we use to judge the project before the regulator responds (leading indicators)?
- What are your non-negotiable acceptance criteria for us to consider this engagement successful?
- Which stakeholder signals (internal or external) would let you feel confident mid-project that we’re on track?
What's Missing Under the Hood?
- Which unseen documentation or evidence gaps do you suspect are the root cause of late-stage surprises?
- Who owns the critical artifacts we may need to collect (test reports, risk files, clinical evidence, DMR/DHR)?
- Are your key test reports issued against the intended product configuration and lot numbers?
- Do you have a current traceability matrix that links requirements to verification and validation artifacts?
- How many external labs or vendors need to be coordinated for outstanding data, and what are their typical lead times?
- Would you be open to a rapid gap assessment where we review a priority subset of files and return a prioritized remediation plan within 7–10 business days?
Trade-offs and the Small Steps That Change Everything
- If you have to choose, which two matter most: speed to market, minimizing cost, or maximizing regulatory certainty — and why?
- What’s your preferred engagement model with external regulatory partners?
- What budget range have you allocated for external regulatory support on this project?
- How soon could you assemble a cross-functional kickoff with decision-makers present?
- What specific access, approvals, or artifacts would we need to start work within 7 days (e.g., NDA, system credentials, device samples, QMS records)?
- What governance cadence (meeting frequency, decision gates, executive check-ins) would keep this project from slipping?
Final Logistics: The Practical Things That Make or Break Us
- Who in your organization has the authority to sign contracts or commit the budget needed on the timeline you described?
- Do you require your legal team to review a master services agreement before kickoff?
- Which billing model do you prefer for regulatory engagements?
- Are there existing vendor agreements, exclusivity clauses, or conflict-of-interest issues we should know about?
- What is the single most important thing we should resolve in our first 7–10 days together to build trust and momentum?
- Any final questions, immediate red flags, or sensitive issues you want us to flag to leadership before we propose a plan?
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Solution Experience
Walk through how our reviewer-side expertise addresses the customer’s specific submission risks and timelines.
Experience Meetings
- Solution Experience Kickoff — Diagnosis & Alignment
- Reviewer-Side Risk Mapping — Live Gap Mapping
- Submission Timeline Simulation — Critical Path & Contingencies
- Evidence Review & Package Proof — Annotated Package Walkthrough
- Validation & Next Steps — Agreement on Acceptance Criteria
- Secure customer validation that the annotated approach and edits map to their product and internal needs.
- Customer to upload any missing supporting documents identified during mapping (e.g., test reports, labeling drafts) within 5 business days.
- Assign responsible SMEs for each gap area (risk, bench testing, clinical, labeling) and confirm contact details.
- Confirm timeline assumptions and constraints
- Produce a validated critical-path timeline with reviewer-driven accelerators and contingency buffers.
- Agree on milestone owners and SLAs required to meet target submission/clearance dates.
- Quantify expected time savings and reduced rework risk from the proposed approach.
- Seller to deliver a draft Gantt timeline and decision-tree scenarios showing time-to-clear projections within 2 business days.
- Customer to confirm resource availability and names for each milestone owner within 3 business days.
- Schedule weekly cadence meeting for timeline tracking during documentation and submission phases.
- Pre-check: confirm artifacts available for live review
- Demonstrate concrete, reviewer-annotated artifacts that would pass a reviewer pre-check.
- Produce a list of remaining evidence items and edits required to achieve an acceptance-ready package.
- Introductions & Meeting Objectives
- Seller to provide the annotated sample package and traceability matrix as a deliverable within 2 business days.
- Customer to deliver any missing test reports or clarify data gaps identified in the review within 5 business days.
- Assign an internal reviewer to reconcile seller annotations with internal QMS artifacts and report back.
- Recap: current state, consequence, future state
- Obtain explicit customer validation that the proposed approach will achieve the defined future state.
- Agree on the definition of done and formal acceptance criteria for submission readiness.
- Secure commitment to next steps, owners, and initial scheduling for the Solution Scope and Mutual Commit stages.
- Customer to provide formal sign-off (email or shared doc) on acceptance criteria and chosen timeline within 3 business days.
- Seller to prepare a draft Statement of Work / engagement plan that maps deliverables, phases, responsibilities, and acceptance criteria.
- Schedule the Solution Scope kickoff meeting and weekly governance cadence in the calendar.
- Produce and agree to a single-sentence current state describing the failure mode to be addressed.
- Quantify the consequence of not remediating the current state in time/cost/risk terms.
- Define a single-sentence future-state outcome that will be used as the success metric for the experience.
- Identify the focal submission(s), required artifacts, and owners for proof activities.
- Customer to provide prioritized submission list and deadline constraints (files or tracker) within 48 hours.
- Customer to assign a single owner for each prioritized submission who will be the point of contact for artifact delivery.
- Seller to prepare draft one-sentence problem/consequence/future-state statements and distribution before the next meeting.
- Recap of confirmed current state & consequence
- Produce a prioritized list of reviewer-facing gaps tied to specific artifacts and acceptance criteria.
- Identify which gaps are showstoppers vs. manageable risks and agree remediation priority.
- Validate that the consultant's assessment matches the customer's understanding and constraints.
- Seller to deliver an annotated reviewer checklist with highlighted gaps and suggested evidence types within 3 business days.
- Current State — one-sentence confirmation
- Annotated device description and claims mapping
- Critical path simulation — milestone walkthrough
- Reviewer acceptance criteria summary (tailored)
- Walk through acceptance criteria / Definition of Done
- Confirm remediation plan, timeline, and owners
- Scenario modeling: deficiency and accelerated-review cases
- Consequence — quantify impact
- Risk analysis and mitigation traceability
- Live gap mapping exercise
- Decision & commitment
- Failure-mode examples and precedence
- Test reports and acceptance criteria alignment
- Future State — one-sentence definition
- Mitigations, accelerators, and parallelization
- Immediate next steps and scheduling
- Agreement on milestones, owners, and SLAs
- Traceability matrix & package completeness check
- Immediate mitigations and sequencing
- Prioritization of Submissions & Constraints
- Validation checkpoint
- Pre-work & Data Requirements
- Validation: customer confirmation that annotated package meets expectations
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Solution Scope
Define deliverables, phases (strategy, documentation, submission), responsibilities, and acceptance criteria.
Scope Configuration
- Draft 510(k) Traditional Submission Package
- Prepare De Novo Classification Request Package
- Compile PMA Application Modules and Summaries
- Assemble EU MDR Technical File (Annex II/III)
- Author Clinical Evaluation Report (MDR) or CER
- Prepare Risk Management File (ISO 14971) and FMEA
- Draft Device Labeling and Instructions for Use
- Draft FDA deficiency responses and supplemental submissions
- Create Substantial Equivalence / Predicate Comparison Matrix
- Compile Design History File (DHF) and Device Master Record
- Prepare Post‑Market Surveillance Report and PMCF Study Reports
- Develop Q‑Submission / Notified Body Meeting Package and Slides
Scope Questions
Draft 510(k) Traditional Submission Package
- Do you intend to file a Traditional 510(k) for this device?
- What is the device classification and product code (if known)?
- Do you have an identified predicate device(s)?
- Which performance and bench tests are available or planned?
- What labeling/indications for use will be proposed (brief)?
- Who will prepare the submission documents (roles)?
- What is your target FDA submission date and any critical regulatory deadlines?
Prepare De Novo Classification Request Package
- Is De Novo being pursued because no predicate exists and the device is low-to-moderate risk?
- Describe the novel features or technologies that prevent predicate reliance (brief).
- Are non-clinical and/or clinical data available to support De Novo risk/benefit (select all applicable)?
- Have you completed a benefit-risk analysis or risk control justification for novel hazards?
- Do you require support drafting recommended special controls and proposed classification?
- Desired submission timeline and any planned pre-submission interactions?
- Any prior interactions with FDA about this device (e.g., Pre-Sub, informal feedback)? Provide dates/outcomes.
Compile PMA Application Modules and Summaries
- Is a PMA required or being considered due to high-risk classification or novel technology?
- Which PMA modules/data packages are available or planned (select all)?
- Are pivotal clinical study reports finalized and available for inclusion?
- Who will assemble the technical summaries and PMA administrative sections?
- Do you need expert review of statistical analyses and clinical endpoints?
- Target timeline for PMA submission and any PDUFA or business constraints?
- Are there any outstanding CAPA, inspection, or facility issues that could affect PMA acceptance?
Assemble EU MDR Technical File (Annex II/III)
- Is this file for CE marking under EU MDR (annex II/III) or for legacy MDD transition?
- Which parts of the technical file are complete or need work (select all)?
- Has a Notified Body been selected and do you have their guidance or NB audit history?
- Is the device software / AI component subject to specific MDCG guidance or state-of-the-art concerns?
- Are clinical data or equivalence claims required for conformity demonstration?
- Who will own document control and final sign-off for the technical file?
- Desired Notified Body submission timeframe and any market launch constraints (dates/countries)?
Author Clinical Evaluation Report (MDR) or CER
- Is a CER required or does an existing CER need an MDR-aligned update?
- What sources of clinical evidence are available (select all)?
- Has a literature search strategy been conducted and are search results available?
- Do you require gap analysis against MEDDEV/MDCG guidance and state-of-the-art?
- Who will perform the clinical appraisal and benefit-risk conclusions?
- What is the planned timeline to finalize the CER for submission?
- Are there any known clinical data quality or completeness issues that may affect acceptance?
Prepare Risk Management File (ISO 14971) and FMEA
- Is an ISO 14971-aligned Risk Management File already established?
- Which risk analyses are present or required (select all)?
- Are risk control measures and verification evidence documented?
- Who will be the designated risk management owner and signatory?
- Do you require risk acceptability criteria or benefit-risk justification development?
- Any specific hazards of concern (e.g., software failure, biocompatibility, sterility)?
- Target date to complete risk file and link to other deliverables (e.g., CER, technical file)?
Draft Device Labeling and Instructions for Use
- Do you require drafting of labels, IFU, and packaging artwork for regulatory review?
- Which markets/languages must labeling support (select all)?
- Are indications for use, contraindications, and warnings finalized?
- Will the labeling require reconciliation against a predicate or specific regulatory claims?
- Who will approve final artwork and label translations?
- Do you need human factors/usability validation input tied to IFU content?
- Deadline for finalized labeling before submission or product launch?
Draft FDA deficiency responses and supplemental submissions
- Are you responding to an active FDA deficiency letter or request for additional information (RAI)?
- What is the FDA's stated deficiency and the due date for response?
- Do you have data or analyses ready to address the deficiency (select all that apply)?
- Would you like a reviewer-style argument and executive summary to accompany responses?
- Who will be the authorized correspondent for submission of the response?
- Are there any expedited timelines or business impacts if response is delayed?
- Do you require draft review cycles and formal redlines prior to filing the response?
Create Substantial Equivalence / Predicate Comparison Matrix
- Do you need a predicate search and a formal substantial equivalence comparison matrix?
- How many candidate predicates are you evaluating?
- Which attributes should be compared (select all that apply)?
- Is there existing evidence of equivalence (bench or clinical) to predicates?
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Mutual Commit
Finalize commercial terms, timelines, governance, and acceptance criteria to proceed.
Agreement Modules
- Non-Disclosure Agreement (NDA)
- Master Services Agreement (MSA)
- Statement of Work (SOW)
- Pricing & Payment Schedule
- Project Timeline & Milestones
- Acceptance Criteria & Governance Plan
- Roles & Responsibilities Matrix
- Change Control & Scope Amendment
- Data Processing & Security Addendum (DPA)
- Regulatory Interaction Authorization
- Risk Allocation & Liability Terms
- Termination, Renewal & Wind-down
- Kickoff Authorization / Purchase Order
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Deployment
Operationalize rollout with readiness checks, enablement, and outcome validation.
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Pre-Deployment Readiness
Confirm data access, device documentation, test reports, and responsible owners are ready for execution.
Readiness Questions
Getting Comfortable Together
- Tell us the product name, primary intended use, and the exact markets you plan to submit to first (e.g., FDA 510(k), EU MDR, Health Canada).
- Which regulatory pathway(s) are you targeting for this submission?
- How would you describe the device risk/classification today?
- Who on your team will be our primary contact for technical questions, and who is the executive sponsor we should keep informed?
- Roughly how soon do you need the filing to be submitted or a clearance decision reached?
If We Filed Today, What Would Break?
- Imagine we hit 'submit' this afternoon — what critical item(s) would cause an immediate reject or major deficiency?
- Which specific test reports or protocols are incomplete, missing, or still in draft form?
- For any missing or draft items above, how long would it take to finalize them if prioritized?
- Have you ever received a regulatory deficiency or rejection on a related device or submission? If yes, briefly describe what triggered it.
- Which of these would you say is the single biggest risk to a first-cycle approval for this submission?
Who’s Holding the Keys — Access, Owners, and Backups
- Who currently holds primary custody of the device data, test artifacts, and design history (names and roles)?
- If that person were unavailable for two weeks, what would happen to review or approval tasks tied to the submission?
- Do you have account-level access (or intent to grant it) to the submission portals we’ll need (e.g., FDA ESG, EU Notified Body portals)?
- List the named owners for these domains and whether they are decision-makers or contributors: Regulatory, Quality, R&D/Engineering, Clinical, Manufacturing, Supply Chain.
- How mature is your internal RACI for submission tasks (file owner, reviewer, approver)?
Paper Trail or Wild West — Documentation, Traceability, and Version Control
- How confident are you that the documents we plan to include tell a single, defensible story from risk to verification to labeling?
- Which of the following documentation artifacts exist in final, approved form and are traceable to design inputs/outputs?
- If you use a document control system (e.g., QMS), name it and state whether external consultant accounts can be provisioned for read-only access.
- Are there known inconsistencies between versions of documents (e.g., specs vs. test protocols vs. labeling)? If so, pick the areas where inconsistencies are most likely.
- Would you be willing to let our former-examiner reviewers run a gap checklist against one key file (e.g., DHF or RMF) before we finalize the submission?
Where Timing Hides the Problems — Deadlines, Dependencies, and Lead Times
- What non-negotiable deadlines are driving this submission (e.g., product launch, contract milestones, regulatory transition dates)?
- Which dependencies are most at risk of slipping and would derail your timeline if delayed?
- How often do you update your internal timeline, and who owns that cadence?
- When a critical dependency slips, what is your usual mitigation — accelerate, scope down, push deadline, or add external resources?
- Are there upcoming external events (audits, clinical milestones, supplier changes) that could materially change the submission readiness in the next 60–120 days? Please list.
What Would Reviewer-Grade Acceptance Actually Look Like?
- If a reviewer with your target regulator opened the package, what are the three things you absolutely want them to say or see immediately?
- Which reviewer objections have you seen repeatedly across prior submissions or in your market segment?
- Would you like us to map a reviewer-expectations checklist to your submission and surface the top 5 must-fix items before finalization?
- Do you have prior communications with regulators (meeting minutes, deficiency letters, Q-Sub responses) we should incorporate into the package?
- Which acceptance criteria do you already use internally to sign off a package (e.g., traceability complete, test coverage 100%, clinical evidence threshold)? Please list or attach.
If First-Time Success Isn't Reality, What’s the Plan B?
- Be candid: do you have an internal resubmission playbook or SOP for responding to deficiency letters or NB review comments?
- If the regulator issues a major deficiency, who will lead the technical response and who approves the messaging?
- What is your acceptable tolerance for a delayed market entry (weeks/months) before leadership demands an alternative path?
- Which contingency options are you open to if key test data are unfavorable: additional testing, design changes, labeling restriction, clinical supplement, or market segmentation?
- What internal escalation path exists for urgent resource needs (budget, outside labs, executive sign-off)?
Final Check — What Would Make Us All Sleep Better?
- What are the top three outcomes that would make you consider this engagement an unqualified success?
- Which artifacts would you want returned as company-owned deliverables (editable DHF, trace matrix, test protocols, redline-ready submission)?
- How would you prefer we surface risks and progress during execution—weekly dashboard, twice-weekly calls, email summaries, or an on-platform shared workspace?
- If we begin with a focused pre-deployment gap assessment, are you prepared to grant access to one core artifact (choose one) for our reviewers to evaluate within 48–72 hours?
- Finally, what is the best way and time to schedule an initial 60–90 minute discovery workshop with your cross-functional team?
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Deployment Enablement
Schedule tasks, assign consultants and reviewers, and execute documentation and submission activities.
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Validation Checklist
Verify submission packages meet reviewer expectations and checklist acceptance before filing.
Validation Questions
Tell Me About Today (A Quick Picture)
- Which single submission or regulatory objective are we focusing on right now?
- Briefly describe the product and its intended use in one or two sentences (this helps us match reviewer experience).
- What is the current target filing date or regulatory milestone you're committed to?
- Who on your team is the day-to-day owner for this submission?
- What triggered this engagement—new product launch, audit/deficiency, legacy recertification, competitor pressure, or something else?
If This Goes Sideways, What Actually Breaks?
- Imagine the submission is rejected or delayed—what is the single biggest consequence for your organization?
- How often have similar submissions hit major issues in the past 24 months?
- Tell me about a past rejection or deficiency that mattered—what was the root cause and how long did remediation take?
- Which of these impacts would you rank as most urgent to avoid? (pick up to two)
- How does your leadership team quantify acceptable delay or risk—do you have a hard deadline tied to revenue, commercial agreements, or funding?
Who Really Decides (And Who Just Thinks They Do)?
- Who are the decision makers who must sign off before a filing goes out—and who tends to slow decisions down?
- How confident are you that each stakeholder understands the tradeoffs between speed, evidence, and risk?
- Describe a recent meeting where a regulatory decision was delayed—what information was missing and who pushed back?
- Do you have existing relationships or named contacts at the agency or notified body that can clarify expectations? If yes, who?
- Which governance rhythm best reflects how you make submission decisions today?
Where the Paperwork Breaks (and Why)
- If a senior reviewer opened your submission folder today, what three documents would give them the clearest picture—and are they final and available?
- Which of the following critical artifacts are incomplete, out-of-date, or missing?
- Walk me through the single biggest documentation gap you suspect exists and why it's been hard to close.
- How consistent are your templates and reviewer-facing narratives (e.g., summary of testing, rationale for predicate/clinical strategy)?
- Who owns the handoff between engineering, clinical, and regulatory documentation, and has that handoff failed before?
What Would a Reviewer Praise—and What Would They Flag?
- If you were inside the review office, what assumption about your submission would surprise you the most?
- Which reviewer comments have you seen repeatedly (from agency or notified body feedback) over the past two years?
- How often do you run internal 'reviewer eye' checks (i.e., ex-FDA reviewer walkthroughs) before filing?
- Describe one reviewer expectation you think you meet exceptionally well, and one you worry you don’t.
- Would you be open to a focused pre-submission review from an ex-reviewer to identify fatal flaws before filing?
What Does 'Success' Actually Feel Like for You?
- Beyond clearance or CE marking, what three business outcomes matter most for this submission?
- Which of these timelines would you describe as a true 'success' versus merely 'acceptable'?
- How will you know we’ve done our job—what are the acceptance criteria from your leadership and from the reviewers?
- What tradeoffs are you willing to accept to shorten the timeline—more testing, additional consultants, or higher commercial risk?
- What would immediate peace of mind look like after our first 30 days working together?
What's the Smallest Change That Would Save Months?
- If one focused intervention could remove the biggest bottleneck, which would you pick: a documentation overhaul, targeted testing, a reviewer-led gap assessment, or stakeholder alignment?
- What internal resources (people, test labs, budget) can you make available in the next 30 days to accelerate progress?
- What timeline does your leadership expect for a decision to engage outside help (i.e., commit budget and terms)?
- Are there contractual or procurement steps (legal reviews, PO approvals) that typically add weeks to starting an engagement?
- What would make you say 'yes' to a mutual commit today—fixed timeline certainty, a defined scope of deliverables, risk-sharing on outcomes, or something else?
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Success
Confirm regulatory outcomes, capture lessons, and maintain a shared channel for post-market issues and improvements.
Success Reviews
- Regulatory Outcome Review
- Lessons Learned / Post-Mortem
- Post‑Market Readiness & Handover
- Shared Channel & Governance Setup
- Executive Success Review & Commercial Closeout
Issues & Enhancements
- Welcome & Objectives
- Update product labeling and marketing hold status if required, and notify commercial teams.
- Set Purpose & Rules
- Produce a documented lessons-learned report with concrete, actionable recommendations.
- Identify root causes for the top 2–3 failures and agree corrective actions.
- Assign owners and timelines to improvement items and schedule a follow-up review.
- Draft the lessons-learned report with timeline, root causes, and recommended changes; circulate for comment.
- Create a prioritized improvement backlog in the shared workspace and assign owners.
- Schedule a three-month check-in to review progress on implemented improvements.
- Schedule training sessions on vigilance reporting and complaint triage for named owners.
- Handover Scope & Objectives
- Complete a formal handover of regulatory artifacts and data access to post-market owners.
- Confirm training needs and schedule required sessions for responsible teams.
- Agree monitoring cadence and KPIs for post-market safety and performance surveillance.
- Grant access permissions in the shared channel/repository to all post-market owners and confirm via checklist.
- Publish the post-market monitoring dashboard and share initial KPI baselines.
- Purpose & Scope of Channel
- Stand up a governed shared channel with clear structure, access rules, and SLAs.
- Agree the issue lifecycle and escalation flow so post-market events are handled consistently.
- Define pilot metrics and review cadence to validate channel effectiveness.
- Create the shared workspace and channel, set up initial folder structure, and invite core users.
- Publish the channel governance doc with roles, SLAs, and escalation flow to the workspace.
- Start the 30-day pilot and report baseline metrics at the pilot review.
- Executive Summary of Outcome
- Secure executive sign-off on regulatory outcome and commercial acceptance of deliverables.
- Decide whether to engage ongoing post-market support and agree next steps or contract amendments.
- Obtain permission to use the project as a reference or publish a joint case study where acceptable.
- Circulate the executive summary and obtain formal sign-off on acceptance criteria and any remaining commercial items.
- If agreed, draft a short retainer proposal for ongoing post-market support and circulate to executive sponsor.
- Confirm reference usage permissions and finalize approved messaging for any public materials.
- Formally confirm and document the regulator's decision and its operational implications.
- Identify and assign owners for all post-decision obligations and mitigation actions.
- Update the project timeline and market launch plan based on the regulator outcome.
- Upload signed regulator communications to the shared regulatory record and tag relevant stakeholders.
- Create a short-term mitigation plan for any conditional items with owners and due dates.
- Operational & Risk Overview
- Timeline Walkthrough
- Regulator Communication Summary
- Artifact & Data Access Review
- Platform & Structure
- Roles & Responsibilities
- Implications for Market Access
- What Went Well
- Commercial Deliverables & Acceptance
- Access, Roles & Permissions
- What Didn’t Go Well
- Communication Norms & SLAs
- Options for Ongoing Support
- Monitoring & KPIs
- Outstanding Conditions & Obligations
- Issue Lifecycle & Escalation Flow
- Training & Documentation
- Root Cause Analysis
- Reference & PR Permissions
- Risk & Mitigation Plan
- Escalation & Regulatory Reporting
- Prioritize Improvements
- Document & Record Updates
- Versioning, Retention & Audit Trail
- Decisions & Closeout Next Steps