Regulatory Open Forum

 View Only
  • 1.  MDSAP Pilot Program

    This message was posted by a user wishing to remain anonymous
    Posted 23-Mar-2020 09:12
    This message was posted by a user wishing to remain anonymous

    Hello all,
    Hoping you and yours remain safe and healthy!! I realize there are many more pressing concerns everyone is dealing with right now, so please excuse the "business as usual" question.

    The small med-tech (SaMD) company I work for has been struggling to understand whether the newly announced (Jan 2020) MDSAP Remote Pilot program can be applied for us due to Coronavirus concerns. (Our office is located in one of the US epicenters). Has anyone heard of this going forward yet?

    MDSAP AU P0036.001 Remote Auditing Pilot Program [fda.gov]  


  • 2.  RE: MDSAP Pilot Program

    Posted 23-Mar-2020 12:20
    I mostly flounder around in MDSAP, trying to make sense of things, but I would think that, the procedure having been published, it can go forward, and whether or not it does go forward depends on the AOs.  That is who I would ask.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 3.  RE: MDSAP Pilot Program

    Posted 23-Mar-2020 12:43
    Hi Anon,

    This is a good topic to bring up to get other members' current experiences as there is definitely some disruption happening in this space. The MDSAP procedure you posted is limited to remote auditing of only one chapter of the audit (Device Marketing Authorization and Facility Registration Process).  

    Our MDSAP surveillance audit is scheduled for Tuesday - Thursday of this week.  I was informed last week that the audit was switched to a remote audit.  It appears that each AO is creating a covid-19 mitigation plan, with some audits being delayed and some being done remotely. In my case, audits that were delayed are delayed until at least the end of May.  We're a small team with some employees quarantined working off-site that will be participating in the remote audit, remotely. It's going to be a unique experience!

    Definitely reach out to your AO to get their mitigation plan, determine if your upcoming audits will be affected and how you can begin to prepare for a remote audit.


    ------------------------------
    Brittany Gibson BSc
    Director, Quality and Regulatory Affairs
    Winnipeg MB
    Canada
    ------------------------------



  • 4.  RE: MDSAP Pilot Program

    Posted 23-Mar-2020 13:01
    Brittany, thanks for your considerably more informed response!   Please do come back and let us know how it went and any lessons learned that might be helpful for companies undergoing remote audits in the future.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: MDSAP Pilot Program

    This message was posted by a user wishing to remain anonymous
    Posted 27-Mar-2020 15:08
      |   view attached
    This message was posted by a user wishing to remain anonymous

    As a follow up to this, I wanted to share my company's experience in case it helps some of you going through a similar situation. Unfortunately the FDA confirmation was bad news for us - no remote audits for first Stage 2 certifications.

    Attachment(s)

    pdf
    MDSAP-Transmittal-AO-.pdf   55 KB 1 version