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Insights from the Gens and Associates Executive Podcast with James Gianoutsos

By

Bethaney Lentz

August 12, 2024

4 min read

Rimsys Founder & CEO, James Gianoutsos, was recently a guest on the Gens and Associates Podcast, a series dedicated to regulatory trends, topics, and insights from industry thought leaders. During the interview, James and Gens and Associates Managing Partner, Steve Gens, shared their unique founding stories and discussed digital transformation in the medtech industry.

One particular aspect James and Steve discussed is the role of AI in medtech regulatory affairs. Historically, the medtech industry has lagged behind pharma in digital adoption by 10-15 years. As the medtech industry takes on digital transformation initiatives, some medtech companies pursue AI solutions first. Through his extensive experience helping medtech companies embrace and adopt digital change, James states the importance of starting with efficient regulatory information management. Listen to the full interview to learn why setting a proper data foundation is critical to leveraging AI successfully along with: 

  • How AI will evolve in medtech regulatory affairs
  • The importance of data governance in medtech digital transformation
  • Why partnering with a medtech-focused RIM provider like Rimsys is essential for a successful transformation
  • What's next on the Rimsys product roadmap as the company enters its next phase of growth, including enhancements to Rimsys Intel

Find the full interview on the Gens and Associates website, Spotify and Apple.

We'd like to thank Gens and Associates for featuring James and for the opportunity for him to share his thoughts about medtech digital transformation with the Gens and Associates community!


About Gens and Associates

Gens and Associates is a boutique Life Science management and organizational consultancy specializing in strategic planning and roadmap development, industry benchmarking, regulatory information management, organizational transition management, and working with leadership and project teams to accelerate change and value realization. Learn more on the Gens and Associates website.


TRANSCRIPT: 

Steve Gens: Welcome to the gens, an associates executive podcast series where I have one-on-one conversations with leading executives that represent the Regulatory software and services sector, to learn more about how their organizations are supporting, and more importantly innovating this space. So, Steve gens here, managing partner of Gens and Associates today, I'm happy to be speaking with James Gianoutsos, founder and CEO of Rimsys. So welcome, James, I've been looking forward to this conversation and, you know, as we have this executive series, it's kind of rare to have a founder, you know, founding Gens and Associates in 2005, seemed like a very risky proposition and it's different when you're founding something versus just being a CEO of existing organization. So, before we get started with Rimsys being a fairly new company, I think you were founded in 2017. Could you give our listers a brief history of Rimsys and yourself and how you support the me tech sector?  

James Gianoutsos: Yeah, absolutely. And before I start off, just thanks for having myself on board and being a presenter here. And yeah, for everybody who does not understand the med tech arena or know Rimsys, my name is James Gianoutsos on founder and CEO of Rimsys. And I've spent the last 17 plus years in the Regulatory and quality industry.

And so I started my career at Philips and worked for several small and medium sized medtech manufacturers. I've had, the experience of actually managing global Regulatory operations, doing global submissions, moving 600,000,000 dollar manufacturing locations under consent decrees in the midst of the EU MDR and I VDR transitions. And so I've also had a really nice breadth, of medtech background as well, medtech product background, I should say all the way from c- pap devices to internal surgical adhesives even on the consumer side such as pacifiers, incubators, you name it.  

I've really had a really diverse in broad experience level with medtech itself. And so back in 2017, I was actually working for a small medtech manufacturer. And fortunately, unfortunately, I was laid off of that position. It was something that I know that there's a lot of medtech manufacturers that are kind of doing the same thing in this year last year, I should say. And… and it was, you know, that would happen on May 31, 2017, at noon and I started Rimsys at 1 PM that same day. It was just something that I've always had in the back of my mind's something that I always wanted to pursue.  

And really looking at the landscape back then there were only pharmaceutical RIM providers on the market. And so there was nothing really catered to, the medtech industry. Medtech and pharma aren’t uniform and aren’t just worlds but universes apart in terms of regulatory complexity, how you get products to market, how you maintain those products on the market and just the regulatory pathways and workflows around that. And so really started my endeavor hiring a couple developers offshore.

And, and to your point, you know, it's definitely different to be a founder than just a CEO because you're so heavily invested and so heavily involved that's you know, over the last five to six years… seven years is to say it's been a really cool experience to be personally involved with this development and working with the largest tech manufacturers in the world to help develop our solution and improve the regulatory workflows. So at the end of the day, they can get the products to market faster and keep those products on the market.  

Steve Gens: Excellent. So thank you so much for that good introduction. And then again from one founder to another, I still remember I had a fold up desk in a spare room with a laptop, my cell phone, you know, one customer, one contract and, you know, we're starting our twentieth year and have over 100 global customers. Like, I could never imagine back then where it would be but, you start someplace, you have a vision, you see a need, you go after it. You, you just get the best team around you and you just do it. So, so congratulations, you had a very successful lift off, and that's where I'd like to start.

I know when we first got introduced and started covering you about four years ago. And, I think it's on your website too is, you know, that context because again, we support both the biopharmaceutical and tech and they are very different although there's growing combinational products, right? So they're starting to be a little worrying, but there they are two different worlds or universes. Kind of in your case, you know, I know you say, yeah, we build this by Regulatory affairs, you know, professionals, there's a better way to do this. And also like the other terminology that a lot of people use big words like transformation and all that. But in Regulatory, it's a major monetization and simplification. And I know on the medtech outside, organizationally you know, they tend to be a lot more distributed design center. So in some ways you have a different set of complexity. So we've been tracking you for about four years now, we've watched your growth. We get those regular annual updates, but I think one thing our customers would really be interested in is, you know, why do your customers pick Rimsys? You know, what differentiates you from, the competition?  

James Gianoutsos: Yeah, there's a lot to unpack from that question. And I'm, happy to dive in a little bit more to it. You know, one of the primary things that we do and understand is the medtech industry period. And so from day one, you know, this is why our company exists to support medtech. There's you know, the whole thesis around Rimsys around our solution and our product, in the industry historically medtech is 10 to 15 years behind pharma from a digital transformation standpoint.  

Medtech has been undergoing this digital transit initiative over the last several years and since then, we've really taken off because especially at the enterprise level standpoint, and the complexity around the workflows, the understanding of how the, in relation between the data elements of not just, you know, regulatory information, but of how the products are associated to those registrations to certificates to really all the entire Regulatory product life cycle really differentiates us because, we understand, those nuances better than anybody in the industry period.  

You know, we've a we've had a lot of success because it feels like, the pharma industry is kind of waking up to it. We've actually seen some pharma companies try to come into medtech and actually failed miserably because, you know, I would say with 100 percent conviction that nobody wants a pharma RIM with the medtech label slapped onto it. And what allows us to be successful in that is that we partner deeply with our enterprise customers to understand those nuances, and we're adaptable to those changing regulatory needs. We are a relatively young company. But we are broadly and vastly experienced in that med tech space. And so that's really been one of our competitive advantages is just understanding the space like nobody else.  

And you mentioned combination products and what's really unique about medtech is that, you know, combination products at the end of the day are a drug coded stint or some type of prefilled syringe, those are a medical device. And based on the primary mode of action, some other items that are typically more medtech forward devices. And so that creates an interesting opportunity for Rimsys because, you know, drugs are drugs at the end of the day, it might have different dosages, but the varying aspects of where that do can be put into the system or put into your system. I should say… your body is vast and a lot of those have or need a medical device to deliver that.

And so, the variations and complexity around that makes for Rimsys to be at the forefront and leader of that combination product standpoint. And a lot of our customers have actually adopted Rimsys even more heavily because of that, not just on the medtech side but on combination side.  

Another interesting item that we're seeing is that we are also because medtech as it is so vast and so complicated and complex from the workflows. You know, we're product centric and that has the adjacent categories as well where you can go into veterinary biocides, biologics consumer side combination because at the end of the day, the framework in the structure is generally the same. However, the regulatory pathways might be different. And so, that bodes well with our client base because a medical device manufacturers product portfolio, is ever-changing but also becoming more broad in nature as it expands itself into its new markets.  

Steve Gens: Yeah. Thanks for that overview. And I've been taking some notes on that. And I've seen kind of on the biopharmaceutical side, some of the RIM providers, hey, we should do medtech and, you know how I maybe I'm looking at this naive is like in the biopharmaceutical generics, you know, it's more of a data paradigm where, your life is an engineering paradigm and as opposed to like one to one with the health ministry or the health authority, you could have one to many in each country, right?  

James Gianoutsos: Precisely.  

Steve Gens: In your submission, so it's that extra kind of permutation if you will of complexity and maybe another podcast, maybe we'll do later on too. I was just thinking about, you brought up the stint in earlier in my career. I think, you know, I was a Johnson and Johnson guy and one day, you know, one of the pharma scientists was, you know, talking with one of the device scientists and they came up with a stint that must be like 20 years ago. But maybe another conversation, just the emergence of software as a device. You know, that's a big interesting topic. But that's venture on a little bit more so.  

And I know we talked about this kind of, the other day, you know, about monetization of regulatory systems and processes. And there's such an intense focus. The big word this day is AI, right? But there's AI and automation, and sometimes people confuse, the two. What's Rimsys doing as far as helping your customers, and maybe just in the very near term. So maybe tactical things we're you're doing either with AI or automation or the combination. And what does the longer term look like?

James Gianoutsos: Yeah, it's a great question. And to your point, I think there's a couple items that, I specifically want to address there because at the end of the day, you know, AI, is this thing that's being used from a marketing standpoint or just from a general industry standpoint in general, right? And it's this idea that these systems or software solutions can help do the work for you. Not, you know, it's not gonna take anybody's job, but there are ways that it can definitely help make you more efficient.  

You know, what's particularly interesting in the medtech digital digitalization transformation initiative that's going on right now is that, you know, medtech in itself is 10 to 15 years behind the times period. And so especially with these large enterprise level companies. And so, when you're in a horse and buggy, which is what the med tech industry is today. And we're trying to get into a spacecraft, of course, I think, the logical and the initial item in thinking is that, okay, we can just go straight to AI, but really at the end of the day AI is only as good as the data that is trained on.  

And… phase one of the company has always been the information management period of medtech in the organization. In getting that, right, we've invested so much time and money and collaboration with our partners of how product attributes, UDI attributes, regulatory… attributes. And how all of that plays well and interlays with one another because if you don't get that fundamental framework, you're gonna have a hard time. You might do some really interesting things with AI, but you're gonna have a hard time keeping that information organized in the manner that you will need to have it organized to do things later on.

And so, what's really been interesting is that we're about complete with our phase one of the company, meaning that the information and organization and complex workflows have a majority of that has been addressed, meaning that we have now reached this pinnacle where we're gonna go into phase two of Rimsys.  

Pase two has really been in and is all about the Intelligence. And so if you think about everything we've done in the phase one of the company where it's the information management, the we're call it the data layer. Now, we're entering the phase two, we're now we can overlay intelligence and market information directly over that data layer, so you can do some really fun and interesting and innovative things with that data. And so from an AI standpoint, we actually have some things coming down the pipeline at the end of this year, early next year, that's really going to help one with data ingestion in our system.  

You know, we have companies that have 300,000 products and 249 countries globally and that's just one company, right? And so there are some really interesting things we can do with data ingestion and data maintenance from our standpoint. But also there's some really interesting things we're gonna do with market intelligence notifications of, you know, regulatory changes in the market as well as some things that are coming through with submissions as well. And, and we have a really nice road map played out that in the next six to 12 months that it'll be, it's gonna be really cool to see some of those things come to fruition here.  

Steve Gens: Yeah. There's there's a lot. I just took a lot of notes on that on this and just a few comments I think, you know, for our listeners too, just another layer of complexity between, the med tech and pharmaceutical is, besides the things you've mentioned, I've mentioned, you know, you're dealing with a class one, two or three, you know, device. So like the one client with, you know, all those products. It's kind of reminds me of the consumer side and JNJ, it's like you have Tylenol as a product but you have so many variations then different names of it in so many different countries, mind explodes just trying to manage the label.  

You know on that, I think the other thing on the probably where you guys are more ahead on the medtech side is there's this nirvana of embedded reg intel, you know, where, you know, the reg intel actually directs the workflow you know, as opposed to, the user based on whatever regulatory activity you're working on. If you're doing a renewal in Thailand, for example, it has the reg intel and it knows what to do so.  

The same thing too, some people are scared of AI is going to replace, you know, my job, but I think you know, more and more people realize it's a virtual assistant or a writing assistant where the AI might do the first version, one of a document, you know, the boring stuff. And then the expert medical writer would actually take it, you know, with their scientific knowledge.  

And the last thing I wanted to comment to because we just finished up our very large study, you know, with AI, it's only as good as the data we've proved out. And I don't know how much of an issue. It is just like having the highest level of data quality and regulatory, but, you know, a lot of folks on the biopharmaceutical side, it's like well, you know, should we enter it centrally, decentralize, hybrid at that time? How the data is entered into data quality where that is not linked. We've proved it out that having those really good data quality practices, the data governance, have that in place and that's a direct correlation.  We call those the data assets, you know. And then there's a shiny activity. If you have the right skills and the right KPI, you put those four together. And that's where the magic happens, right?  

So, the last question, and actually from founder to founder, you had the sparkle in your eye when you thought about this and you actually pulled the trigger. So instead of, you know, kind of having the CEO voice, but from the founder's voice, what excites you most about Rimsys in the coming years. So, where is the company going?  

James Gianoutsos: It's such a loaded question because I feel like there's so many amazing things to do. I mean, we're still at the beginning of this whole thing. And my mind has been going since, you know, 10 years ago when I first arrived this, you know, to 2017 when I first started putting… pen to paper.  

And, you know, having all these tools and things that I wish I had when I was in industry would have been absolutely amazing not just from a jobs perspective standpoint, but from the company perspective standpoint because the things that regulatory does has a direct impact on the revenue as well as getting those products to market for the patients need the most and maintain those products on the market for the patients that need in the most. And so, there's a high degree of vested interest to get those products and keep those products on the market as a regulatory professional, honestly just as a human being.

And so, the things that I'm excited for are the new Rimsys Intel that we're gonna be continuing to advance here in the next six to nine months. And there's gonna be some, really exciting things, that I think there's some new adjacent product regulatory life cycle items that we can get into. So, there's always the premarket, on-market, and post-market. And we really haven't even touched post-market yet. We've really been concentrating on the on-market and premarket aspects of things and especially getting UDI right. Because at the end of the day, those udi attributes are needed for a lot of the post-market activities that are on gonna be a regulatory requirement or already a regulatory requirement.  

But then two, from a reporting standpoint,  you're gonna need to maintain those products in the market. And so, there's this continuum of information management that we're gonna be continuing to do and gather, and address, and then, the layering on top of that Rimsys, Intel is absolutely gonna be a game changer because nobody really does RIM like Rimsys, and, you know, we've had the luxury of building this from the ground up specifically dedicated to the medtech industry. And that has so many more advantages than trying to, reposition or retransform an existing system to medtech because it just, it doesn't translate. And so, I'm really excited, for some of those aspects.  

Steve Gens: Yes, indeed. You know, a very exciting, and also just an amazing journey in just seven years. So, and it seems like it's a very bright future, you know, for you. So, so thanks again for your time, you know, some very Rich and insightful discussions, you know, and it's great with our listeners and some of them are many of them are biopharmaceutical, you know, learning a little bit more about the med tech side.  

But in the lens and why I thought this was so important and we kind of touched on it just the growing a portfolio of combination products - It's just really merging our latest data. Had 60 percent of the companies with their product portfolios have combination products. So that's something that's growing. So certainly listeners, if you're on the biopharmaceutical side, you know, maybe you have combo products or a device division, you know, definitely give them a look. Yeah. So as we kind of, you know, close up, some of our listeners might want to get a hold of you. So what's, the best way to contact you? I don't know if it's through the website or LinkedIn or, what would you suggest?  

James Gianoutsos: Yeah, I would say definitely get our website: www.rimsys.io. You can schedule a demo and you can actually just put a Linkedin request to me directly. I love talking shop. I love talking specifically around regulatory complexities and some of the issues that you're experiencing firsthand because at the end of the day, those help continue to expand our system capabilities and serve, the medtech market. You know, one of the things that I'm really proud of with Rimsys is, you know, we already have 40 percent of the top 10 medical device manufacturers globally and we're expanding more. And this is a really exciting time for the industry as well, as well as, for Rimsys as we enter into this new phase of growth.

Steve Gens: Excellent. And, you know, indeed. And I think, you shared, you know, the other day, well name of another very impressive logo thatat you're gonna be starting to work with there. So before I say goodbye to the listeners, you know, we're both fouders and have that in common. But I would be remiss here. Maybe this is more for us listeners that you're based in Pittsburgh, Pennsylvania. I grew up in central Pennsylvania. So it's the black and gold. I know we talk about the Pittsburgh steelers, the, you know, NFL football seasons about ready to kick off. So hopefully the black and gold, the Pittsburgh steelers are gonna do well. I know we another thing that we have in common. Yeah.  

So with that said with our listeners, if there's any questions you have for the Gens team use our contact page off of our website or similarly just reach out, I'm on Linkedin quite a bit and please enjoy our other podcasts. We actually just reorganized our whole podcast web page to have a section for this executive series, our world class RIM research, and then a third as we have different subject matter experts, really talking in detail about some of the key issues that industry works on today. So again, James, thanks a lot for your time and maybe in another six or nine months, we'll have you come back and see where yourself and Rimsys are at.  

James Gianoutsos: Sounds great. Thank you.


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MedTech

Nonconformance reporting for medical device manufacturers

By

Wendy Levine

March 30, 2023

4 min read

Defining nonconformance

Very simply, a nonconformance occurs when a specification is not met. The FDA defines a specification in 21 CFR 820.3 as “any requirement with which a product, process, service, or other activity must conform,” and ISO 13485:2016 as a “need or expectation that is stated, generally implied, or obligatory.”

While managing nonconformance starts with fully defining specifications; it is the identification, tracking, and resolution of nonconformance that is a focus of medtech quality and regulatory teams and a requirement of both ISO 13485:2016 and the FDA’s 21 CFR Part 820 quality system regulation.  

Identifying nonconformance occurrences

As part of a compliant quality system, medical device manufacturers should implement procedures to identify and address both major and minor non-conformances. Nonconformances may be identified through processes found in multiple subsystems that are part of an overall quality management system within the organization.

The systems and subsystems in which nonconformances are identified typically include:

  • ERP
  • Regulatory information management (RIM)
  • Product lifecycle management (PLM)
  • Document management
  • Customer service / customer management  
  • Complaint handling
  • Device history records
  • Audit management
  • CAPA
  • Training/learning management  
  • Calibration/preventative maintenance
  • Development change management

Evaluating nonconformance

Once a nonconformance is identified, it should be evaluated in a timely manner, and a determination made as to the disposition of any affected products. Requirements for additional investigation and reporting should also be identified. Based on the severity of the nonconformance and its effect on the safety and efficacy of devices being manufactured or already in the market, a CAPA (corrective/preventative action) record may need to be created. In the U.S., this is defined in the quality regulation 21 CFR Part 820.100.

To disposition a nonconformance, consider the following:

  • Will the existing system detect the nonconformance if it recurs in time for remediation?
  • How likely is it that this issue will recur?
  • What is the impact of the non-conformance (i.e., could it affect patient health)?

Issues that are more severe or are more likely to recur should trigger a more immediate and comprehensive response.

Nonconformances that are escalated and handled under CAPA are based on risk and can include those that have or could have an impact on a product or process that is:

  • Not easily corrected
  • Recurring
  • Severe

In addition, nonconformances that rise to the level of a CAPA require significant resources and typically result in a full project to identify root cause(s), containment, and corrective actions, and monitoring for effectiveness.  

Nonconformances that don’t require a CAPA have simpler resolutions that include documenting actions taken to correct the issue (or justification for no action). If the issue is not recurring, there may be no other action required. For example, a nonconforming material received from a vendor may be a singular issue that was easily identified through existing inspection procedures and is not expected to recur. In this case, the material is returned to the vendor and no additional action is required.

Processes that are out of conformance are often resolved through improved documentation and/or additional user training. However, be sure that the true root cause of the nonconformance is identified as procedural nonconformances can signal additional issues.

Documenting nonconformances

An important part of nonconformance procedures is the nonconformance report (NCR) or other documentation procedures.  Nonconformances are typically documented within the subsystem in which they were identified. Some organizations will have a nonconforming system in which issues originating from all subsystems are documented. Centralized nonconformance systems allow for trending and other analysis across all subsystems, the results of which may generate CAPAs.  

The requirements for documenting a nonconformance may vary by subsystem. In general, however, nonconformance documentation records:

  • The requirement/specification that was not met.
  • The objective evidence supporting the determination.
  • The action that is being taken to address the nonconformity.

Nonconformances are a common point of focus during quality audits by regulatory bodies, including the FDA, and should follow a well-documented process. Auditors will often try to determine if the quality system is functioning effectively by looking at self-identified nonconformances and comparing them to externally reported nonconformances. This is to ensure that nonconforming products were not released, or that the appropriate actions were taken to resolve issues in the field.

The importance of nonconformance reports

Nonconformances related to distributed products of higher risk result in nonconformance reports issued to government authorities through vigilance reporting, medical device reporting, and field action/recall reports. For example, the FDA requires that a medical device report be submitted within 30 days of a serious adverse event (see 21 CFR Part 803 Subpart E). Strong reporting procedures for nonconformances of all types are important in identifying trends, addressing issues before they become critical, and as part of a complete quality management system.

A nonconformance reporting procedure is only part of a strong quality system. Read An overview of 21 CFR part 820 and ISO 13485 overview for more information on establishing quality systems for medtech companies.

Company

Why we developed Rimsys from the ground up

By

Wendy Levine

May 26, 2022

4 min read

Rimsys has had quite a year already! In early December, we closed on $16 million in Series A financing and since then we have been carefully growing the company to better serve our customers and the regulatory affairs community. We have almost doubled our employee count and redesigned the Rimsys system to deliver deeper functionality that is even easier to use. We had our first in-person employee meeting here in Pittsburgh at the end of April where we introduced our new mission statement, and we are all excited to be doing our part to improve global health!

All of these changes made us think back to the founding of Rimsys and how far we have come. So - I sat down with Rimsys Founder and CEO, James Gianoutsos, to talk about the genesis of the company and how he knew that a new type of system designed for medtech regulatory affairs professionals was needed, and needed to be built from the ground up.

Q: What was the biggest challenge you faced as a regulatory professional that led you to form Rimsys?

James: The biggest challenge I saw while working at Philips for many years was completely understanding the complexity and the nuances around everything regulatory from a product standpoint. This really came to light whenever we acquired products. Just seeing firsthand how inefficient and out of compliance these manufacturers really were, and how hard it was from an administrative standpoint just to get into compliance and then to stay compliant, was striking. 

I was working with a smaller medical device company which had acquired products from Philips. Philips provided the company with a list (a color-coded Excel spreadsheet)  of all of their products that the company had acquired along with the registration status of those products globally. After digging into the spreadsheet for several months, we found that about 50% of it was wrong, incomplete, or just completely missing. The company was trying to keep track of registration information, but the available tools were making it nearly impossible. I realized that this was the challenge, and that there really wasn’t a solution on the market that could solve that problem in an easy manner and in a medtech regulatory-focused way.

Q: There were solutions on the market that were geared more towards the pharmaceutical industry, correct?

James: Yes. So I did what every other regulatory professional did, which was to Google “regulatory software,” and I saw that there just really wasn’t anything on the market that fit our needs. The solutions on the market really were pharma-specific, even those that said they worked with medical devices. The workflows and regulatory requirements for medtech are very specific for each market, depending on the product type and risk class and so many other factors. To use a pharma system that was already on the market  just wasn’t even an option because it was like comparing apples to oranges. It is completely different from the regulatory and workflow side of things.

Q: There are existing tools used by the regulatory community, such as quality management and document management systems. Did you envision the new RIM system integrating with existing tools, replacing them, or a little of both?  

James: I never set out to replace those types of systems, no. In fact, I knew that existing system architecture and infrastructure couldn’t handle the specific medtech regulatory workflows but needed to connect to those systems. There have always been PLM (Product Lifecycle Management) systems that contain a company’s product master data, but those systems were never meant to be workflow-driven based on regulatory requirements. At the same time, they are critical for organizing and maintaining product-specific metadata. Then there are ERP systems, which are really about making sure companies have sales flags (i.e. regulatory blocks) in place, appropriate shipping codes, or selling status linked to product registration status. Regulatory professionals are concerned about answering two questions for ERP users; one, “does the product have a valid and current registration within the country or market,” and two, “if it is registered, are we selling and shipping into that market.”  Lastly, quality/document management systems house critical documentation and records needed for registrations. The problem with these systems is that there are no regulatory workflows and no way to compile technical documentation, leaving the documents and records siloed from the regulatory filings.

To do the things that a regulatory affairs professional, in a critical regulatory department, does for their company, the system really had to be built from the ground up with all of these systems in mind. It had to be product-centric. It had to integrate with all these other sources of information, because there really wasn’t a common connection point between your products, your documentation, and the records that you needed to compile and how that relates to getting products on the market. We had no way to communicate to our other systems that a product is actually available for sale in that market or that it confidently can, or more importantly cannot, ship to that market.

Q: What was the most difficult piece of functionality to implement in Rimsys?  

James: Well, at the time it kind of all seemed difficult! No, really the most difficult part was thinking thoughtfully and strategically about how data was going to be mapped and used in conjunction with other data elements, in order to make the system most helpful from a user perspective. We wanted to single-source information to enhance and streamline regulatory workflows, but then also make sure that it was as user friendly as possible. There are a lot of stakeholders that need information or have input into regulatory workflows. Quality assurance, marketing operations, R&D, engineering, sales - all of those specific stakeholders need to view information in a way that is understandable to them.

We worked hard to bring all that information, streamline complex regulatory workflows, and all of those internal and external data sources together in an understandable and user-friendly way.

Q: How important has the technology itself been in the creation of Rimsys?

James: Technology has been a huge advantage for us from day one. Our team had quality and regulatory backgrounds, so we knew what companies would expect from us. We knew we had to be 21 CFR Part 11 compliant. We knew we had to be ISO 27001 certified. We knew we had to have SOC2 Type 2 reports. We knew we had to integrate with a company’s existing IT infrastructure. We really had to build this thing from the ground up on a GxP compliant platform that we could build upon and expand, without having to go back and reinvent the wheel every time we added new functionality. 

It’s continued to pay dividends for us because it was something that we thought about from the beginning and that gave us a lot of flexibility. We already had the system and infrastructure in place that we could then expand upon a lot more quickly than we would have been able to otherwise. It’s like the difference between building a house today and trying to remodel a house that was built in the year 1900. If you break down a wall in the older house, there might be so many hidden issues behind that wall - load bearing issues, knob and tube wiring, asbestos, etc. With new modern infrastructure, it is just night and day in terms of adapting quickly with changing regulations and a fast-paced market.

Q: Was there any specific technology you can talk about that became important to the development of Rimsys?

James: Our choice of technology was driven by our desire to build a system that was user friendly and built on a modern infrastructure that felt familiar to our users. So, we took a lot of the Google framework to build an application that didn’t look like enterprise software, but looked and felt more like a consumer product that is inviting, not overwhelming. 

The other thing is that we built the system from day one to integrate because we knew we had to connect with a lot of different sources of information. We strategically built the system with API’s in mind.

Q: What is Rimsys doing differently than other software companies in the regulatory space?

James: We are creating a holistic solution, which is different from what is out there now. We know that registration management is just one key aspect of what regulatory affairs teams need. In order to create a proper regulatory system, we had to take into account all of the data and dependencies and build a system specifically for medtech regulatory teams and other key consumers of regulatory data. There has to be a single source of truth for this data, because otherwise it becomes a nightmare at the end of the day. Existing software solutions were siloed and purpose-built for other industry needs, such as eQMS, PLM and ERP. None of those systems can do what a holistic RIM platform can do. Because of the complex workflows, the regulatory needs are far too broad and interdependent, that data infrastructure is completely different, data sources are too numerous, and the systems offer limited support to bring everyone and everything together into a cohesive, streamlined, compliant and medtech-specific solution.

Another key component of what we are doing is to institutionalize regulatory knowledge and resources into Rimsys—this is at the heart of who we are and what we do. Having the only purpose-built, holistic RIM platform built by and for regulatory professionals specific for the medtech industry really couldn’t be done without internalizing that experience within our own team.

Q: What are you most proud of when it comes to Rimsys? 

James: I think there are two things that immediately come to mind. Having our Rimsys 5 platform launch is really exciting. This is the fifth iteration of our platform, and we did it by listening to our customers and iterating over and over again to get it right. We had to go back to the drawing board a couple of times, not because what we had written wasn’t working, but because our customers that were using the system every day gave us better ways to do things. Rimsys 5 is a really proud moment because this is the platform that we are taking into the future, that will let us get to the next level where we are truly empowering regulatory professionals to make critical decisions and do the job that they are meant to do. 

The ability for us to listen to our customers, take that feedback and move fast is the second thing I’d mention here. We know that this has to be a validated system, but we are able to make changes and add features in a way that is thoughtful and gets our customers what they need right away. Regulatory professionals are very particular. I know since I am one, and making sure they are comfortable using Rimsys from day 1 is critically important. Being a customer-centric company really makes our experience as a team extremely rewarding.

Q: Where is Rimsys going next?  What are you most excited about?

I think I am most excited about Rimsys being an advocate for the medtech regulatory community and helping them wherever we can. Regulatory has a seat at the table now and it is a great feeling to see that we’re able to help these companies to streamline their workflows, accelerate time to delivery for life-saving products and maintain that compliance to keep those products on the market. Regulatory affairs is a mission critical department that the medtech industry cannot underestimate. It’s empowering because while we are helping our customers, they are helping us and every single one of our other customers through the journey of regulatory uncertainty that everyone is going through right now. It feels like a real partnership between us, our customers, and the industry as a whole and I am excited to see where that will take us.

I am also really excited about where we are going with regulatory intelligence. We are just scratching the surface of this now, but you will see regulatory intelligence data built into Rimsys and providing RA professionals with tools that can really provide a competitive advantage for their company. The release of Rimsys 5 platform (“Phase 1”) provides us that platform that will take us into “Phase 2” of Rimsys, with embedded intelligence that will further empower regulatory professionals to make decisive, correct and confident decisions for their products and their company.

MedTech

Your eSTAR submission questions answered by FDA experts

By

Bruce McKean

September 8, 2023

4 min read

Your eSTAR submission questions answered

Starting on October 1, 2023, all 510(k) submissions, unless exempted, will need to be submitted electronically using eSTAR. eSTAR, which is short for Electronic Submission Template and Resource, is a dynamic PDF submission template that contains automation, guides, integrated databases, integrated policies and procedures, and automatic verification to help users prepare a comprehensive medical device submission.

Rimsys recently hosted a webinar, eSTAR submissions overview and live Q&A with FDA, to help the medtech community prepare for the quickly approaching eSTAR deadline. Patrick Axtell, Assistant Director for Tools and Templates Team, and Sajjad Syed, Software Engineer for Tools and Templates Team, from FDA joined our panel of Rimsys regulatory experts to provide an overview of eSTAR, demo, and live question and answer session. If you're interested in watching the webinar replay, you can find it here.

Due to high participation, we couldn't answer all questions live. This blog post provides Patrick's and Sajjad's answers to questions we couldn't get to during the webinar. Read below to learn what other industry professionals want to know about eSTAR!

Q: In the past, the sections were numbered Section 10 - Device Description.  How should section(s) be numbered in the eSTAR?

You may number attachments how you prefer, this includes numbering attachments according to the previous section numbers of the Format for Traditional and Abbreviated guidance document.  However, the numbering hierarchy in the IMDRF documents, which the attachment questions in eSTAR correlate to, may be better, since that numbering scheme is internationally harmonized.  So for example, if you are using the nIVD eSTAR, the IMDRF document specifies the Comprehensive Device Description would be numbered 2.04.01: https://www.imdrf.org/sites/default/files/docs/imdrf/final/technical/imdrf-tech-190321-nivd-dma-toc-n9.pdf.

Q: After October 1, 2023, will the In Vitro Diagnostics eSTAR Version be acceptable to use for a Dual 510(k) and CLIA Waiver by Application (Dual Submission)?

Yes, the next IVD eSTAR update will fully support Dual submissions, and the workaround we were previously implementing will no longer be needed. CLIA waiver submissions will continue to be submitted via current methods, and are not required to use eSTAR after Oct 1, 2023.

Q. It is not possible to view eSTAR online from cloud storage platforms. eSTAR like IFU Form and CDRH Form cannot be viewed online without users downloading these files. I will highly appreciate if  someone from the panel can give a solution to this. I understand these are special pre-programmed PDFs but it will immensely help if these can be shared for online viewing without having users download these files.

You need to choose to open eSTAR in the default application from within the cloud application you use, you can’t just click on it, since it will open in the browser, and browsers can’t open dynamic PDFs like eSTAR, Form 3881, Form 3514, and other forms FDA uses.

We can’t say that all cloud applications will work, but using Box does work. Once eSTAR is loaded in, click on the three dots, then choose the application you have installed, see screenshots below. I have Adobe Acrobat 2017 and Adobe Acrobat Pro both installed.

Be aware that every time you save the form, you upload it back into the cloud, so depending on how large it is and how fast your internet connection is, it may take many seconds to save each time, though you will see a progress bar.

Q: Does the eSTAR submission need to be submitted by only the US Agent or can this be done by the Foreign Manufacturer?

510(k) eSTARs, like 510(k) eCopies, can be submitted by foreign applicants.

Q: Will it be mandatory to use the eStar template for PMA supplement submissions?

Yes, by the end of 2023, eSTAR for PMA will be released. Similar to eSTAR for 510(k), there will be a pilot, guidance, and a transition period before it becomes mandatory.

Q: When do you expect to release the next version or sub-version of the non-IVD eSTAR template (4.x or 5.0) and will it be more elaborate on cybersecurity?

We are at the mercy of updating when policies are updated, which is irregular and unpredictable. Please email CDRH management and recommend a more consistent (e.g. quarterly) policy deployment schedule so that eSTAR can also have a more predictable deployment schedule. We are updating approximately one to every two months currently. Please be sure to read the Version History on page 1 of eSTAR regarding versioning and which version to use.

Q: How should a device categorized as a breathing gas pathway device in accordance with ISO 18562 be handled in eSTAR? One cannot find ISO 18562 categorization for a device in the eSTAR form.

This is a regulatory and policy question, and we are not sure what is meant by the statement “be handled.” Please reach out to OPEQ Submission Support OPEQSubmissionSupport@fda.hhs.gov with this question and they will direct your question appropriately.

Q: How often does FDA anticipate revising the eSTAR form?

eSTAR updates are almost exclusively timed according to policy updates, which the Tools and Templates Team has no control over. The T&T Team, as well as other groups in CDRH, are pushing for a quarterly update, where any policy updates in a quarter have an implementation date set for the beginning of the next quarter (e.g. Oct 1st, Jan 1st, Apr 1st). Please email Center management and promote this.

Q: The guidance Format for Traditional and Abbreviated 510(k)s: Guidance for Industry and FDA staff recommends a specific format for submissions. Biocompatibility, for example, is section 15. Should attachments in the eSTAR submission cross-reference the sections cited in the guidance? (So still using biocompatibility as an example, attachment 15.1 would be Cytotoxicity, attachment 15.2 would be Sensitization and so on)

The Format guidance, as well as the eCopy guidance, RTA guidance, and many other guidances, no longer apply for eSTARs.  Eliminating the applicability of guidances - simplifying the preparation process - is something we are proud of doing. You do not need to follow the numbering of this guidance.  See response above, where we recommend using the IMDRF numbering scheme instead, which is internationally harmonized.

Q: Where is information for risk assessments and management best included?

Depending on the type of submission you have selected (e.g. 510(k), De Novo, then Traditional, Special, Abbreviated), certain sections will become visible and active and some of them will be disabled. However, the bookmark pane will show all the sections in the entire eSTAR. Hence, please fill the sections that are visible to you since they are based on your selections. For example, if you have selected a Traditional 510k, the “Benefits, Risks and Mitigation Measures” section is not applicable. Hence it is not displayed and clicking on it leads a user back to the first page of the eSTAR. However, if you select “Special” as the 510k you are submitting, the “Benefits, Risks and Mitigation Measures” section does become applicable, and is displayed if you click on the bookmark. Also note that if you select De Novo, the section does become active as well. Another point to note is that for a Traditional 510(k) submission, if you do want to submit a Risks, Mitigations, Benefits report, you can attach it in the Performance Testing --> Bench Testing section of the eSTAR and identify it as “Other Non-Clinical Evidence”.

Q: Under Biocompatibility any idea when there will be endpoint questions for hemocompatibility or coagulation?

Hemocompatibility endpoint information, including Hemolysis, Complement Activation, and Thrombogenicity information, will appear depending on the tissue contact type and duration you choose. If you choose Implant Device >30 days, you will see this tab appear for example. The tabs that show are based on our Biocompatibility guidance.

Q: Guidance and Special Controls Adherence Section: According to the 510(k) electronic submission guidance document, identification of any applicable device-specific guidance documents or special controls should be included, which was done in the past; however, eSTAR requires each specific special control regulation or guidance recommendation to be listed. Can you please specify to what level of detail needs to be included within this section? The text box contains a character limitation, so it is unclear how specific information needs to be.

There are four textboxes like this in eSTAR. The specifications, characteristics, etc., of the device should not be provided in these textboxes. Instead, these textboxes should be used to refer to the attachments where these controls or recommendations are found, per each specific recommendation. These textboxes do expand as text is typed in, if needed. Keep in mind that the special controls, device-specific guidance citations would be divided among these four textboxes.

Q: Why are Advertisements included within the Labeling section, when they should be considered promotional materials? Could reference to advertisements be removed from this section?

Advertisements and promotional materials are included under the Other Labeling, and within the sub-attachment type "Other Labeling and promotional material" since this is consistent with Internationally harmonized document N9 and N13.  As the help text states, whether you actually need to attach it at all (it is an optional attachment) is dependent on the jurisdiction. For FDA, you would need to reach out regarding your device and current policy at opeqsubmissionsupport@fda.hhs.gov.

Q: I need to know how eSTAR would promote efficiency.

There are many efficiency gains with eSTAR, this is not an exhaustive list. The eSTAR website also includes some of this information.

-eSTAR complements the reviewer's internal smart review template used to review the submission (i.e. the questions correlate).  Therefore the reviewer is getting what they are expecting

-eSTAR provides a standardized format so that the reviewer (and applicant) always know where to find certain information

-eSTAR auto-updates many aspects of the submission, most notably it ensures the content is present negating the need for an RTA review by the reviewer, and therefore RTA holds

-eSTAR autocompletes information that you enter, ensuring you never need to enter the same information twice

-eSTAR includes built-in databases that ensure you see the information pertinent to your device (e.g. device-specific guidances), classification information automation, and the standards database, for auto-filling standards info accurately

-eSTAR has many forms built in, so that you don’t need to attach or upload them (e.g. T&A statement, Form 3514, 510(k) Summary, Declaration of Conformity, Form 3881)

-eSTAR guides the applicant through what is needed throughout, ensuring we collect everything that needs to be provided, and you know how to do it correctly

-eSTAR is collecting submission data in a structured format, which will help automate many aspects of our processing.  This will provide applicants and reviewers many benefits (e.g. automating the submission log-in process, therefore permitting reviewers to receive a submission within minutes of when the submission is uploaded in the CDRH Portal)

-eSTAR is intended to be used as a resource also, since it consolidates all the information needed (e.g., regulation links, guidance links, submission process information) to prepare a submission

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