Cybersecurity for Healthcare & Medical Device Manufacturers
FDA Compliance, Product Security & Risk-Centric Threat Modeling for Medical Devices, Equipment & Healthcare Products
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Patient Safety Begins in Product Development
When a medical device fails due to a cybersecurity vulnerability, patients can be harmed. Insulin pumps can be manipulated. Pacemakers can be disrupted. Imaging systems can be used as launchpads for hospital-wide ransomware attacks.
At VerSprite, we believe patient safety must be the primary consideration in medical device security -not just regulatory compliance, not just liability reduction, but genuine protection of the people who will depend on your products.
For over 20 years, we’ve partnered with some of the world’s largest healthcare manufacturers on product security. Our risk-centric PASTA methodology helps product teams identify the security risks that actually matter-clearing the path to market while building devices that healthcare organizations and patients can trust.
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The FDA Cybersecurity Landscape: 2025 and Beyond
The FDA’s June 2025 final guidance on “Cybersecurity in Medical Devices” represents a fundamental shift in how medical device security is regulated. Cybersecurity is no longer advisory-it’s enforceable.
Key Requirements Under Section 524B
Requirement |
What It Means |
|---|---|
| Reasonable Assurance of Cybersecurity | Manufacturers must demonstrate that cyber devices and related systems are cybersecure—not just safe and effective |
| Software Bill of Materials (SBOM) | Mandatory disclosure of all commercial, open-source, and off-the-shelf software components |
| Cybersecurity Management Plan | Plans and procedures to monitor, identify, disclose, and address vulnerabilities throughout the product lifecycle |
| Vulnerability Disclosure Timeline | Defined timelines for developing and releasing updates based on vulnerability criticality |
| Postmarket Monitoring | Ongoing obligations to monitor for and respond to cybersecurity risks throughout device lifecycle |
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What Qualifies as a “Cyber Device”
Under Section 524B, a cyber device is any device that:
- Includes software validated, installed, or authorized by the manufacturer
- Has the ability to connect to the internet
- Contains technological characteristics that could be vulnerable to cybersecurity threats
This broad definition means most modem medical devices are now subject to enforceable cybersecurity requirements.
Consequences of Non-Compliance
- Premarket submission denial – FDA may refuse to clear or approve devices with inadequate cybersecurity
- Substantial equivalence rejection – Devices with increased cyber risks vs. predicates may be found not substantially equivalent
- Postmarket enforcement-Violations classified as regulatory breaches under Section 301(q)
- False Claims Act exposure – Growing enforcement risk for misrepresentations about device cybersecurity
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How VerSprite Supports Medical Device Manufacturers
FDA Premarket Cybersecurity Documentation
The FDA expects 12 key cybersecurity documents in premarket submissions. We help manufacturers develop:
1. Threat Model
Comprehensive threat analysis aligned with PASTA methodology and FDA expectations
2. Cybersecurity Risk Assessment
Risk evaluation considering safety and security impacts
3. Security Architecture Views
Documentation of security controls and design decisions
4. SBOM
Complete software bill of materials meeting FDA format requirements
5. Vulnerability Analysis
Assessment of known vulnerabilities in device components
6. Unresolved Anomaly Documentation
Tracking of security issues and compensating controls
7. Security Testing Documentation
Evidence of security testing activities and results
8. Cybersecurity Management Plan
Postmarket vulnerability monitoring and response procedures
9. Customer Security Documentation
User guidance for secure deployment and operation
10. Labeling Content
Cybersecurity information for device labeling
11. Regulatory Correspondence
Responses to FDA cybersecurity questions
12. Lifecycle Support Plan
End-of-life and end-of-support planning
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PASTA Threat Modeling for Medical Devices
Our PASTA methodology is uniquely suited to medical device security because it:
- Starts with business and clinical context – Understanding how the device is used in care delivery
- Considers patient safety threats – Not just confidentiality, but risks to patient health and life
- Models realistic attack scenarios – Based on actual threat intelligence, not theoretical risks
- Produces FDA-aligned documentation – Outputs that satisfy regulatory expectations
- Prioritizes by impact – Helping product teams focus on risks that matter most
Sample PASTA Outputs for Medical Devices
Deliverable |
FDA Value |
|---|---|
| Attack Trees | Visual representation of threat scenarios for premarket submission |
| Threat Library | Cataloged threats specific to device type and use environment |
| Risk Quantification | Impact and likelihood ratings aligned with ISO 14971 |
| Control Mapping | Traceability between threats, risks, and mitigating controls |
| Residual Risk Analysis | Documentation of remaining risks and acceptance rationale |
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Product Security Across the Device Lifecycle
Design Phase Security
- Security requirements definition early in development
- Threat modeling integrated into design reviews
- Architecture guidance for secure-by-design approaches
- Component selection security considerations
Development Phase Security
- Secure coding practices and training
- SAST/DAST integration into development workflows
- Dependency management and SBOM generation
- Code review support for security-critical components
Verification & Validation
- Penetration testing of device software and firmware
- Fuzz testing for protocol and interface robustness
- Hardware security assessment where applicable
- Integration testing for connected device ecosystems
Premarket Submission Support
- Cybersecurity documentation preparation
- FDA Q-Sub meeting support for cybersecurity questions
- Reviewer question response assistance
- 510(k), De Novo, and PMA cybersecurity sections
Postmarket Security
- Vulnerability monitoring program development
- Coordinated disclosure process design
- Patch management strategy
- Customer communication procedures
- End-of-life planning
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Segments We Serve
Diagnostic & Imaging Equipment
- CT, MRI, X-ray, ultrasound systems
- Laboratory analyzers and diagnostics
- Point-of-care testing devices
- Digital pathology systems
Therapeutic Devices
- Infusion pumps and medication delivery
- Surgical robotics and navigation
- Radiation therapy systems
- Dialysis equipment
Patient Monitoring
- Vital signs monitors
- Telemetry systems
- Remote patient monitoring platforms
- Alarm management systems
Implantable Devices
- Cardiac rhythm management (pacemakers, ICDs)
- Neurostimulation devices
- Drug delivery implants
- Cochlear implants
Wearables & Consumer Health Devices
- Continuous glucose monitors
- Wearable ECG monitors
- Connected fitness devices
- Digital therapeutics
Software as a Medical Device (SaMD)
- Clinical decision support
- Diagnostic algorithms
- AI/ML-enabled diagnostics
- Companion applications
Healthcare Equipment & Apparel
- Hospital beds and furniture
- Surgical instruments
- Protective equipment
- Healthcare facility systems
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Addressing Residual Risk for Product Leaders
One of the most common challenges we see: product teams delayed at market by security findings they can’t fully remediate.
VerSprite’s risk-centric approach helps product leaders:
- Identify which risks actually matter – Not all vulnerabilities are created equal
- Develop defensible compensating controls -For risks that can’t be fully eliminated
- Build risk acceptance documentation -That satisfies FDA and legal/regulatory stakeholders
- Communicate residual risk clearly -To customers, regulators, and executive leadership
- Plan realistic remediation timelines -Aligned with product roadmaps and business needs
Our goal: help you get to market with products that are genuinely secure-not blocked by security findings that don’t represent real patient safety risks.
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Regulatory Framework Expertise
FDA Cybersecurity Guidance
- 2025 Final Guidance implementation
- Section 524B compliance
- Premarket submission requirements
- Postmarket management expectations
Standards & Frameworks
Standard |
Application |
|---|---|
| IEC 62443 | Industrial control system security for medical devices |
| AAMITIR57 | Medical device security risk management |
| AAMI SW96 | Medical device security-Security risk management for device manufacturers |
| ISO 14971 | Medical device risk management integration |
| ISO 27001 | Information security management systems |
| NISTCSF | Cybersecurity framework alignment |
International Requirements
- EU MDR cybersecurity requirements
- Health Canada guidance alignment
- IMDRF harmonization principles
- Japan PMDA expectations
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Why VerSprite for Medical Device Manufacturers
20+ Years of Healthcare Experience
We’ve been working with healthcare organizations and manufacturers since before the first FDA cybersecurity guidance existed. We’ve watched the regulatory landscape evolve and helped clients adapt at every stage.
Deep Product Security Expertise
Our team includes professionals with extensive experience in medical device development, embedded systems security, and FDA regulatory processes. We speak both security and regulatory fluently.
Risk-Centric Methodology
PASTA was designed to align security with business objectives-making it ideal for medical device environments where regulatory compliance, patient safety, and time-to-market must all be balanced.
Practical, Actionable Guidance
We understand that you can’t redesign your device to address every theoretical risk. We help you prioritize, develop compensating controls, and build documentation that supports defensible risk acceptance decisions.
Manufacturer-Trusted Partner
We’ve worked with some of the world’s largest healthcare manufacturers on their most critical products. We understand the pressure you’re under and the stakes involved.
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Get Your Device to Market Securely
Whether you’re preparing a premarket submission, responding to FDA cybersecurity questions, building a postmarket vulnerability management program, or addressing security findings that threaten your timeline, VerSprite can help.
Contact us
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Related Resources

PASTA Threat Modeling Methodology
Process for Attack Simulation and Threat Analysis Cybersecurity

Embedded Device Attack Surfaces
From printers to CPAP machines and even the cars we drive, Embedded devices are in constant use

Risk Centric Threat Models for IoT & Medical Devices
Focusing on IoT based medical devices and the overall importance of threat modeling

Application Threat Modeling
Helping Clients Learn & Build Risk-Based Threat Models
We’re Not a Vendor – We’re Your Security Partner
- Risk-centric security
- True extension of your team
- Executive-level experience