Question

Visit the web site of one of the following government agencies:

• Federal Drug Administration

Search the site for information about the agency’s standards related to information security. Study the information you find and draw some conclusions about it. How are the regulations presented? How easily can businesses access and follow these regulations? Summarize your findings in a brief report (06 - 08 pages)

Answer 1

All legally-marketed medical devices have benefits and risks. The FDA allows devices to be marketed when there is a reasonable assurance that the benefits to patients outweigh the risks.

Medical devices are increasingly connected to the Internet, hospital networks, and other medical devices to provide features that improve health care and increase the ability of health care providers to treat patients. These same features also increase the risk of potential cybersecurity threats. Medical devices, like other computer systems, can be vulnerable to security breaches, potentially impacting the safety and effectiveness of the device.

Threats and vulnerabilities cannot be eliminated; therefore, reducing cybersecurity risks is especially challenging. The heath care environment is complex, and manufacturers, hospitals, and facilities must work together to manage cybersecurity risks.

Mitigating Cybersecurity Risks

Medical device manufacturers (MDMs) and health care delivery organizations (HDOs) should take steps to ensure appropriate safeguards are in place.

• Medical device manufacturers (MDMs) are responsible for remaining vigilant about identifying risks and hazards associated with their medical devices, including risks related to cybersecurity.
• Health care delivery organizations (HDOs) should evaluate their network security and protect their hospital systems.
• Both MDMs and HDOs are responsible for putting appropriate mitigations in place to address patient safety risks and ensure proper device performance.

Cybersecurity Safety Communications

In each of the following cases, the FDA is not aware of any patient injuries or deaths associated with cybersecurity incidents, nor are we aware that any specific devices or systems in clinical use have been purposely targeted. However, left unpatched or otherwise mitigated, these vulnerabilities could allow unauthorized users to access, control, and issue commands to compromised devices, potentially leading to patient harm. Health care facilities can reduce the risk of unauthorized access by implementing recommendations in the safety communications listed below.

Date	Safety Communication	Description
03/03/2020	SweynTooth Cybersecurity Vulnerabilities May Affect Certain Medical Devices	The FDA is informing patients, health care providers, and manufacturers about the SweynTooth family of cybersecurity vulnerabilities, which may introduce risks for certain medical devices.
01/23/2020	Cybersecurity Vulnerabilities in Certain GE Healthcare Clinical Information Central Stations and Telemetry Servers	The FDA is raising awareness among health care providers and facility staff that cybersecurity vulnerabilities in certain GE Healthcare Clinical Information Central Stations and Telemetry Servers may introduce risks to patients while being monitored.
10/01/2019	Urgent/11 Cybersecurity Vulnerabilities May Introduce Risks During Use of Certain Medical Devices	The FDA is informing patients, health care providers and facility staff, and manufacturers about cybersecurity vulnerabilities for connected medical devices and health care networks that use certain communication software.
06/27/2019	Certain Medtronic MiniMed Insulin Pumps Have Potential Cybersecurity Risks: FDA Safety Communication	The FDA has become aware of potential cybersecurity risks in certain Medtronic MiniMed Paradigm insulin pumps. The FDA recommends patients replace affected pumps with models that are better equipped to protect them from these potential risks.
03/21/2019	Cybersecurity Vulnerabilities Affecting Medtronic Implantable Cardiac Devices, Programmers, and Home Monitors: FDA Safety Communication	The FDA became aware of cybersecurity vulnerabilities identified in a wireless telemetry technology used for communication between Medtronic's implantable cardiac devices, clinic programmers, and home monitors. The FDA recommends that health care providers and patients continue to use these devices as intended and follow device labeling.
10/11/2018	Cybersecurity Updates Affecting Medtronic Implantable Cardiac Device Programmers	Medtronic released a software update to address the cybersecurity vulnerabilities associated with Medtronic's cardiac implantable cardiac device programmers.
04/17/2018	Battery Performance Alert and Cybersecurity Firmware Updates for Certain Abbott (formerly St. Jude Medical) Implantable Cardiac Devices	Abbott released an additional firmware update to address premature battery depletion and confirmed cybersecurity vulnerabilities identified in Abbott's (formerly St. Jude Medical) implantable cardiac devices
08/29/2017	Firmware Update to Address Cybersecurity Vulnerabilities Identified in Abbott's (formerly St. Jude Medical's) Implantable Cardiac Pacemakers	Abbott released a firmware update to address cybersecurity vulnerabilities identified in Abbott's (formerly St. Jude Medical) implantable cardiac pacemakers. The firmware update continues Abbott's efforts to mitigate confirmed vulnerabilities discovered by an independent research firm in 2016.
01/09/2017	Cybersecurity Vulnerabilities Identified in St. Jude Medical's Implantable Cardiac Devices and Merlin@home Transmitter	The FDA became aware of cybersecurity vulnerabilities in these devices after an independent research firm released information about these vulnerabilities.
05/13/2015	LifeCare PCA3 and PCA5 Infusion Pump Systems by Hospira - Security VulnerabilitiesExternal Link Disclaimer	The FDA and Hospira became aware of cybersecurity vulnerabilities in these infusion systems after an independent researcher released information about these vulnerabilities. On July 31 2015, Hospira and an independent researcher confirmed that it is possible to access the Symbiq Infusion SystemExternal Link Disclaimer remotely through a hospital's network.
06/13/2013	Cybersecurity for Medical Devices and Hospital NetworksExternal Link Disclaimer	The FDA recommends that medical device manufacturers and health care facilities take steps to ensure that appropriate safeguards are in place to reduce the risk of device failure due to cyberattack.

To receive safety communications on medical devices, including cybersecurity-related safety communications, subscribe to our Medical Devices Safety and Recalls emails.

Reporting Cybersecurity Issues to the FDA

As a part of our surveillance of medical devices on the market, the FDA monitors reports of cybersecurity issues with devices.

• Manufacturers, Importers, and Device User Facilities: See Medical Device Reporting (MDR) for details on mandatory reporting requirements.
• Health care providers: Use the MedWatch voluntary report form for health professionals (Form 3500) to report a cybersecurity issue with a medical device.
• Patients and caregivers: Use the MedWatch voluntary report form for consumers/patients (Form 3500B) to report a cybersecurity issue with a medical device.

Memoranda of Understanding on Cybersecurity in Medical Devices

The table below provides an overview of the cybersecurity information sharing agreements that the FDA has with various stakeholders to help us further protect and promote the public health.

MOU/MOA	Parties	Description
MOU 225-18-028	National Health Information Sharing & Analysis Center, Inc. (NHISAC) and MediSAO (information sharing analysis organization)	The goal of these Information Sharing and Analysis Organizations (ISAOs) is to provide manufacturers with the opportunity to share information about potential vulnerabilities and emerging threats with the FDA and to help manufactures protect patients by addressing those issues earlier.
MOU 225-18-030	Health Information Sharing & Analysis Center, Inc. (H-ISAC), formerly known as the National Health Information Sharing & Analysis Center, Inc. (NH-ISAC), and Sensato Critical Infrastructure ISAO	The goal of these ISAOs is to provide manufacturers with the opportunity to share information about potential vulnerabilities and emerging threats with the FDA and to help manufacturers protect patients by addressing those issues earlier.
MOA: DHS-FDA Medical Device Cybersecurity Collaboration	Department of Homeland Security (DHS)	The agreement implements a framework for greater coordination and information sharing about potential or confirmed medical device cybersecurity vulnerabilities and threats. This collaboration between the two agencies is intended to lead to better and more timely responses to potential threats to patient safety.

Workshops and Webinars on Cybersecurity

Date	Topic	Purpose
09/10/2019	Patient Engagement Advisory Committee Meeting: Cybersecurity in Medical Devices - Communication That Empowers Patients	Provided background to the committee regarding the complexity of integrating medical device cybersecurity risk into health risk communications so that they can provide recommendations to the FDA on this topic. Committee provided recommendations that: address which factors should be considered by the FDA and industry when communicating cybersecurity risks to patients and to the public, including but not limited to the content, phrasing, the methods used to disseminate the message and the timing of that communication. address concerns patients have about changes to their devices to reduce cybersecurity risks as well as the role of other stakeholders such as health care providers in communicating cybersecurity risks to patients
01/29-30/2019	Public Workshop: Content of Premarket Submissions for Management of Cybersecurity in Medical Devices	Brought together diverse stakeholders to discuss, in-depth, the draft guidance, Content of Premarket Submissions for Management of Cybersecurity in Medical Devices and the sub-topic of the draft guidance regarding a Cybersecurity Bill of Materials (CBOM), which can be a critical element in identifying assets, threats, and vulnerabilities.
05/18-19/2017	Public Workshop: Cybersecurity of Medical Devices: A Regulatory Science Gap Analysis	Examined opportunities for FDA engagement with new and ongoing research; catalyzed collaboration among stakeholders to identify regulatory science challenges; discussed innovative strategies to address those challenges; and encouraged proactive development of analytical tools, processes, and best practices by the stakeholder community in order to strengthen medical device cybersecurity.
01/12/2017	Webinar: Postmarket Management of Cybersecurity in Medical Devices	Provided information about the guidance and opportunity to ask questions.
01/20-21/2016	Public Workshop, Moving Forward: Collaborative Approaches to Medical Device CybersecurityExternal Link Disclaimer	Highlighted past collaborative efforts and increased awareness of existing maturity models which are used to evaluate cybersecurity status, standards, and tools in development.
10/29/2014	Webinar: Content of Premarket Submissions for Management of Cybersecurity in Medical DevicesExternal Link Disclaimer	Provided information about the guidance and opportunity to ask questions.
10/21-22/2014	Public Workshop: Collaborative Approaches for Medical Device and Healthcare CybersecurityExternal Link Disclaimer	Encouraged collaboration among stakeholders, identified challenges and discussed strategies and best practices for promoting medical device cybersecurity.

Other Collaborations on Cybersecurity in Medical Devices

International Medical Device Regulators Forum (IMDRF): The FDA serves as a co-chair of the IMDRF working group tasked with drafting a global medical device cybersecurity guide. The purpose of the guide is to promote a globally harmonized approach to medical device cybersecurity that at a fundamental level ensures the safety and performance of medical devices while encouraging innovation. The guide is thus intended to provide medical device cybersecurity advice for stakeholders across the device lifecycle on topics including but not limited to medical device cybersecurity terminology, stakeholders' shared responsibility, and information sharing. The finalized guideExternal Link Disclaimer was published on March 18, 2020.

Healthcare and Public Health Sector Coordinating Council (HSCC): The FDA serves as a co-chair of the Government Coordinating Council (GCC) for the HPH HSCCExternal Link Disclaimer. Specifically, this is a public-private partnership among healthcare industry leaders and the government to address the most pressing security and resiliency challenges to the healthcare sector as a whole including cybersecurity. As a co-chair of a task group within the HSCC cybersecurity working group, the FDA participated in the development of the Medical Device and Health IT Joint Security Plan (JSP)External Link Disclaimer. The JSP is a total product lifecycle reference guide to developing, deploying and supporting cybersecure technology solutions in the health care environment.

MITRE and MDIC Threat Modeling Bootcamps: In 2020, the FDA funded a series of threat modeling bootcampsExternal Link Disclaimer, developed and hosted by MDIC and MITRE in partnership, to highlight the importance of threat modeling during the development, deployment, and maintenance of connected medical devices, and to provide training to industry representatives on threat modeling best practices and strategies. In addition to the bootcamps, the FDA has funded MDIC and MITRE to produce a threat modeling playbook that stakeholders throughout the sector may use to learn more about threat modeling best practices, and how to incorporate them into their own organizations and processes.

MITRE Corporation: In October 2018, the FDA supported the development of the MITRE Corporation's Medical Device Cybersecurity Regional Incident Preparedness and Response PlaybookExternal Link Disclaimer. The playbook describes the types of readiness activities that will enable health delivery organizations (HDOs) to be better prepared for a cybersecurity incident involving their medical devices and gives product developers more opportunity to address the potential for large scale, multi-patient impacts that may raise patient safety concerns.

Medical Device Innovation Consortium (MDIC): In September 2018, as a member of an MDIC Steering Committee, the FDA supported the development of an MDIC's report Medical Device Cybersecurity Report: Advancing Coordinated Vulnerability DisclosureExternal Link Disclaimer. The report encourages the adoption of coordinated vulnerability disclosure (CVD) policies by medical device manufacturers (MDMs) in an effort to promote medical device cybersecurity and patient safety. CVD policies establish formalized processes for obtaining cybersecurity vulnerability information, assessing vulnerabilities, developing remediation strategies, and disclosing the existence of vulnerabilities and remediation approaches to various stakeholders—often including peer companies, customers, government regulators, cybersecurity information sharing organizations, and the public. This report addresses the importance of CVD policies for MDMs and stakeholders across the medical device ecosystem.

Cybersecurity in the News

• FDA News Release: FDA Informs Patients, Providers and Manufacturers About Potential Cybersecurity Vulnerabilities in Certain Medical Devices with Bluetooth Low Energy (March 3, 2020)
• FDA News Release: FDA informs patients, providers and manufacturers about potential cybersecurity vulnerabilities for connected medical devices and health care networks that use certain communication software (October 1, 2019)
• FDA News Release: FDA warns patients and health care providers about potential cybersecurity concerns with certain Medtronic insulin pumps (June 27, 2019)
• FDA In Brief: FDA issues alert on potential premature battery depletion of certain Medtronic implantable pacemakers, approves related enhancements to device (May 7, 2019)
• FDA In Brief: FDA proposes updated cybersecurity recommendations to help ensure device manufacturers are adequately addressing evolving cybersecurity threats (October 17, 2018)
• FDA News Release: FDA and DHS increase coordination of responses to medical device cybersecurity threats under new partnership; a part of the two agencies' broader effort to protect patient safety (October 16, 2018)
• FDA In Brief: FDA warns patients, providers about cybersecurity concerns with certain Medtronic implantable cardiac devices (October 11, 2018)
• FDA Statement: FDA's efforts to strengthen the agency's medical device cybersecurity program as part of its mission to protect patients (October 1, 2018)
• FDA News Release: FDA outlines cybersecurity recommendations for medical device manufacturers (January 15, 2016)