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Regulatory Affairs Excellence:
Staffing & Performance in Medical Device Companies




       Best Practices, LLC Strategic Benchmarking Research




                                                             BEST PRACTICES,   ®
                                                                                   LLC
TABLE OF CONTENTS
I.    Executive Summary
           Research Objective & Methodology
           Key Findings
           Participating Companies Demographics
II.   Respondent Background
           Respondent Demographics
           Regulatory Affairs Reporting Relationship
III. Regulatory Affairs Structure
           Functional Structure
           Corporate Regulatory Affairs FTEs
           Span of Control
IV. Regulatory Function Activities
           Active Regulatory Submissions
           2010 Filings
           Filing Trends
V. Regulatory Function Roles & Responsibilities
           Leading & Supporting Roles
           Corporate Regulatory Affairs Roles
           Storage, Publishing & Translation Solutions
VI. Regulatory Function Investment and Staffing
           2010 Spend & Staffing
           Future Resource Trends
VII. Regulatory Function Outsourcing and Offshoring Trends
           Regulatory Affairs Growth through Resource Efficiencies
VIII. Impact of 510(k) Reform
           Impact of Reform on Resources

                                                                      BEST PRACTICES,   ®
                                                                                            LLC
Research Background and Methodology
Best Practices, LLC conducted this benchmarking study to establish meaningful
benchmarks for the resource levels and the activities scope of the Regulatory Affairs
function for medical device companies.

  Background:
  With the monumental task of ensuring that companies comply with the plethora of global regulations
  and laws pertaining to developing and marketing medical device products, Regulatory Affairs groups
  must rely on their own internal effectiveness and efficiencies to remain productive. Optimal resourcing
  and staffing, including a balance of outsourcing and off-shoring, will help Regulatory Affairs in the
  Medical Technology industry prioritize roles and responsibilities that will be most beneficial to growth.

 Field Research & Insight Development:                                                  Objective:
  Surveyed eight leaders at eight medical device                             To uncover resource and activity




                                                                INFORM
   companies.                                                                 benchmarks as well as forward-
  Conducted three deep-dive executive interviews to                             looking insights about the
   collect qualitative insights from selected survey                           Regulatory Affairs function at
   participants.                                                                 medical device companies.


 Deep Dive Interview Questions:
  1.   What process improvement initiatives are you working on in the Regulatory Affairs function?
  2.   In what areas do lean processes already exist?
  3.   Which structure best supports Regulatory Affairs activities?
  4.   How do you approach outsourcing and off-shoring of Regulatory Affairs activities?
  5.   How do you expect Regulatory Affairs resources to change in response to reform?

                                                                                               BEST PRACTICES,
                                                          3                                                      ®
                                           Copyright © Best Practices, LLC                                          LLC
Universe of Learning: Eight Companies Engaged
Research participants included eight executives from eight medical device companies.
Three executives participated in deep-dive interviews. The key findings and insights are
based on qualitative and quantitative data from their knowledge and experiences.




       Participating Companies: Bausch & Lomb; Becton Dickinson; Boston Scientific;
            Edwards Lifesciences; Ethicon; Medtronic; Roche Diagnostics; Zimmer

                                                                        BEST PRACTICES,
                                                  4                                        ®
                                   Copyright © Best Practices, LLC                            LLC
Key Findings & Insights – 1/3
The following key findings and insights emerged from the data.




 Medical Device Revenue: The average medical device revenue is $7B for the benchmark
Medical Device Revenue: The average medical device revenue is $7B for the benchmark
 class. Half of the medical device revenue comes from U.S. sales.
class. Half of the medical device revenue comes from U.S. sales.
 Regulatory Affairs Reporting Relationship: For 38% of companies, the Regulatory Affairs
Regulatory Affairs Reporting Relationship: For 38% of companies, the Regulatory Affairs
 function reports to C-level management, or the highest level of senior management. For more
function reports to C-level management, or the highest level of senior management. For more
than one-third of companies, the Regulatory Affairs function reports into aacombined Quality
 than one-third of companies, the Regulatory Affairs function reports into combined Quality
 and Regulatory Affairs executive.
and Regulatory Affairs executive.
 Functional Structure: Most Regulatory Affairs functions are business unit centric with RA
Functional Structure: Most Regulatory Affairs functions are business unit centric with RA
employees reporting directly to the business unit they support. A hybrid approach - -one that
 employees reporting directly to the business unit they support. A hybrid approach one that
centralizes planning, information, and coordination, but not staff - -may help increase
 centralizes planning, information, and coordination, but not staff may help increase
 efficiency.
efficiency.
 Corporate Regulatory Affairs Groups: Corporate Regulatory Affairs groups average seven
Corporate Regulatory Affairs Groups: Corporate Regulatory Affairs groups average seven
 FTEs. The groups primarily promote standards, monitor the worldwide regulatory environment,
FTEs. The groups primarily promote standards, monitor the worldwide regulatory environment,
 coordinate internal and external policy advocacy efforts, and advise business unit Regulatory
coordinate internal and external policy advocacy efforts, and advise business unit Regulatory
 Affairs staff.
Affairs staff.


                                                                             BEST PRACTICES,
                                                    5                                           ®
                                     Copyright © Best Practices, LLC                               LLC
Medical Device Revenue Ranges from $1B to $16B
Medical device and technology companies of all sizes face regulatory changes and must
adapt resources to meet demand. Medical device revenue in the benchmark class averages
approximately $7B.

   Q2. Please estimate your company's 2010 annual revenue from medical device sales and related
 services. (Provide all cost figures in U.S. dollars. Use data from most recently completed fiscal year.)



                                                     Estimated Medical Device
                                                         Revenue ($USD):

                            Max                           $16,000,000,000
                            75th Percentile                $9,100,000,000
                            Mean                           $6,995,875,000
                            Median                         $5,950,000,000
                            25th Percentile                $3,565,000,000
                            Min                            $1,447,000,000



(n = 8)

                                                                                     BEST PRACTICES,
                                                        6                                               ®
                                         Copyright © Best Practices, LLC                                   LLC
Most RA Groups Support Corporate Headquarters
Given the importance of Regulatory Affairs to the overall success of a medical device
company, most Regulatory Affairs executives in the benchmark class support efforts at
corporate headquarters. Only 25% primarily support a specific business or operating unit,
which can be attributed to the existing corporate structures at those companies.
                   Q9. Which entity do you primarily support? (Choose one.)


                    A specific
                    business/
                  operating unit,
                       25%




                                                                       The corporate
                                                                       headquarters,
(n = 8)                                                                     75%

                                                                                       BEST PRACTICES,
                                                   7                                                     ®
                                    Copyright © Best Practices, LLC                                         LLC
Most Regulatory Affairs Structures Are BU-Centric
Nearly two-thirds of companies employ a business-unit-centric Regulatory Affairs
structure where RA employees report directly to the business unit or manufacturing site
they support, but also have informal reporting relationships ("dashed line reporting") to a
separate Regulatory hierarchy that ultimately reports to a senior Regulatory Affairs leader.
            Q12. How is Regulatory Affairs structured in your company? (Choose one.)


                                                                           Distributed
                               Other, 13%                                  Regulatory-
                                                                              centric
                                                                         Function: RA is
                                                                           a separate
                                                                             function
             Business-unit-                                              closely aligned
                  Centric                                                     with or
                Regulatory                                               distributed into
             Function: RA                                                  BUs and/or
                employees                                                   sites, 25%
             report directly
               to the BU or
             manufacturing
                 site they
              support, 63%                                               Other:
                                                                         •In transition from business centric
(n = 8)                                                                  to distributed RA centric

                                                                                     BEST PRACTICES,
                                                     8                                                          ®
                                      Copyright © Best Practices, LLC                                              LLC
Most File Regulatory Submissions in >50 Countries
In addition to U.S., EU, Japan and Canada, benchmarked companies file regulatory
submissions in 56 other countries on average. A seamless global IT solution for document
storage is critical to avoid reinventing the wheel for every submission.

Q18. Outside the US, EU, Japan and Canada, in how many additional countries does your company file
                            regulatory submissions for medical devices?



                                                   Number of Additional
                                                   Countries where Filing
                                                  Regulatory Submissions:
                          Max                                    100
                          75th Percentile                         60
                          Mean                                    56
                          Median                                  56
                          25th Percentile                         45
                          Min                                     24



(n = 7)

                                                                               BEST PRACTICES,
                                                     9                                           ®
                                      Copyright © Best Practices, LLC                               LLC
As with EU, Canadian Submissions are Less Taxing on RA
Resources
Canadian licensing costs are much lower per submission than for the U.S. or Japan,
although cost per submission is slightly higher than for the EU.

   Q17. Approximately how much is your Regulatory spend and how many Regulatory FTEs and
        Consultants do you have per each of the following active regulatory submissions?

                          Global RA Spend/                         Global RA FTEs/             Global RA Consultants/
                          Active Submission                       Active Submission              Active Submission
                                                                  Canadian        Canadian       Canadian      Canadian
                        Canadian            Canadian
                                                                  licenses -      licenses -     licenses -    licenses -
                   licenses - Class III licenses - Class II
                                                                  Class III &       Class II     Class III &     Class II
                      & IV devices:          devices:
                                                                 IV devices:       devices:     IV devices:     devices:
 Max                 $1,800,000            $340,000                 17.50           2.70           2.00          0.50
 75th Percentile      $249,251             $229,091                  1.67           1.73           0.21          0.15
 Mean                 $411,342             $162,966                  3.58           1.20           0.37          0.12
 Median               $213,333             $163,102                  1.49           0.93           0.06          0.02
 25th Percentile      $170,383              $84,457                  1.10           0.57           0.04          0.02
 Min                   $26,793              $10,563                  0.55           0.18           0.00          0.00
 (n =                      7                      7                    7               7             7             7)



                                                                                                    BEST PRACTICES,
                                                             10                                                             ®
                                               Copyright © Best Practices, LLC                                                 LLC
PMAs and IDEs Received Consultant Focus
PMAs (see previous slide) and IDEs had the highest Regulatory Consultant FTE levels.
Submission Consultant FTE levels are total RA Consultant FTEs divided by total number of
submissions for each category.
Approximately how many Consultant FTEs were involved in each of the following submissions in 2010?



                                                     Canadian
                                                                     Canadian       Investiga-
                        Japan        Japan Shonin licenses -         licenses -   tional Device    Design     Technical
                     Todokede           (approval    Class III &
                                      applications):
                                                                       Class II    Exemptions     dossiers:     files:
                    (notifications):                  Class IV
                                                                      devices:        (IDEs):
                                                      devices:

  Max                  2.00            5.00            0.40            4.00          4.00          2.00        2.00
  75th Percentile      0.82            0.42            0.19            0.16          1.54          1.50        0.53
  Mean                 0.57            1.01            0.15            0.73          1.13          0.86        0.51
  Median               0.15            0.23            0.12            0.10          0.40          0.40        0.27
  25th Percentile      0.10            0.14            0.02            0.04          0.22          0.30        0.11
  Min                  0.00            0.00            0.00            0.00          0.00          0.00        0.00
    (n =                 6               6               5                6              7            7           7)



                                                                                                    BEST PRACTICES,
                                                             11                                                           ®
                                               Copyright © Best Practices, LLC                                               LLC
RA Leads Submissions, Labeling, FDA Correspondence, and
Registrations
At all organizations, regulatory takes a lead role for filing submissions. Meanwhile, 75
percent of companies have regulatory leading interactions with the FDA on official
correspondence and listings/registrations.

 Q22. For the following responsibilities, does the Regulatory Affairs function lead, support, or play no
                              role? (Choose one role per responsibility.)

                                                                  No Role   Supporting Role    Leading Role
         Regulatory submissions to gain and/or
                                                                                  100%
                 market authorization
                          Labeling/publishing                 25%                        75%
                     FDA Official Correspondent           13% 13%                        75%

                  FDA Listings and Registration           13% 13%                        75%
      Field corrective actions: notification to
                                                          13%               50%                     38%
   regulatory agencies; and follow up reporting
      Responses to Notified Body Observations                               75%                        25%

              Responses to FDA warning letters                                88%                             13%

            Responses to FDA 483 observations                                 88%                             13%
    Audit support (FDA, Notified Bodies, all other
                                                                                  100%
                     agencies)
(n = 8) Complaint handling and MDR reporting                      38%                         63%

                                                                                              BEST PRACTICES,
                                                       12                                                           ®
                                         Copyright © Best Practices, LLC                                               LLC
About Best Practices, LLC

Best Practices, LLC is a research and consulting firm that conducts
work based on the simple yet profound principle that organizations
can chart a course to superior economic performance by studying
the best business practices, operating tactics and winning
                strategies of world-class companies.




                   Best Practices, LLC
      6350 Quadrangle Drive, Suite 200, Chapel Hill, NC 27517
                          919-403-0251
                bestpractices@best-in-class.com
                     www.best-in-class.com




                                                            BEST PRACTICES,   ®
                                                                                  LLC

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Regulatory Affairs Excellence: Staffing and Performance in Medical Device Companies

  • 1. Regulatory Affairs Excellence: Staffing & Performance in Medical Device Companies Best Practices, LLC Strategic Benchmarking Research BEST PRACTICES, ® LLC
  • 2. TABLE OF CONTENTS I. Executive Summary  Research Objective & Methodology  Key Findings  Participating Companies Demographics II. Respondent Background  Respondent Demographics  Regulatory Affairs Reporting Relationship III. Regulatory Affairs Structure  Functional Structure  Corporate Regulatory Affairs FTEs  Span of Control IV. Regulatory Function Activities  Active Regulatory Submissions  2010 Filings  Filing Trends V. Regulatory Function Roles & Responsibilities  Leading & Supporting Roles  Corporate Regulatory Affairs Roles  Storage, Publishing & Translation Solutions VI. Regulatory Function Investment and Staffing  2010 Spend & Staffing  Future Resource Trends VII. Regulatory Function Outsourcing and Offshoring Trends  Regulatory Affairs Growth through Resource Efficiencies VIII. Impact of 510(k) Reform  Impact of Reform on Resources BEST PRACTICES, ® LLC
  • 3. Research Background and Methodology Best Practices, LLC conducted this benchmarking study to establish meaningful benchmarks for the resource levels and the activities scope of the Regulatory Affairs function for medical device companies. Background: With the monumental task of ensuring that companies comply with the plethora of global regulations and laws pertaining to developing and marketing medical device products, Regulatory Affairs groups must rely on their own internal effectiveness and efficiencies to remain productive. Optimal resourcing and staffing, including a balance of outsourcing and off-shoring, will help Regulatory Affairs in the Medical Technology industry prioritize roles and responsibilities that will be most beneficial to growth. Field Research & Insight Development: Objective:  Surveyed eight leaders at eight medical device To uncover resource and activity INFORM companies. benchmarks as well as forward-  Conducted three deep-dive executive interviews to looking insights about the collect qualitative insights from selected survey Regulatory Affairs function at participants. medical device companies. Deep Dive Interview Questions: 1. What process improvement initiatives are you working on in the Regulatory Affairs function? 2. In what areas do lean processes already exist? 3. Which structure best supports Regulatory Affairs activities? 4. How do you approach outsourcing and off-shoring of Regulatory Affairs activities? 5. How do you expect Regulatory Affairs resources to change in response to reform? BEST PRACTICES, 3 ® Copyright © Best Practices, LLC LLC
  • 4. Universe of Learning: Eight Companies Engaged Research participants included eight executives from eight medical device companies. Three executives participated in deep-dive interviews. The key findings and insights are based on qualitative and quantitative data from their knowledge and experiences. Participating Companies: Bausch & Lomb; Becton Dickinson; Boston Scientific; Edwards Lifesciences; Ethicon; Medtronic; Roche Diagnostics; Zimmer BEST PRACTICES, 4 ® Copyright © Best Practices, LLC LLC
  • 5. Key Findings & Insights – 1/3 The following key findings and insights emerged from the data. Medical Device Revenue: The average medical device revenue is $7B for the benchmark Medical Device Revenue: The average medical device revenue is $7B for the benchmark class. Half of the medical device revenue comes from U.S. sales. class. Half of the medical device revenue comes from U.S. sales. Regulatory Affairs Reporting Relationship: For 38% of companies, the Regulatory Affairs Regulatory Affairs Reporting Relationship: For 38% of companies, the Regulatory Affairs function reports to C-level management, or the highest level of senior management. For more function reports to C-level management, or the highest level of senior management. For more than one-third of companies, the Regulatory Affairs function reports into aacombined Quality than one-third of companies, the Regulatory Affairs function reports into combined Quality and Regulatory Affairs executive. and Regulatory Affairs executive. Functional Structure: Most Regulatory Affairs functions are business unit centric with RA Functional Structure: Most Regulatory Affairs functions are business unit centric with RA employees reporting directly to the business unit they support. A hybrid approach - -one that employees reporting directly to the business unit they support. A hybrid approach one that centralizes planning, information, and coordination, but not staff - -may help increase centralizes planning, information, and coordination, but not staff may help increase efficiency. efficiency. Corporate Regulatory Affairs Groups: Corporate Regulatory Affairs groups average seven Corporate Regulatory Affairs Groups: Corporate Regulatory Affairs groups average seven FTEs. The groups primarily promote standards, monitor the worldwide regulatory environment, FTEs. The groups primarily promote standards, monitor the worldwide regulatory environment, coordinate internal and external policy advocacy efforts, and advise business unit Regulatory coordinate internal and external policy advocacy efforts, and advise business unit Regulatory Affairs staff. Affairs staff. BEST PRACTICES, 5 ® Copyright © Best Practices, LLC LLC
  • 6. Medical Device Revenue Ranges from $1B to $16B Medical device and technology companies of all sizes face regulatory changes and must adapt resources to meet demand. Medical device revenue in the benchmark class averages approximately $7B. Q2. Please estimate your company's 2010 annual revenue from medical device sales and related services. (Provide all cost figures in U.S. dollars. Use data from most recently completed fiscal year.) Estimated Medical Device Revenue ($USD): Max $16,000,000,000 75th Percentile $9,100,000,000 Mean $6,995,875,000 Median $5,950,000,000 25th Percentile $3,565,000,000 Min $1,447,000,000 (n = 8) BEST PRACTICES, 6 ® Copyright © Best Practices, LLC LLC
  • 7. Most RA Groups Support Corporate Headquarters Given the importance of Regulatory Affairs to the overall success of a medical device company, most Regulatory Affairs executives in the benchmark class support efforts at corporate headquarters. Only 25% primarily support a specific business or operating unit, which can be attributed to the existing corporate structures at those companies. Q9. Which entity do you primarily support? (Choose one.) A specific business/ operating unit, 25% The corporate headquarters, (n = 8) 75% BEST PRACTICES, 7 ® Copyright © Best Practices, LLC LLC
  • 8. Most Regulatory Affairs Structures Are BU-Centric Nearly two-thirds of companies employ a business-unit-centric Regulatory Affairs structure where RA employees report directly to the business unit or manufacturing site they support, but also have informal reporting relationships ("dashed line reporting") to a separate Regulatory hierarchy that ultimately reports to a senior Regulatory Affairs leader. Q12. How is Regulatory Affairs structured in your company? (Choose one.) Distributed Other, 13% Regulatory- centric Function: RA is a separate function Business-unit- closely aligned Centric with or Regulatory distributed into Function: RA BUs and/or employees sites, 25% report directly to the BU or manufacturing site they support, 63% Other: •In transition from business centric (n = 8) to distributed RA centric BEST PRACTICES, 8 ® Copyright © Best Practices, LLC LLC
  • 9. Most File Regulatory Submissions in >50 Countries In addition to U.S., EU, Japan and Canada, benchmarked companies file regulatory submissions in 56 other countries on average. A seamless global IT solution for document storage is critical to avoid reinventing the wheel for every submission. Q18. Outside the US, EU, Japan and Canada, in how many additional countries does your company file regulatory submissions for medical devices? Number of Additional Countries where Filing Regulatory Submissions: Max 100 75th Percentile 60 Mean 56 Median 56 25th Percentile 45 Min 24 (n = 7) BEST PRACTICES, 9 ® Copyright © Best Practices, LLC LLC
  • 10. As with EU, Canadian Submissions are Less Taxing on RA Resources Canadian licensing costs are much lower per submission than for the U.S. or Japan, although cost per submission is slightly higher than for the EU. Q17. Approximately how much is your Regulatory spend and how many Regulatory FTEs and Consultants do you have per each of the following active regulatory submissions? Global RA Spend/ Global RA FTEs/ Global RA Consultants/ Active Submission Active Submission Active Submission Canadian Canadian Canadian Canadian Canadian Canadian licenses - licenses - licenses - licenses - licenses - Class III licenses - Class II Class III & Class II Class III & Class II & IV devices: devices: IV devices: devices: IV devices: devices: Max $1,800,000 $340,000 17.50 2.70 2.00 0.50 75th Percentile $249,251 $229,091 1.67 1.73 0.21 0.15 Mean $411,342 $162,966 3.58 1.20 0.37 0.12 Median $213,333 $163,102 1.49 0.93 0.06 0.02 25th Percentile $170,383 $84,457 1.10 0.57 0.04 0.02 Min $26,793 $10,563 0.55 0.18 0.00 0.00 (n = 7 7 7 7 7 7) BEST PRACTICES, 10 ® Copyright © Best Practices, LLC LLC
  • 11. PMAs and IDEs Received Consultant Focus PMAs (see previous slide) and IDEs had the highest Regulatory Consultant FTE levels. Submission Consultant FTE levels are total RA Consultant FTEs divided by total number of submissions for each category. Approximately how many Consultant FTEs were involved in each of the following submissions in 2010? Canadian Canadian Investiga- Japan Japan Shonin licenses - licenses - tional Device Design Technical Todokede (approval Class III & applications): Class II Exemptions dossiers: files: (notifications): Class IV devices: (IDEs): devices: Max 2.00 5.00 0.40 4.00 4.00 2.00 2.00 75th Percentile 0.82 0.42 0.19 0.16 1.54 1.50 0.53 Mean 0.57 1.01 0.15 0.73 1.13 0.86 0.51 Median 0.15 0.23 0.12 0.10 0.40 0.40 0.27 25th Percentile 0.10 0.14 0.02 0.04 0.22 0.30 0.11 Min 0.00 0.00 0.00 0.00 0.00 0.00 0.00 (n = 6 6 5 6 7 7 7) BEST PRACTICES, 11 ® Copyright © Best Practices, LLC LLC
  • 12. RA Leads Submissions, Labeling, FDA Correspondence, and Registrations At all organizations, regulatory takes a lead role for filing submissions. Meanwhile, 75 percent of companies have regulatory leading interactions with the FDA on official correspondence and listings/registrations. Q22. For the following responsibilities, does the Regulatory Affairs function lead, support, or play no role? (Choose one role per responsibility.) No Role Supporting Role Leading Role Regulatory submissions to gain and/or 100% market authorization Labeling/publishing 25% 75% FDA Official Correspondent 13% 13% 75% FDA Listings and Registration 13% 13% 75% Field corrective actions: notification to 13% 50% 38% regulatory agencies; and follow up reporting Responses to Notified Body Observations 75% 25% Responses to FDA warning letters 88% 13% Responses to FDA 483 observations 88% 13% Audit support (FDA, Notified Bodies, all other 100% agencies) (n = 8) Complaint handling and MDR reporting 38% 63% BEST PRACTICES, 12 ® Copyright © Best Practices, LLC LLC
  • 13. About Best Practices, LLC Best Practices, LLC is a research and consulting firm that conducts work based on the simple yet profound principle that organizations can chart a course to superior economic performance by studying the best business practices, operating tactics and winning strategies of world-class companies. Best Practices, LLC 6350 Quadrangle Drive, Suite 200, Chapel Hill, NC 27517 919-403-0251 bestpractices@best-in-class.com www.best-in-class.com BEST PRACTICES, ® LLC