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Fernandez Consulting

Fernandez Consulting

Global SaMD Program Direction

Rigorous strategic discipline combined with hands-on delivery, directing Class II/III Software as a Medical Device programs from strategy and governance through multi-market launch and post-market operations.

We do not conclude at recommendations.We remain accountable for outcomes.

Every program is scoped with the rigor of a top-tier strategy engagement and then delivered with full ownership — through governance, stage gates, and into the markets it was designed to serve.

Core markets

  • United States

    FDA

  • European Union

    EU MDR

  • United Kingdom

    MHRA

  • Canada

    Health Canada

  • Australia

    TGA

  • Switzerland

    Swissmedic

Extended capability: Japan · China · Brazil · Selected Asia-Pacific

The mandate

Strategy, scoping, governance, execution

One continuous arc under a single accountable direction. Most engagements begin at the first stage; recovery mandates begin wherever the program actually stands.

  1. 01

    Strategic Scoping and Analysis

    Establish the real position before committing to a plan.

    Device qualification and classification, regulatory pathway selection across target markets, and an evidence gap assessment measured against the date the business has committed to. Delivered as a decision document, not a discussion.

    • Qualification and classification rationale per market
    • Pathway strategy across core and extended markets
    • Evidence and documentation gap baseline
    • Quantified exposure to the committed timeline
  2. 02

    Program Governance and Direction

    Convert strategy into a structure that can be executed.

    Terms of reference, workstream architecture, named ownership and decision rights. Design control governance and phase gate criteria defined so that engineering velocity and regulatory obligation advance together rather than in tension.

    • Program terms of reference and re-baselined plan
    • Workstream architecture with accountable owners
    • Design control governance and gate criteria
    • Steering cadence and executive escalation path
  3. 03

    Execution and Delivery

    The phase where advisory engagements end and ours continues.

    We hold the plan and drive it. Decisions are taken to closure, blockers removed personally, cross-functional and cross-border dependencies managed, and the evidence base completed to the standard the gate requires.

    • Requirements traceability through verification and validation
    • Technical documentation and design history file completion
    • Risk management and cybersecurity documentation
    • Gates prepared, reviewed and passed
  4. 04

    Multi-Market Success

    Launch is a milestone, not the finish line.

    Market entry sequenced so that a single body of evidence serves as many submissions as the requirements allow, followed by the surveillance and change control obligations that begin on the day of release.

    • Sequenced multi-market submission strategy
    • Notified body and agency interaction management
    • Post-market surveillance and vigilance readiness
    • Change control and lifecycle governance

The distinction

Where advisory engagements conclude, the mandate continues

The scoping stage would be familiar to anyone who has bought from a top-tier firm. What follows it is not.

Conventional advisory

  • A findings pack and a set of recommendations
  • An implementation roadmap for another team to run
  • Risks identified, logged and handed over
  • Success measured by acceptance of the report

Fernandez Consulting

  • Decisions taken to closure and recorded
  • The plan executed under our direction
  • Blockers removed personally and escalated early
  • Success measured by the gate passed and the market entered

Capability

Where the program and the regulation meet

Class II/III software programs fail at the seams between functions. Direction is held across all of them rather than within any single one.

SaMD Program Direction

Direction of Class II/III software programs where delivery, regulatory compliance and patient safety cannot be separated from one another.

Multi-Market Regulatory Strategy

FDA, EU MDR, MHRA, Health Canada, TGA and Swissmedic pathways sequenced as one coordinated program rather than as separate, duplicated submissions.

Lifecycle Governance

IEC 62304 lifecycle processes and ISO 13485 quality systems applied so that they describe how the organization genuinely builds software.

Design Control and Traceability

A traceable path from requirements and design controls through verification, validation and release that withstands notified body and agency review.

Interoperability

HL7 FHIR and connected clinical systems, where integration risk across hospital environments is program risk and must be governed as such.

Medical Device Cybersecurity

Security requirements, threat modeling and documentation carried inside the delivery plan rather than raised as a premarket surprise.

Global reach

Programs directed across regulated markets worldwide

Multi-market entry is planned as a single sequence, so that evidence generated once serves more than one submission wherever the requirements permit.

Core markets

Extended capability

Extended markets are directed in coordination with local authorized representatives and in-country agents, under the same program governance as the core markets.

When we are engaged

Programs at the point where direction decides the outcome

Engagement models

Interim, fractional and embedded direction

The arc is constant. What varies is what is held, at what commitment, and over what term.

Interim Program Direction

4–5 days weekly · 3–9 months

Embedded leadership of a Class II/III program during a vacancy, transition or capability gap. We hold the plan, chair the governance and carry the milestone dates until a permanent appointment is made and the mandate handed over.

Fractional Program Direction

1–3 days weekly · Rolling, 3-month minimum

Continuous senior direction for organizations requiring genuine regulatory-delivery judgment across release cycles without a full-time appointment.

Program Recovery

Full-time, front-loaded · 90 days, extendable

Time-boxed intervention where priorities, evidence or cross-functional friction have stalled delivery. The first phase establishes the true position; the remainder restores a credible, owned path to release.

Submission and Gate Readiness

2–4 days weekly · To the gate

Direction of a defined workstream to a specific gate, covering requirements traceability, verification and validation readiness, and technical documentation completeness — assessed against the standard the gate applies, then driven closed.

Specialist Augmentation

Scaled to the workstream · Defined deliverable

Where a workstream exceeds the capacity an organization can release internally, we mobilize qualified specialists under our direction and inside your quality system. A specialist can typically be placed within days.

EU MDR PRRC Support

Defined availability · Ongoing

Article 15(6) permits micro and small enterprises to hold the Person Responsible for Regulatory Compliance externally, provided that person is permanently and continuously at the manufacturer's disposal. Above that threshold we support the appointed PRRC rather than hold the role.

Engage

High-stakes programs deserve a direct conversation.

If you are accountable for a Class II or III software program under regulatory or delivery pressure, we should speak. If the mandate is not one we should hold, you will be told so directly.