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Healthcare software testing for products a regulator will read

We test electronic health records, telemedicine platforms, connected devices and software that is itself a medical device. The work is planned against the clauses your reviewer will cite, and it produces the traceability, the protocols and the defect records an audit asks to see. Compliance itself stays yours.

We test against the requirements in these standards and prepare the artefacts an auditor asks for. Compliance itself is held by the organisation that ships the product.

We sign a Business Associate Agreement before any engagement that touches PHI.

Where does regulated software cost you money?

Regulatory

What happens when a reviewer asks for the evidence?

A reviewer picks a requirement and follows it to the test that covers it. Where the trail stops, the submission turns into a deficiency letter, and the launch date moves by however long the response cycle takes.

The trail is built while the work happens. Reconstructing it after the questions arrive costs more and convinces less.

Preparing software for an FDA submission

Product

What happens when a clinician acts on a wrong screen?

A dose, an allergy flag or a result lands in the wrong field, and the person reading it has no reason to doubt it. The defect is found by the patient rather than by the release.

Clinical workflows get tested as workflows, with the data conditions that make them fail, rather than as screens.

The QA a digital health product needs first

What changes when the software is regulated?

When does the evidence an auditor reads get produced?

It gets produced during the testing, because a reviewer picks a requirement and follows it to the test that covers it, then to the result and to any defect it raised. Assembling that trail afterwards means reading old tickets and reconstructing intent. IEC 62304 puts the trace inside the development process for that reason, and an auditor can tell which way round it was done.

What IEC 62304 asks you to keep

Do test environments need real patient data?

No. Production records in a test environment turn every export, every screenshot and every debug log into an incident waiting for someone to notice. Synthetic records and de-identified extracts cover the same test cases and remove that class of incident before the first case is written.

How we handle PHI, BAAs and test environments

Which defects reach patients?

The defects that reach patients are the ones that look correct on screen. A crash gets reported by the first person who sees it. A medication list that drops an entry after a patient merge, or an allergy flag that fails to survive an HL7 v2 to FHIR translation, is read as correct by the clinician acting on it. Those paths get tested as clinical workflows, with the data conditions that break them.

Testing against HL7 v2 interfaces

Who accounts for third party code?

You do. IEC 62304 calls it SOUP, software of unknown provenance. Clause 5.3 wants functional and performance requirements for each item, and clause 7.1 wants the published anomaly lists evaluated against your own hazards. A dependency list generated from a package manifest answers neither question.

Testing software of unknown provenance

Which standards apply where you are shipping?

United States

  • 21 CFR Part 11What 21 CFR Part 11 asks of a computerised system, which requirements FDA said in 2003 it would not enforce, and what validation testing has to demonstrate.
  • FDA CSAWhat FDA's computer software assurance guidance recommends, which software it covers, how the testing methods nest, and the record an investigator asks for.
  • FHIR R4Why "we support FHIR" names no testable obligation, which parts of R4 version 4.0.1 are stable enough to build on, and what a conformance test measures.
  • HIPAA Security RuleWhat the HIPAA Security Rule asks of software, which technical safeguards a test can exercise, and which records an OCR investigator asks to see.
  • HITRUSTWhat HITRUST certification is, which of the e1, i1 and r2 assessments applies, what it commits you to every year, and where HITRUST's own documents disagree about HIPAA.
  • HL7 v2Why an HL7 v2 message can conform to the standard and still be rejected at the receiving site, which optionality and usage codes decide it, and what a conformance test measures.
  • ICD-10Which of the three ICD-10 code sets your software stores, the construction rules a validator has to encode, and what the 1 October changeover does to stored diagnosis data.
  • IEC 62304What IEC 62304 asks for from software testing, how the safety class changes the scope, and which records an auditor asks to see.
  • IEC 62366-1What IEC 62366-1 Edition 1.1 asks of usability validation, which records land in the usability engineering file, and why FDA recognises only the consolidated edition.
  • IEC 82304-1Which clauses IEC 82304-1 adds on top of IEC 62304, what its validation and accompanying document clauses are called, and why ISO/TS 82304-2 is a different document.
  • ISO 13485Where ISO 13485 requires software to be validated, which clauses reach software under the FDA QMSR, and what an auditor asks to see for each one.
  • ISO 14971Which ISO 14971 clauses testing produces evidence for, why verifying that a risk control works is separate from verifying it exists, and what an auditor opens in the risk management file.
  • ONC Health IT Certification ProgramWhat the ONC Health IT Certification Program tests against 45 CFR 170.315, which obligations recur annually after certification, and what is under enforcement discretion.
  • WCAG 2.1 Level AAWhich US rule actually makes WCAG 2.1 Level AA binding, what a Level AA claim covers, and why Success Criterion 4.1.1 Parsing is still required after W3C retired it.

European Union

  • EU AI ActWhich medical AI the EU AI Act treats as high risk, what Articles 9 to 17 ask testing to produce, and why the Annex I date is now 2 August 2028.
  • EU MDRHow Annex VIII Rule 11 classifies software under the EU MDR, which Annex I requirements bind it, and what Annex II asks for as software test evidence.
  • IEC 62304What IEC 62304 asks for from software testing, how the safety class changes the scope, and which records an auditor asks to see.
  • IEC 82304-1Which clauses IEC 82304-1 adds on top of IEC 62304, what its validation and accompanying document clauses are called, and why ISO/TS 82304-2 is a different document.
  • ISO 13485Where ISO 13485 requires software to be validated, which clauses reach software under the FDA QMSR, and what an auditor asks to see for each one.
  • ISO 14971Which ISO 14971 clauses testing produces evidence for, why verifying that a risk control works is separate from verifying it exists, and what an auditor opens in the risk management file.
  • IVDRHow Regulation (EU) 2017/746 classifies software without an MDR-style software rule, what Annex XIII asks you to prove about performance, and which records an assessor opens first.

International

  • DICOMWhat DICOM PS3.2 requires of a Conformance Statement, why two conforming systems can still fail to interoperate, and which checks a test plan can build from the Standard.
  • FHIR R4Why "we support FHIR" names no testable obligation, which parts of R4 version 4.0.1 are stable enough to build on, and what a conformance test measures.
  • HITRUSTWhat HITRUST certification is, which of the e1, i1 and r2 assessments applies, what it commits you to every year, and where HITRUST's own documents disagree about HIPAA.
  • HL7 v2Why an HL7 v2 message can conform to the standard and still be rejected at the receiving site, which optionality and usage codes decide it, and what a conformance test measures.
  • ICD-10Which of the three ICD-10 code sets your software stores, the construction rules a validator has to encode, and what the 1 October changeover does to stored diagnosis data.
  • IEC 62304What IEC 62304 asks for from software testing, how the safety class changes the scope, and which records an auditor asks to see.
  • IEC 62366-1What IEC 62366-1 Edition 1.1 asks of usability validation, which records land in the usability engineering file, and why FDA recognises only the consolidated edition.
  • IEC 82304-1Which clauses IEC 82304-1 adds on top of IEC 62304, what its validation and accompanying document clauses are called, and why ISO/TS 82304-2 is a different document.
  • ISO 13485Where ISO 13485 requires software to be validated, which clauses reach software under the FDA QMSR, and what an auditor asks to see for each one.
  • ISO 14971Which ISO 14971 clauses testing produces evidence for, why verifying that a risk control works is separate from verifying it exists, and what an auditor opens in the risk management file.
  • WCAG 2.1 Level AAWhich US rule actually makes WCAG 2.1 Level AA binding, what a Level AA claim covers, and why Success Criterion 4.1.1 Parsing is still required after W3C retired it.

What are you shipping?

  • Medical billing

    What breaks in medical billing software, why the defects pass every schema check, and which published artefact a claim has to be tested against.

    HL7 v2, FHIR R4, ASC X12N 005010, ICD-10-CM, ICD-10-PCS

  • EHR and EMR

    What breaks in an electronic health record under test, which certification and privacy rules a record system answers to, and where the interface and migration defects concentrate.

    HL7 v2, FHIR R4, ICD-10

  • IoMT and connected devices

    Why a connected medical device is tested against a network its manufacturer does not own, and why a vulnerability in a third party component becomes a design question instead of a ticket.

    HL7 v2, DICOM, FHIR R4

  • Patient portals

    What breaks in a patient portal driven by an untrained user, why HIPAA leaves proxy eligibility to state law, and what a suite has to cover on the identity, delegation and patient rights paths.

    FHIR R4, HL7 v2

  • Clinical trials

    What breaks in EDC and randomisation systems, why the trial record has to stay readable after the software is switched off, and why a test that reveals a treatment assignment is a defect.

    FHIR R4, DICOM, HL7 v2

  • Remote patient monitoring

    What breaks when readings arrive continuously from outside the clinic: gaps, duplicates, readings out of order, clocks that disagree, and what the system does while nothing arrives.

    HL7 v2, FHIR R4

  • SaMD

    Why SaMD test records sit inside the regulatory file, which classification decides how much testing binds, and what an assessor opens first when the software is the device.

  • Telemedicine

    What breaks in a telemedicine platform once the call leaves the office network, which standards reach it, and how the encounter record is checked after the consultation ends.

    HL7 v2, FHIR R4, ICD-10

What do buyers ask about this?

Do you take on our compliance obligation?
No, and no testing vendor can. The obligation sits with the organisation holding the marketing authorisation, the ONC certification or the covered entity relationship. What we take on is the testing against the requirements in those standards and the artefacts an audit asks for. A vendor who tells you otherwise is worth checking with your regulatory lead.
What do you need from us before testing starts?
An intended use statement, the risk classification if one exists, the requirement list in whatever shape it is currently in, and access to an environment that is not production. Where the classification or the requirements are thin, that gap is the first thing the work produces, because the clause set that binds you follows from it.
Does this work for a product that is already on the market?
Yes. IEC 62304 clause 4.4 covers legacy software and lets risk management activities and objective evidence from field use stand in for development records that were never produced. It asks for a gap analysis, a plan to close the gaps that matter, and a written rationale for continuing to use the software.

What does validating your product actually involve?

Answer four questions about your markets, your product type and its integrations. You get the standards that reach you, the artefacts each one asks you to produce, and which of them a test supplier delivers.