Post-Market Surveillance Plans for MDR and MFDS: Unified Approach
Build a single PMS plan that satisfies both EU MDR and Korean MFDS requirements. This 20-page guide covers structure, data sources, reporting, and integration.
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The PMS Convergence Opportunity
EU MDR Article 83-86 and Korean MFDS Notice 2023-104 both require:
- Documented PMS plan covering device lifetime
- Active and reactive surveillance components
- Periodic safety reporting
- Integration with vigilance
- Plan updates based on findings
They differ in:
- Reporting frequency (PSUR annually for MDR; annual report for MFDS)
- Specific data elements required
- Korean-specific patient population analysis
- Notification timelines for action
A unified PMS plan with jurisdiction-specific outputs is operationally efficient.
Unified PMS Plan Architecture
Section 1: Device Scope and Risk Classification
- Devices covered by plan
- EU classification (Class I, IIa, IIb, III)
- Korean classification (Class I, II, III, IV)
- Risk classification rationale
Section 2: Surveillance Methodology
- Active surveillance (proactive data collection)
- Reactive surveillance (complaint and event reporting)
- PMCF (Post-Market Clinical Follow-up) for EU MDR
- Korean-specific surveillance elements
Section 3: Data Sources
| Source | Purpose | EU/Korea Coverage |
|---|---|---|
| Customer complaints | Reactive | Both |
| Adverse event reports | Reactive | Both |
| Distributor feedback | Active + Reactive | Both |
| Literature monitoring | Active | Both |
| Regulatory database monitoring (FDA MAUDE, EU Eudamed) | Active | Both |
| Korean medical literature | Active | Korea-specific |
| Clinical investigator feedback | Active (PMCF) | EU emphasis |
| Hospital network data | Active | Korea-specific |
| User surveys | Active | Both |
Section 4: Data Analysis
- Statistical methods
- Trend analysis frequency (quarterly recommended)
- Korean subgroup analysis
- Comparison with benefit-risk profile
- Performance vs intended use
Section 5: Periodic Reports
| Report Type | Jurisdiction | Frequency |
|---|---|---|
| PSUR (Periodic Safety Update Report) | EU MDR | Annually (Class IIa+), every 2 years (Class I) |
| PMS Report | EU MDR Class I non-implantable | Updated as needed |
| Annual Report | Korean MFDS | Annually |
| Significant Update Report | Both | When trends suggest action |
Section 6: Action Triggers
- Performance trends requiring CAPA
- Vigilance thresholds requiring FSCA (Field Safety Corrective Action)
- Regulatory notification triggers
- Plan update triggers
Section 7: Integration with Vigilance
- Adverse event reporting feeds PMS data
- PMS trends inform vigilance thresholds
- Unified investigation workflow
- KLH interface (Korea-specific)
Section 8: Records and Documentation
- PMS data archive (5+ years for Korea, lifecycle + 5 for EU MDR)
- Periodic report archives
- Decision documentation
- Plan revision history
EU MDR vs MFDS — Detailed Comparison
| Requirement | EU MDR | Korean MFDS |
|---|---|---|
| Plan required | Yes (Article 84) | Yes (Notice 2023-104) |
| Active surveillance | Yes | Yes |
| Reactive surveillance | Yes | Yes |
| PMCF (clinical follow-up) | Yes (most classes) | Recommended (not strictly required for all) |
| Periodic safety report | PSUR annually | Annual report |
| Trend reporting | Required | Required |
| FSCA reporting | Per MDR Article 87-89 | Per MFDS Notice 2023-104 |
| Korean population analysis | N/A | Required |
| Korean clinical literature monitoring | N/A | Recommended |
| KLH interface | N/A | Required |
PSUR vs MFDS Annual Report
Both required annually but differ in detail:
| Element | PSUR (EU MDR) | MFDS Annual Report |
|---|---|---|
| Sales volume | Yes | Yes |
| Adverse event summary | Yes (Eudamed reportable) | Yes (Korean events) |
| Trend analysis | Yes | Yes |
| Benefit-risk reassessment | Yes (formal) | Yes (less formal) |
| CAPA summary | Yes | Yes |
| Regulatory actions taken | Yes | Yes |
| Korean clinical literature | N/A | Yes |
| Korean subgroup analysis | N/A | Yes |
| Submission to | Notified Body / Eudamed | MFDS via KLH |
A unified data collection produces both outputs through different reporting templates.
Korean-Specific PMS Elements
Beyond EU MDR alignment, MFDS expects:
Korean Patient Population Analysis
- Performance in Korean patients
- Demographic subgroup analysis (age, gender, comorbidity)
- Comparison with Korean clinical practice guidelines
Korean Healthcare Environment Considerations
- Korean hospital usage patterns
- Korean medical device combination scenarios
- Korean healthcare workflow integration
Korean Regulatory Updates Tracking
- MFDS notice monitoring
- Korean medical device standard updates
- Korean clinical guideline evolution
Operational PMS Workflow
Daily
- Customer complaint intake
- Adverse event triage
- Distributor feedback monitoring
Weekly
- Vigilance event review
- Reportable event determination
- KLH coordination for Korean events
Monthly
- PMS data aggregation
- Trend analysis
- KPI dashboard update
Quarterly
- Comprehensive PMS review
- Action trigger evaluation
- Management review input
Annually
- PSUR generation (EU MDR)
- MFDS annual report generation
- Plan update review
- Benefit-risk reassessment
Cost Estimates
Initial Setup (One-Time)
| Component | Cost |
|---|---|
| Unified PMS plan development | $20K–$45K |
| Data collection infrastructure | $15K–$50K |
| Analysis tools and templates | $5K–$15K |
| Training | $5K–$15K |
| Total Initial | $45K–$125K |
Annual Operating Costs
| Component | Cost |
|---|---|
| Daily/weekly PMS operations | $40K–$100K |
| Quarterly reviews | $10K–$30K |
| PSUR generation | $15K–$40K |
| MFDS annual report generation | $10K–$25K |
| Tool subscriptions | $5K–$20K |
| Total Annual | $80K–$215K |
Common PMS Pitfalls
Pitfall 1: Separate Plans per Jurisdiction
Maintaining EU MDR PMS plan + MFDS annual reporting separately. Duplicates effort 60%+.
Fix: Unified plan with jurisdiction-specific outputs.
Pitfall 2: Reactive-Only Surveillance
Relying on complaint intake; missing active surveillance.
Fix: Active data collection (literature, distributor feedback, hospital data).
Pitfall 3: No Korean Subgroup Analysis
Korean events analyzed as part of global data; missing Korean-specific patterns.
Fix: Korean subgroup analysis in quarterly reviews and annual reports.
Pitfall 4: PSUR Generated Annually Without Quarterly Foundation
Annual PSUR rushed; quality suffers.
Fix: Quarterly PMS reviews build PSUR throughout year.
Pitfall 5: Vigilance and PMS Disconnected
Vigilance events not feeding PMS analysis.
Fix: Unified investigation workflow; vigilance events automatically inform PMS.
Frequently Asked Questions
Q: Can our distributor handle PMS?
A: Some yes, but most distributors lack capacity. KLH-driven PMS with manufacturer-supplied analysis is more reliable.
Q: How does FDA post-market surveillance fit?
A: FDA MAUDE-based reporting is reactive. FDA does not have PSUR equivalent for most devices. Active surveillance can be unified across FDA, EU MDR, and MFDS.
Q: What if we have many products?
A: Portfolio-level PMS plan with device-specific subsections. Pooled data analysis with device-specific risk assessment.
Q: Does Leanabl provide PMS services?
A: Yes. Leanabl's Vigilance & Post-Market Reporting and Korea Post-Market Operations services include PMS plan development and operations.
Q: How often should we update the PMS plan?
A: Minimum annually. Updates triggered by: significant adverse events, regulatory changes, product changes, plan effectiveness review.
How Leanabl Helps
- Vigilance & Post-Market Reporting — vigilance + PMS operations
- Korea Post-Market Operations — portfolio-wide post-market
- Korea License Maintenance — license maintenance with integrated PMS
Contact Leanabl for unified PMS planning.
Last updated: 2026-05-15.
更多资源
EU MDR and IVDR Technical Files: A Complete Guide
Annex II/III for MDR, Annex I/II for IVDR. GSPR checklists, Notified Body engagement, and the Korean cross-reference for manufacturers entering both regions.
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UDI Implementation Guide for Korea and Global Markets
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