Regulatory infrastructure

Every change to a cleared device forces the same call: new 510(k), or Letter‑to‑File?

Galen turns a code change, ticket or ECO into a cited, review-ready regulatory decision — a drafted Letter-to-File, or a flag that a new submission is likely required — in minutes rather than days.

The cost of getting it wrong

$50K–$250K+

Over-file

Burned on testing and submission prep for a 510(k) that a defensible Letter-to-File justification would have covered. A single misjudged filing costs more than a year of the review work it was meant to avoid.

Warning letter

Under-file

A change that needed a new submission documented as a Letter-to-File instead — surfacing years later in an inspection, with a recall as the downside case.

The decision leans on two dense FDA guidance flowcharts for device and software changes, your own change-control SOP, and quality records scattered across systems — the design history file, risk files, prior 510(k)s, verification and validation reports — plus live context from git, Jira and Polarion.

Today that work is manual, slow and inconsistent: hours per change, done by RA and QA staff or outside consultants billing $75–$450 an hour.

Both directions are expensive. The judgment itself is the bottleneck — not the paperwork.

How it works

Five steps from a change landing in your tracker to a signed record in your quality system.

  1. 01

    Ingest

    QMS and DHF records, prior 510(k)s and Letters-to-File, risk files — plus live context from git, Jira and ECOs.

  2. 02

    Evidence dossier

    Only the records this one change turns on, each excerpt traced back to its source.

  3. 03

    Decision tree

    FDA's change guidance as explicit, versioned logic. Every node cites what it branched on.

  4. 04

    Cited draft

    A .docx Letter-to-File — or a flag that a 510(k) is likely required — every field linked to its evidence.

  5. 05

    Review and sign-off

    Field-by-field accept, edit or reject. A separate approver signs. Galen never submits.

Galen drafts and cites. A named reviewer decides, and a second approver signs.

Why you can defend it

The realistic failure mode for a tool like this is a plausible-sounding, unsupported justification landing in a regulated record that an investigator reads years later. Galen is built against that specific outcome.

Every field carries a citation

Each statement in the draft links to the excerpt it came from. Where the evidence does not support a claim, the field renders as a flagged placeholder — never as invented prose that reads plausible and cites nothing.

An auditable decision tree, not a prompt

The regulatory logic is explicit and versioned, built from FDA's own guidance rather than retrieved and summarized at answer time. It is structured to be validated the way your QA team validates other quality-system software.

An assistant, not a system of record

The approved Letter-to-File stays in your Veeva Vault, MasterControl or Polarion. Galen exports a .docx plus a machine-readable evidence sidecar for write-back, so your records stay where your auditors expect them.

A human decides, on the record

Field-by-field accept, edit or reject, with a separate approver sign-off. The audit trail captures who changed what and which evidence they saw when they decided.

Built to be validated the way your QA team validates other quality-system software — QMSR §4.1.6 and ISO 13485 §4.1.6.

Every claim traces to a document. Every decision traces to a person.

Who it's for

An engineer ships a change. Someone now has to decide whether it is a Letter-to-File under 21 CFR 807.81(a)(3) or a new 510(k) — and defend that call to an auditor years from now.

That someone is usually an RA manager, a QA director, or a VP of regulatory affairs.

  • Regulatory affairs and quality teams at medical device and medtech software companies.
  • Active 510(k)-cleared product lines making frequent software or design changes.
  • Single-product mid-market companies through to large multi-line device makers.

If that call lands on your desk more than a few times a quarter, Galen is built for you.

Design partners

Galen is in development.

We are onboarding a small number of design partners — RA and QA teams willing to put real change-control decisions in front of the pipeline and tell us where it falls short.

GalenRegulatory infrastructure

In development — seeking design partners.