Healthcare Non-Medical Device Statement
What the Healthcare Non-Medical Device Statement Is
Why this statement matters for healthcare operations
A clear non-medical device statement reduces regulatory confusion, supports correct billing and procurement, and documents the supplier’s intent. It helps avoid inadvertent classification as a medical device, which could trigger FDA requirements or coverage and reimbursement issues under payer rules.
Primary users and stakeholders
This statement is used by manufacturers, procurement teams, compliance officers, and clinical engineering to establish intended use and avoid regulatory misclassification.
- Manufacturers and distributors — provide product identification, intended-use language, and contact details for regulatory questions.
- Procurement and supply chain teams — attach the statement to purchase orders and supplier profiles for sourcing clarity.
- Compliance and clinical engineering — keep the statement with device inventories and risk assessments to support audits.
Use the statement as part of vendor onboarding, product catalogs, purchase orders, and internal device inventories to maintain consistent classification records.
Step-by-step: completing the statement
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01Identify product: Enter full product name, model, and version.
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02State intended use: Declare that the item is not for diagnosis or treatment.
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03Provide manufacturer: List legal entity name, address, and contact point.
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04Sign and date: Add authorized signature, printed name, and MM/DD/YYYY date.
Common questions and practical answers
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Can this statement be signed electronically?
Yes. Under the ESIGN Act (15 U.S.C. §7001) and UETA (adopted by almost all states), electronic signatures are legally valid when intent, consent, attribution, and retention are present. Ensure the platform captures an audit trail and, for consumer‑facing transactions, provide any required consumer disclosure.
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Is notarization required?
Generally no. Most non-medical device statements are contractual declarations and do not require notarization unless specific contracting parties or jurisdictions demand it. Verify contract or state requirements before requesting a notary.
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Do healthcare privacy laws apply?
If the statement includes Protected Health Information (PHI), HIPAA applies and a Business Associate Agreement may be required. Keep PHI minimal and follow HIPAA retention and access controls (45 CFR §164.530(j)).
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How do I correct a signed statement?
Prepare an amendment or corrected statement, have the authorized signer re-sign, and retain both versions with change history. If documents were e-signed, capture the updated audit trail showing the correction.
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What supporting documents should be attached?
Attach product datasheets, labeling, safety data sheets, and any regulatory determinations. These attachments improve transparency during procurement and audit reviews.
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Who should authorize the statement?
An authorized company representative with knowledge of product design or regulatory affairs should sign. The signer’s title and authority should be documented to support attribution in audits.
Key risks from incorrect or missing statements
Common preparation mistakes to avoid
- Vague language that fails to state 'not for diagnosis or treatment' creates ambiguity during audits and procurement reviews.
- Missing manufacturer contact information can delay verification and vendor onboarding for healthcare purchasing teams.
- Using inconsistent product identifiers (different model numbers) causes inventory reconciliation errors and complicates recalls.
- Relying on scanned handwritten signatures without an attached audit trail makes it difficult to prove signer intent and attribution.
Typical workflow for issuing and approving the statement
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Prepare document: Draft statement and attach supporting data.
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Route for review: Send to regulatory and procurement reviewers.
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Sign: Authorized signer executes electronically or on paper.
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Store: Archive with audit trail and attachments.
Technical considerations for eSigning and storage
Choose a platform that supports secure e-signing, audit trails, attachments, and required compliance controls for healthcare records.
- Integrations: Salesforce, NetSuite, Microsoft 365
- Formats: PDF, DOCX, HTML
- Authentication: Email, SMS, 2FA
How to set up an online completion workflow
| Field | Configuration |
|---|---|
| Authentication | Email link or SMS code; enable 2FA for higher assurance |
| Conditional Fields | Show manufacturer details only if vendor is external |
| Retention Policy | Automatically retain signed copy and attachments |
| Attachments | Require datasheet and labeling as mandatory uploads |
Typical timelines, turnaround, and processing expectations
Provision on request:
Provide statement to purchaser upon vendor onboarding request
Internal review time:
Allow 1–3 business days for compliance and procurement review
Notarization delay:
If requested, add 3–10 business days for scheduling and completion
RON sessions:
Remote notarization may add a session fee and brief scheduling delay
Correction window:
Allow 30 days to issue amended statements when needed
Key milestones from drafting to archival
Draft prepared
Originator completes statement and attaches supporting documents
Regulatory review
Compliance confirms language and risk assessment
Authorized signing
Designated signer executes and dates the document
Archive and link
Store in records system and link to product entry
eSignature vendor comparison for executing the statement
| signNow | DocuSign | Adobe Sign | PandaDoc | HelloSign | |
|---|---|---|---|---|---|
| Starting Price | $8/user/mo | $15/user/mo | $14/user/mo | $19/user/mo | $15/user/mo |
| Free Trial | 7-day free trial | Free trial available | Free trial available | Free trial available | Free trial available |
| Bulk Send | Yes | Yes | Yes | Yes | No |
| Audit Trail | Yes | Yes | Yes | Yes | Yes |
| HIPAA Compliant | Yes | Yes | Yes | No | No |