Template Detail

FDA QMSR transition checklist

Track the move from a Part 820 quality system to the QMSR — task by task, with owners and evidence.

The QMSR took effect on February 2, 2026 — ISO 13485:2016 incorporated by reference, QSIT retired, and records that were previously off-limits now reviewable in inspections. This checklist turns the transition into 19 tracked tasks across six phases, each with an owner, status, and evidence reference. Companion to the QMSR transition hub.

QMSR transition planning — regulation binder and checklist on a quality manager's desk

What the checklist covers

Nineteen tasks across six phases: gap assessment (mapping legacy procedures to ISO 13485 clauses plus the FDA additions at 820.35 and 820.45), change-controlled document updates, management review as a producible record per ISO 13485 §5.6, the re-pointed internal audit program, training on every revised procedure, and readiness drills — including a timed retrieval exercise, because the new inspection program selects records by risk and waits while you produce them.

Each task row has owner, status (dropdown), evidence/record-reference, and notes columns, plus an Instructions tab and a worked example. Add site-specific rows as your gap assessment surfaces them.

Why run the transition as tracked, evidenced work

Most QSR-era systems need a structured gap assessment, not a rewrite — but the work that is needed leaves a trail an investigator can now follow: management review minutes, internal audit findings, and supplier audit records are all reviewable under compliance program CP 7382.850. A checklist with owners and evidence references means the transition itself becomes inspection evidence rather than an undocumented scramble.

Running the transition in a governed system

The checklist works on its own — and works better when the underlying activities run in governed workflows: the document wave under change control, the gap assessment in audit management, training evidence tied to revisions, and management review minutes as controlled, signed records.