Beyond Patching: How to Secure Medical Devices and Meet FDA Compliance Without Changing Code

Posted on October 7, 2025
Author: RunSafe Security

Key Takeaways:

  • Legacy devices can’t be patched easily, but compensating controls provide alternatives.
  • SBOMs are critical for transparency and accountability.
  • The FDA now mandates secure development and life cycle planning.
  • Cybersecurity and patient safety are inseparable—breaches harm care.
  • Collaboration is the only sustainable path forward.

In healthcare cybersecurity, one of the biggest challenges is protecting medical devices that are difficult to patch and written in memory unsafe languages. Unlike web applications or mobile software, which can be updated overnight, medical devices are often built to last 10–15 years and aredesigned for reliability and patient safety—not constant code revisions.

Yet cyber threats are growing, and FDA regulations are tightening. Manufacturers and healthcare providers are now under pressure to secure legacy systems while keeping patients safe. The question is: how can this be done without rewriting a single line of code?

This was the focus of a recent episode of Exploited: The Cyber Truth, featuring Phil Englert (VP of Medical Device Security at Health-ISAC) and Joseph M. Saunders (Founder & CEO of RunSafe Security). Their insights offer a practical roadmap that blends compensating controls, regulatory awareness, and industry collaboration.

 

The Reality of Legacy Devices: Built to Last, Hard to Secure

Medical devices weren’t designed with today’s cybersecurity challenges in mind. Hospitals rely on equipment that often stays in service for a decade or more, from MRI machines to pacemakers, because replacing them isn’t financially or operationally feasible. These devices also run on limited computing resources and cannot tolerate downtime, making traditional patching nearly impossible.

As Englert explained, “We’ve painted a target on our back” by connecting these devices to networks for efficiency and data sharing but without always providing the necessary safeguards. That combination of longevity, limited resources, and operational necessity makes securing these devices a unique and ongoing challenge.

Security Without Code Changes: What It Really Means

When patching or rewriting isn’t an option, the focus shifts to compensating controls, or ways to secure devices without touching their software, as well as opportunities for code protection.

  • Monitoring: Establishing real-time visibility into device activity to catch anomalies early.
  • Segmentation: Isolating devices so that a breach doesn’t cascade across the network.
  • Code Protection: Secure embedded devices in real-time to prevent attacks.

These approaches are not one-size-fits-all. The strategy for an implanted pacemaker is very different from that for a helium-filled MRI machine. But the principle remains: if you can’t harden the device itself, you must harden its environment.

SBOMs: Building Trust Through Transparency

Another theme from the discussion was the rise of Software Bills of Materials (SBOMs). Much like a nutrition label on food, SBOMs give visibility into the “ingredients” inside a medical device. This transparency allows healthcare providers to quickly assess whether known vulnerabilities, like Log4j, impact their devices, hold manufacturers accountable, and make smarter, risk-based decisions about deployment.

As Saunders noted, SBOMs are most valuable when generated close to the point of software production, ensuring accuracy and reliability.

FDA Compliance: Guidance Becomes Mandate

For years, FDA cybersecurity guidance was considered “best practice.” That changed in December 2022 when Congress gave the FDA statutory authority over device cybersecurity under the PATCH Act. By March 2023, manufacturers were required to follow a secure software development lifecycle, account for the full environment in which devices operate, and maintain controls and documentation throughout the device’s lifespan.

This represents a major shift. Compliance is now enforceable, and the focus has expanded from protecting data to ensuring patient safety across interconnected healthcare ecosystems.

Why Patient Safety Is the True Bottom Line

Cybersecurity lapses aren’t abstract IT problems—they have real consequences for patient outcomes. Studies show that clinical performance can decline for up to 18 months following a hospital breach, as resources are diverted to recovery efforts. The “blast radius” often extends beyond one hospital, affecting neighboring facilities that absorb overflow patients.

Among organizations that experienced cybersecurity incidents affecting medical devices, 75% said that cyber incidents caused at least a moderate patient care impact.  46% required manual processes to maintain operations and 24% required patient transfers to other facilities.

As Saunders emphasized, “Cybersecurity is an enabler of patient safety.” Even the most advanced medical care can be undermined without strong cybersecurity practices in place.

Collaboration: The Missing Piece

Perhaps the most actionable takeaway is that no single organization can address these challenges alone. Manufacturers, healthcare providers, regulators, and third-party service organizations all have roles to play.

Practical steps include:

  • Negotiating stronger controls before adopting new devices.
  • Sharing information through groups like Health-ISAC.
  • Starting small—building inventories, mapping data flows, and tightening controls incrementally.

Englert summed it up best: “80% of anything is better than 100% of nothing. Start where you can with the resources you have.”

For more insights on medical device cybersecurity, download RunSafe’s 2025 Medical Device Cybersecurity Index.

 

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