Professional Documents
Culture Documents
The Ultimate Guide To Pharmaceutical Quality Management
The Ultimate Guide To Pharmaceutical Quality Management
Ultimate
Guide to
Pharmaceutical
Quality
Management
Chapter
1 Shifting Focus:
Adopting a Data-Centric Quality Mindset
Shifting Focus:
Adopting a Data-Centric
Quality Mindset
Ultimate Guide
1.1
Visualizing a new data-centered
quality paradigm.
When the first Nokia and Motorola same way that cell phone technology and compliance data across the
cell phones that were affordable and revolutionized modern life, digital entire life cycle of a pharmaceutical
small enough to fit in your pocket hit quality management system (QMS) product. As this evolution continues
the market, they not only changed solutions have transformed paper- to gain momentum, quality data is
how we viewed phone technology but based quality and compliance becoming even more valuable to
how we communicated. processes for the largest pharma pharma businesses as they struggle
Mobile phones went from a novelty enterprises, startups, and every type to shorten development timelines and
that only the wealthy could afford to of organization in between. They get products to market faster — all
an indispensable device that virtually provide modern digital tools for without jeopardizing compliance.
everyone has and, in many ways, managing and automating quality and That’s why it’s necessary to take
can’t live without. But unfortunately compliance documentation to create things a step further by embracing
for both Nokia and Motorola, the efficiency, increase productivity, and reliable modern tools that can enable
transformative effects of cellular mitigate risk. pharma companies to contextualize
devices were not at their apex. In Nowadays, similar to the way the and make better use of their data.
fact, the cycle of innovation was only iPhone shifted the value from voice Applying advanced analytics and
getting started. to data applications, an innovation artificial intelligence (AI) tools to data
The introduction of the iPhone revolution continues to unfold in the usage requires a proper foundation,
took things to the next level by pharma world. A fundamental shift however. Accuracy in analytics and
fundamentally shifting the value of is taking place in the way companies AI is dependent on the veracity
the cell phone from voice to data. By approach quality and compliance. and completeness of the data in
opening new features like text and The focus of quality management use. Unfortunately, most pharma
video messaging, internet access, and is moving beyond digitizing companies have a bad habit of storing
other seemingly limitless avenues documentation and embracing an that data on paper, in employees’
for the usage and access of data, the approach that capitalizes on data- computers, or other similarly siloed
iPhone dramatically increased the driven insights. locations. Even companies that have
utility and value of a mobile device An increasing number of discerning digitized quality processes with an
and forever changed the way we live, pharma companies are steering electronic QMS can have trouble
work, and play. away from quality management merging and deriving meaning from
methodologies that focus on “data all their data.
Innovative technologies have had
a similar impact in pharmaceutical objects” like documents and instead Bringing together information from
and biotech industries. Much in the embracing a model that enables more every department in the organization
granular access to all the information and having the tools to properly
contained within them. Advanced analyze it are critical to survival in the
technologies are entrenching hyper-competitive pharma industry.
themselves as the cornerstone of this The digital documentation layer of
new approach. Pharma companies quality and compliance processes
that have already implemented is still essential and will never go
modern digital tools are now more away, but advanced technologies are
capable of connecting and analyzing helping pharma organizations unlock
data across product life cycles and the data side of the equation.
INCOMING using it to predict issues and prescribe
CALL preventive actions.
Much like the iPhone didn’t eliminate
voice applications, this shift is not
about replacing documents and
processes. It’s an additive evolution
that is progressing toward the
seamless connectivity of all quality
Ultimate Guide
1.2
The promise and peril
of unstructured data.
As they say, the first step is admitting you have a problem. The primary
80%
driver behind the pharma industry’s urgency to adopt more data-centric
approaches to quality and compliance is best understood through the lens
of unstructured data, which accounts for more than 80% of data in the life
science development, production, and commercialization life cycle.1 Think
about locked PDFs, scanned documents, uploaded images, and so forth —
all elements that can be “managed” within today’s QMS software solutions,
of data in the life
but all elements that contain massive amounts of granular data and insights
sciences development,
that are currently difficult to extract and hard to correlate and analyze in
production, and
real time.
commercialization life
Nothing can be done with unstructured data until it is converted into a cycle is unstructured.
useable format. Then, pharma companies can focus on data integrity and
improving data quality. This is one of three critical points to understand
about the hazards of unstructured data and its impact in the evolving
regulatory landscape.
1 2 3
$12.9M
important during inspections, but for the the effectiveness of compliance functions.
FDA’s remote records review having it in But adopting this type of approach to
an electronic format was essential. quality and compliance requires that a
pharmaceutical company first overcome
the obstacle of unstructured data.
estimated annual cost of
poor data quality.2
Ultimate Guide
1.3
Overcoming data overload.
More data, more insights, more Pharma companies that cling Today’s QMS solutions are a giant
opportunity — got it. Not so to their antiquated document- step forward from antiquated,
fast. Like their peers in R&D and oriented approaches to quality are paper-based quality management
marketing before them, pharma just going to fall further behind processes, but they have the
quality professionals can quickly big tech competitors like Amazon, capability to be so much better.
find themselves inundated with too Apple, Google, and Microsoft who Getting there requires moving beyond
much data. Besides being flooded are positioning themselves to be merely digitizing document-centric
with machine performance, product major competitors in R&D, drug processes and focusing on a holistic
performance, process performance, manufacturing, clinical development, approach that allows quality and
and observational data, they also and other pharma spaces. A pharma compliance professionals to access,
have access to “internet of things” company’s failure to invest in analyze, and apply insights from
(IoT) data, social media data, software solutions that improve data structured and unstructured data
structured customer feedback, collection, management, and analysis within the same system across the
and human sentiment data. With while simultaneously improving the product life cycle.
this deluge of available data, the analytics comfort and capabilities of
expectation is that quality should be quality professionals will at best only
able to do more with it. But turning result in inefficiencies, production
this data into something actionable delays, or product defects. At worst,
is challenging. it’ll lead to the harsh consequences of
noncompliance or product recalls.
As traditional health care
companies struggle to tap into
$67.82B
their unstructured data, large
tech companies are rising to the
challenge. The Google Cloud
Healthcare Data Engine and Amazon
HealthLake are frontrunners in this
area.4 Both efforts have similar Projected value of big data analytics
goals in analyzing unstructured data in the health care market by 2025.3
and overcoming the interoperability
issues that are common with
electronic health records.
Ultimate Guide
1.4
Understanding
quality’s document dependency.
No self-respecting tech company would ever record and guidance based on past quality events. The conventional
store important information on paper. Even if big tech approach is not effectively supporting pharma companies
wasn’t a potential competitor, nixing the bankers boxes as they find themselves generating ever-growing
and filing cabinets is still a good idea. But the document- collections of disconnected documents and data. And
centered approach to quality management has been those document collections and disconnected data
the default mindset in the pharmaceutical industry sources are multiplying and fragmenting exponentially.
for as long as it’s been regulated. The mentality has What’s more, regulatory agencies are recognizing that
been predominantly based on the rationale that quality the one-size-fits-all approach to regulation does not
activities are typically rooted in historical information that adequately weigh the wide range of risks posed to
is maintained in reviewable documents. different pharma companies, which has triggered the
subsequent shift to a data-driven, segmented approach
And while there is a rich history of statistical data
to regulation.
analysis in quality, the traditional models have typically
employed point-in-time analysis that provided parameter
1 2 3
1.6
Taking pragmatic steps toward digital leadership.
There’s only so much an individual can do without who lays the groundwork for support up front. Such
the approval and support of the C-suite. Digital leaders … hire AI-experienced senior talent to fill the
transformation is best done holistically, not piecemeal, leadership positions required to help drive the change,
and that level of vision and planning requires someone if the talent doesn’t already exist in the organization.
further up the organization’s hierarchy. Digital They also reduce hierarchy, make AI education a
transformation, connected data, and AI are just steps priority, and consistently communicate at every level
on the same continuum to make better decisions the strategic nature of these changes.”6
based on data with less error. McKinsey & Company If your company isn’t yet planning any AI initiatives,
performs an annual survey about AI, specifically now is the time to start. AI, especially machine
looking at the difference between what they refer to learning (ML), is playing an increasingly vital role
as AI high performers and other organizations. in quality process optimization. There isn’t a single
“The most successful companies we see have a CEO pharma company that couldn’t benefit from the
90%
enhanced predictive/prescriptive analytics that AI
of enterprisewide can provide. But undertaking an AI initiative isn’t as
digital transformations scary as it sounds. There’s no need to run out and hire
in the life sciences are AI experts when advanced tools with built-in AI are
led by new CXOs.5 already on the market.
Ultimate Guide
1.7
Connecting the 4 Ps:
People, Processes,
Policies, and Platforms.
At MasterControl, we are actively focused on the future As one expert from Deloitte points out, “With AI
and helping our customers get the most out of their capabilities increasingly embedded in enterprise
quality and compliance data and processes — not just at a software, and an abundance of cloud-based offerings
technology level, but at the operational level. Digitization and tools that accelerate AI development, a company
continues to be the overarching trend in the pharma no longer needs as many heavy-duty specialists to get
industry, and quality leaders are learning that they started.”8 We know how valuable analytics and AI are
must find new ways of reimagining and redesigning their to pharma organizations, which is why we’re building
processes in order to become more focused on managing those capabilities into our products. Pharma companies
data digitally. can immediately reap the benefits, even as they work to
transform their whole organization.
Overhauling processes is hard enough without worrying
about the technology involved. That’s why we’re
working to integrate completely connected quality
management and predictive and prescriptive insights into
process improvements. With an intuitive user interface, of companies
MasterControl products help employees embrace are significantly
digital transformation and advanced technology such accelerating
as AI by making it easier to use, which also helps their their digital
organization achieve ROI faster. transformations.7
Ultimate Guide
1.8
The future of
connected quality.
Speaking of analytics and AI, that’s really where the While new technology creates new challenges, it also
quality field in general is headed. That doesn’t mean opens the door to new opportunities. The following
quality professionals have to go back to school to section and subsequent chapters describe how you can
get new degrees, but it does mean becoming familiar make data-centric quality a reality in your organization by
with the tools available and the benefits they offer. By implementing tools and methodologies that fully connect
automating the more tedious tasks associated with the entire quality life cycle, extend the quality ecosystem,
quality management, quality professionals can focus on and unlock the hidden intelligence and predictive
improving the pharmaceutical products themselves and capabilities that are waiting to emerge from your data.
getting them to market faster.
As additional benefits of connecting data on a granular
level continue to arise, it becomes easier to visualize
scenarios where the power of quality data can be
unlocked and harnessed.
1 2 3
To provide an even stronger connection between quality The FDA’s new Office of Digital Transformation (ODT) is
data and other areas of the organization, we have developed evidence of this. “The agency began these efforts because
MasterControl Insights. Insights is our analytics tool that … innovation is at the heart of what we do. By prioritizing
incorporates predictive/prescriptive analytics and AI to data and information stewardship throughout all of our
guide your decision-making. Insights gives users complete operations, the American public is better assured of the
control over their data to decide what’s important to their safety of the nation’s food, drugs, medical devices, and
specific role and how to visually display it in the most other products that the FDA regulates,” said former Acting
meaningful way. Data’s potential is too important to not FDA Commissioner Janet Woodcock. “This reorganization
embrace new technology. Even regulators agree with that. strengthens our commitment to protecting and promoting
public health by improving our regulatory processes with a
solid data foundation.”9
2
Ultimate Guide
1 2 3
It should be possible to bring medicines to the market 500 days faster, which
would create a competitive advantage within increasingly crowded asset classes and
bring much-needed therapies to patients sooner. To transform drug development, this
acceleration can be combined with improved quality and compliance, enhanced patient
and health care-professional experience, better insights and decision making, and a
reduction in development costs of up to 25%.”
New Ecosystem
Dynamics:
Enabling Pervasive Quality
Ultimate Guide
3.1
Maintaining quality in
the era of outsourcing.
As a result of the rising timeline Even so, maintaining dynamic, asset- MasterControl’s iPaaS integrations
pressures, augmented complexity, light operations and outsourcing enable seamless data exchange
and distributed supply chain factors increasingly more functions means between systems like:
discussed in the previous chapter, that quality departments must find
pharma companies are increasingly new ways to enhance flexibility
Laboratory Information
adopting asset-light models that are and extend collaborative efforts 1
Management Systems (LIMS)
heavily reliant on a broad ecosystem across a growing number of external
of design, research, and manufacturing partnerships — without increasing risk.
Manufacturing Execution
organizations. To achieve their 2
For pharma companies to Systems (MES)
goals, an ever-increasing number of successfully outsource more
pharma companies are widening their Enterprise Resource
functions, there’s no escaping the 3
networks of contract manufacturing fact that quality cannot effectively Planning (ERP)
organizations (CMOs) and contract operate in isolation. Quality must be
development manufacturing Supply Chain
consistent and pervasive throughout 4
organizations (CDMOs). Management (SCM)
the supply chain in order for it to be
Establishing solid relationships managed comprehensively and for
with reliable contract partners can compliance to be sustainable. To
bring dramatic improvements in maintain comprehensive control and
two key areas that are traditionally complete oversight over quality, you
problematic for pharma organizations: must have continual visibility into all
quality activities as they’re occurring
throughout the entire ecosystem.
• Flexibility:
74% of quality process end This requires not only a platform
users report that launch delays that enables you to digitize,
of products and services are automate, and connect quality
frequently caused by inflexible processes internally, but one that
quality processes. 16 leverages modern integration
management capabilities. That’s one
• Control and transparency: of the main reasons MasterControl
60% of organizations struggle has partnered with MuleSoft to
with real-time visibility into CMO provide quality and compliance
production and 40% lack control professionals with an integration
over product quality. 17 platform as a service (iPaaS) layer.
The adaptability afforded by the
iPaaS integration layer augments
$276.8B
MasterControl’s capacity to provide
simple and reliable integrations of
critical data between enterprise
systems and outsourcing partners
The global pharmaceutical — providing the visibility and control
contract manufacturing and our customers need to ensure
research services market quality and maintain compliance.
size is projected to reach
by 2028 and is expected to
expand at a CAGR of 5.75%
from 2021 to 2028. 15
Ultimate Guide
3.2
Key questions to ask
about QMS extensibility.
As your quality Market pressures are requiring pharma these improvements are expecting —
ecosystem matures, companies to have satisfactory and getting — big returns in each area
responses to these questions. of the value chain.
you need a QMS that
promotes flexibility Companies that can be classified as
and responsiveness. As the regulatory digital frontrunners — organizations
To ensure your environment grows, in which a total quality management
quality management culture is prevalent and quality
our customers are enhancement initiatives are viewed
competencies can keep demanding more of as long-term investments — are
pace with the dynamics
of your ecosystem, us,” said Tony Harnack, far outnumbered by those lagging
in their modernization efforts,
consider the following president of nutritional according to BCG reports. In fact,
questions when supplement provider only 16% of those surveyed reported
evaluating any solution Wellington Foods. that they are applying advanced
that makes claims digital technologies to enhance
about its data and “They’re demanding more traditional best practices in quality
process management of their finished product management.18
improvement and everybody’s liability The pharma organizations on
capabilities. and risk has increased. the leading edge who are past
the planning stages and have
Everybody in the supply already begun implementing
1 Is it configurable? chain recognizes that. digital technologies are already
And everybody in the realizing the important gains
Does it have the necessary that can be made in the areas of
2
modularity and integration
supply chain who wants quality governance, training, and
features your business to be doing this 20 years performance management.
requires?
from now and who wants
3 Does it incorporate to continue to grow is
risk-based analysis?
investing in their quality
4 How quickly can upgrades, management system.”
patches, new features,
and enhancements be
implemented?
Feedback from the executives and
quality managers recently surveyed
5 How burdensome is validation? by BCG tells us that as quality-
focused organizations increase their
6 Can the intelligence the system QMS investments they are finding
provides be personalized that successful implementation
according to users’ roles? entails corresponding improvements
to the management and quality
7 Is it conducive to adapting
of data, as well as enhancements
to the requirements of
technological and regulatory
to analytics technologies and
innovations? methodologies. And the quality
leaders who are committed to making
8 Is it scalable enough to
facilitate the future expansion
of your business?
Ultimate Guide
3.3
Extending quality’s reach while
strengthening control.
A robust quality
4
to end and provide a centralized
management system global repository for managing
all contractor and supplier data,
like MasterControl
documentation, and workflow
allows pharma An integration-platform-as-a-
processes. This ensures pharma
companies to expand organizations and their authorized
service (iPaaS) layer provided by
quality’s scope and external associates have instant
MasterControl partner and industry
impact beyond the leader MuleSoft offers an assortment
access to essential information from of reliable, pre-established connectors
quality department any location, at any time. that streamline integration
to improve efficiency
2
development processes between your
and effectiveness various business systems as well as
in other areas of the with any of your partners’ systems
organization. to which you may need to forge
MasterControl Insights is our connections. By leveraging a proven
Quality is a department, analytics platform that lets users iPaaS platform with a successful
but it should also create customized visualizations track record, MasterControl ensures
characterize everything and tabular reports. It incorporates that your data stays synchronized
a pharmaceutical data from all MasterControl between systems and enables you to
company does. Hence products, including data about gain greater visibility into your overall
the desire to expand documents, training, quality events, quality and compliance activities. In
quality’s reach. When manufacturing, and more. Insights addition, iPaaS integrations enhance
multiple departments also has AI capabilities that use your ability to broaden quality
operate on the same historical data to help companies beyond the quality department as
system as the quality operate more effectively. Ultimately, it you devise connections with other
lets users make data-driven decisions departments or external systems. And
function, they can easily
faster while tracking their key the iPaaS integrations can securely
exchange information and effectively handle any volume
performance indicators (KPIs) so they
which extends quality can measure progress in real time. of data throughput that may be
far beyond the final
3
required. iPaaS versatility augments
check before a batch is MasterControl’s capacity to provide
shipped out. reliable enterprise system integrations
with less effort, risk, money, and time
MasterControl offers an array of
required on your part.
unique tools that enable you to MasterControl Manufacturing
optimize and visualize your Excellence provides electronic MasterControl’s iPaaS-outfitted
extended quality ecosystem: batch records that simplify integrations ensure your quality
1
the input, management, and data will have:
tracking of production data. Many
pharma manufacturers that have 1 Consistency across systems.
implemented Manufacturing
2 Greater value.
MasterControl’s robust Supplier Excellence are seeing a 90%-100%
Excellence and Bill of Materials decrease in data entry errors.
3 Continual availability.
(BOM) solutions facilitate the Similarly, review times are reduced
expansion of and control over quality by up to 80%, letting them get 4 Sustained integrity.
ecosystems for companies that are product out the door that much
increasingly dependent on widening faster. This saves time for everyone 5 Increased capacity to support
involved and provides manufacturing and drive decision-making.
networks of CMOs and CDMOs.
These comprehensive MasterControl records that are more accurate, and
Extended reach across
their electronic nature makes them 6
tools allow companies to manage the enterprise.
the supply chain from beginning easy to locate during an inspection
or audit.
Ultimate Guide
SP O T L I G HT
450 HRS
65% 90%
1 2 3
Ultimate Guide
4.4
The importance of a digitally
empowered quality workforce.
The COVID-19 pandemic changed a When pharma companies use AI-enabled technologies,
lot of things in the general workforce. they make the quality department more effective
regardless of where they’re working from. With AI
One of those was a shift in power from
adoption increasing, it’s important to note that the
the employers to employees.
demand for quality professionals isn’t going anywhere. AI
will take on some of the time-consuming work that quality
Another is the expectation that a role will either be
does now, but it will mostly serve to augment quality
entirely work from home or at least offer flexibility, with
professionals and enable rapid decision-making.
some days being in the office and others being worked
remotely. These expectations are taking hold across all The study from Cognizant makes this obvious. One of the
industries. Employers who were initially forced to allow questions asked of life sciences executives was to estimate
remote work found that productivity didn’t fall off. And what percentage of work would be done by machines
many employees discovered they preferred working by 2023. They were asked about eight categories, but
remotely — so much so, in fact, that they are determined interestingly in every case the executives expect less than
to never return to an office environment. 25% of the work to be done by intelligent machines.25 The
emphasis is increasingly on human-machine collaboration
How does this affect pharma companies’ quality
and getting the best of both worlds by letting the two
departments? Some quality activities are difficult, but not
complement each other. Pharma quality professionals
impossible to perform remotely (e.g., inspections or audits),
won’t be losing their jobs to intelligent machines. Rather,
while others are very conducive to remote work if you have
modern tools will streamline processes and connect and
the right tools. For example, with a cloud-based document
contextualize data so human experts can focus on what
management system, quality professionals can create,
they do best — ensuring that only the highest quality
collaborate on, and gain approval for new standard operating
pharmaceutical products make it to market.
procedures (SOPs) without setting foot in the office.
Ultimate Guide
Summary
Quality isn’t exclusive to a single and predictive insights continues MasterControl enables organizations
department. It’s all-pervasive and to mature in the pharmaceutical like yours to go beyond proactive
integral to every function throughout industry. They are empowering quality management and unleash the
the enterprise. companies to simplify the adoption intelligence and insights hidden in
of a product life cycle approach your unstructured data.
Despite the inherent challenges of
to quality by converging data and
connecting quality and compliance Discover how MasterControl can
processes within a centralized
data in an industry defined by make your vision of truly connected
system that provides true quality
truncated timelines, greater product pharmaceutical quality data a reality.
intelligence and enables real-time
complexity and personalization, and
decision-making. Contact a MasterControl
expanding supply chains and contract representative today.
partner ecosystems, there are tools MasterControl is the foundation for
that can help you ensure quality’s connected quality data and complete
connectedness and central bearing. product quality. It unifies applications,
data, and documentation across your
Connected applications, advanced
entire product development life cycle,
analytics, and AI are becoming
from concept to commercialization.
essential tools as the focus on data
About MasterControl
MasterControl Inc. is a leading provider of cloud- helps organizations digitize, automate, and connect
based quality, compliance, and production critical processes across the regulated product
management software for life sciences and other development life cycle.
regulated industries. Our mission is the same as that For more information, visit www.mastercontrol.com.
of our customers – to bring life-changing products
to more people sooner. The MasterControl Platform
Ultimate Guide
References
1. “Unleashing the power of unstructured data,”
by Kaveh Safavi, Accenture Digital Health and AI, April 26, 2021.
2. “How to Improve Your Data Quality,”
by Manasi Sakpal, Gartner Information Technology Insights, July 14, 2021.
3. “Data and Analytics In Healthcare: Addressing the 21st-century Challenges To Advance Public Health,”
by Deepak Mittal, Entrepreneur, Sept. 28, 2021.
4. “Amazon and Google Are Finally Tackling One Of Healthcare’s Biggest Problems:
Unstructured Health Data,” by Sai Balasubramanian, Forbes, July 26, 2021.
5. “Enterprise digital transformation as a competitive necessity,”
by Todd Konersmann, et al, Deloitte, 2021.
6. “Winning with AI is a state of mind,”
by Thomas Meakin, et al, McKinsey & Company Analytics Insights, April 30, 2021
7. Supra note 5.
8. “The window for AI competitive advantage is narrowing,”
by Susanne Hupfer, Deloitte, Sept. 11, 2020.
9. “FDA Advances Data, IT Modernization Efforts with New Office of Digital Transformation,”
FDA News Release, Sept. 15, 2021.
10. “The pursuit of excellence in new-drug development,”
by Gaurav Agrawal, et al, McKinsey & Company Life Sciences Insights, Nov. 1, 2019.
11. “Powering Global Access: Building a Reliable, Efficient Pharmaceutical Supply Chain,”
by AmerisourceBergen, Fierce Pharma, Nov. 15, 2021.
12. “Tech Trends 2021: Life Sciences perspective,”
by Sheryl Jacobson et al, Deloitte Insights, 2021.
13. “The Work Ahead in Life Sciences: Cures at the Speed of Digital,”
by Brian Williams, Cognizant, 2021.
14. “COVID-19’s Impact on Quality: 3 Lessons Learned and Where We Go From Here,”
by Matt Lowe, Quality Magazine, Aug. 19, 2020.
15. “Global Pharmaceutical Contract Manufacturing and Research Market Services Market Analysis Report 2021-2028,”
ResearchandMarkets.com, Oct. 5, 2021.
16. “Reimagining Quality Processes for the Digital Era,”
Gartner, Inc. Quality Research Team, Nov. 1, 2019.
17. “Dare to be different: It’s time to revamp collaboration in life sciences contract manufacturing,”
Accenture Life Sciences, 2019.
18. “Quality 4.0 Takes More Than Technology,”
by Daniel Kupper, et al, BCG, Aug. 20, 2019.
19. Supra note 14.
20. “Making quality assurance smart,”
by Tacy Foster, et al, McKinsey & Company Life Sciences Insights, Jan. 29, 2021.
21. “Market Guide for Quality Management System Software,”
by Sam New, Gartner, Inc., Jan. 4, 2022.
22. “Ensure Success in Quality Management System Software Selection,”
by Sam New, Gartner, Inc., Oct. 29, 2018.
23. “Health industry AI efforts get a boost from the COVID-19 pandemic,”
by Carlos Moreira and Anand Rao, PwC, 2021.
24. Supra note 8.
25. Supra note 14.
www.mastercontrol.com