The critical gaps in a medical device SME's QMS are not in clause numbers. They are in the interfaces nobody documents: between design and production, between risk management and validation, between written procedures and what actually happens at the workstation.
An auditor who has only ever audited systems does not see these areas. We see them because we built and maintained QMSs before auditing them. The difference is not methodological. It is a matter of perspective.
Our priority: verifying that conformity evidence exists where a notified body will look for it, and that the system's critical interfaces are documented — not just the clauses.