Bruce believes a winter break could help to revitalise the FA Cup, which he won three times during his spell at Manchester United.
He told the Black Cats’ official website: “We have to try to arrest something.
“I have had the privilege of going all the way in the FA Cup, and getting to the latter stages is a fantastic thing for any club.
“My thoughts on it are that the competition needs a radical revamp.
“For example, the third round is usually the first Saturday after New Year when everyone is spent up from Christmas, and it becomes a problem for people after they have shelled out the money for their season tickets.
“Maybe we could try to restructure things. I’ve seen Sir Alex’s quotes on a mid-season break – if we’re going to be successful as a nation, that has to come into play.
“We are the only nation who doesn’t do it. Certainly that would mean a lesser summer, but [a mid-season break] would be common sense and I agree with Sir Alex.
“You could start off your fixtures again with two FA Cup ties when people haven’t seen football for a while. We could kick off again with back-to-back FA Cup ties.”