Regulatory Q&A Forum
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What performance data does FDA require for a 510k submission?
For a Class II medical device with clear technological differences from its chosen predicate—such as an orthopedic implant with a novel biocompatible coating or an infusion pump with significant softw...
When developing a combination product, such as an antimicrobial-coated catheter or a pre-filled injector pen, how should a sponsor definitively determine the product's Primary Mode of Action (PMOA) to...
What are the most common reasons for an FDA 510k Refuse to Accept (RTA) hold?
Beyond a surface-level check against the FDA's Refuse to Accept (RTA) checklist, what systematic, in-depth review process can a sponsor implement to proactively identify and resolve common administrat...
How do I justify substantial equivalence using multiple predicate devices?
When a sponsor develops a novel medical device by creating a hybrid system—for example, an electrosurgical device that combines a unique energy waveform from Predicate A with an advanced tissue-monito...
For a company developing a digital health product, such as a wearable sensor that analyzes sleep data, what is a robust analytical framework for determining whether the product is a regulated medical ...
What cybersecurity documentation is required for a network-connected device 510k submission?
For manufacturers of network-connected medical devices, such as a Wi-Fi-enabled patient monitor, what are the essential components of a robust cybersecurity documentation package for a 510(k) submissi...
How can a manufacturer of a lower-risk device, such as a Class I handheld diagnostic instrument or a Class II software-based patient monitoring tool, strategically implement a "right-sized" Quality Ma...
What are the FDA user fees for a 510k submission in 2024?
When preparing a 510(k) submission, what are the critical process steps and documentation requirements a sponsor must manage to ensure the correct MDUFA user fee is paid, thereby avoiding a Refuse to ...
What are the current MDUFA user fees for a small business 510k submission?
For a small medical device company planning its first 510(k) submission, what are the critical steps and strategic considerations for successfully qualifying for a reduced MDUFA user fee through the S...
What is the FDA review timeline for an eSTAR 510k in 2024?
With the mandatory transition to eSTAR for 510(k) submissions, sponsors of Class II devices, such as novel diagnostic imaging software or connected surgical instruments, are re-evaluating their go-to-...
How to find a predicate device for a novel technology?
When a medical device sponsor develops a product with novel technological characteristics but an intended use identical to legally marketed devices, what is the strategic framework for determining if ...
What is the average FDA 510k review timeline in 2024?
While the FDA's MDUFA performance goal for reviewing a 510(k) submission is 90 calendar days, the total time from submission to clearance often extends significantly longer. For sponsors planning a pr...
What biocompatibility testing is required for a Class II implant?
For a sponsor developing a 510(k) for a Class II implantable device, such as a PEEK spinal cage or a titanium bone screw with permanent tissue contact, what constitutes a robust, risk-based biocompati...
How to prove substantial equivalence if my predicate is not identical?
When a manufacturer modifies a previously cleared 510(k) device—for example, updating an infusion pump with a new motor and software incorporating enhanced cybersecurity features—while keeping the int...
What are the MDUFA user fees for a 510k small business application?
For a small medical device company preparing a 510(k) submission, successfully qualifying for the reduced MDUFA user fee is a critical financial planning step. Beyond simply identifying the fee on the...
What is the FDA's Refuse to Accept (RTA) policy for 510k submissions?
When preparing a 510(k) for a Class II medical device, particularly one with significant software or cybersecurity elements like a connected infusion pump or diagnostic SaMD, what are the most critica...
How is the 90-day FDA review clock for a 510k actually calculated?
The FDA’s 90-day performance goal for 510(k) review is a widely cited metric, but it represents 'FDA Days,' not calendar days, a distinction that significantly impacts project timelines. For a Class I...
What biocompatibility testing is required for a 510k medical device?
For a Class II device with patient-contacting components intended for a 510(k) submission, what constitutes a robust and defensible biocompatibility evaluation strategy that anticipates common FDA que...
How to write a substantial equivalence argument for a 510k submission?
When preparing a 510(k) for a device that has different technological characteristics from its predicate—such as a novel material, a different energy source, or a new software algorithm—how can sponso...
How to justify substantial equivalence with multiple predicate devices?
When a medical device manufacturer develops a new device that combines features from multiple legally marketed devices—for example, a new catheter incorporating an advanced sensor from Predicate A and...