Regulatory Q&A Forum
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How does an RTA hold affect the FDA 510k review timeline?
When a medical device sponsor submits a 510(k) for a product, such as a new diagnostic imaging software, receiving a Refuse-to-Accept (RTA) hold can cause significant project delays. Unlike an Additio...
When does a software change to a cleared device require a new 510k?
For a manufacturer with a 510(k)-cleared medical device, such as a diagnostic imaging workstation, what is a comprehensive and defensible methodology for determining if a planned software update requi...
What are the FDA user fees for a 510k submission in 2024?
For regulatory affairs professionals budgeting for a 510(k) submission, what are the key strategic and operational considerations for navigating the MDUFA user fee requirements for the current fiscal ...
How to determine if a device change requires a new 510k submission?
For a manufacturer with a 510(k)-cleared device, such as an electrosurgical unit, what is a robust and defensible framework for determining if a proposed modification requires a new 510(k) submission ...
What is the average FDA 510k review time after an AI request?
After a sponsor submits a comprehensive response to an FDA Additional Information (AI) request for a 510(k), the review clock officially restarts, but forecasting the time until a final clearance deci...
How to write a substantial equivalence argument for a 510k submission?
When preparing a 510(k) for a device that introduces a novel feature to an established design, such as a Class II orthopedic bone screw with a new surface coating intended to improve osseointegration,...
How much does a 510k submission cost including consultant and testing fees?
When planning for a 510(k) submission, how can a medical device sponsor develop a comprehensive budget that goes beyond the predictable FDA user fee to accurately forecast the major, variable costs as...
What are the 2024 FDA user fee costs for a small business 510k submission?
For a small medical device company preparing its first 510(k), successfully qualifying for the reduced small business user fee is a critical financial step. Beyond simply meeting the gross receipts or...
How long does the FDA 510k review clock stop during an Additional Information request?
When a medical device sponsor's 510(k) submission is placed 'on hold' following an Additional Information (AI) request from the FDA, what are the detailed operational mechanics and strategic best prac...
When does a modification to a cleared device require a new 510k?
When a manufacturer modifies a 510(k)-cleared device—for instance, implementing a software patch for an infusion pump to enhance cybersecurity, or changing a material in a single-use catheter due to a...
How to justify substantial equivalence with multiple predicate devices?
When a medical device sponsor develops a device by combining key features from multiple legally marketed predicates—for instance, an orthopedic implant using a porous coating from Predicate A and a lo...
How does an FDA Additional Information request affect the 90-day review clock?
When a sponsor submits a 510(k) for a Class II medical device, such as a novel patient monitoring system or diagnostic software, project timelines are often anchored to the FDA's 90-day review goal. H...
What cybersecurity documentation is required for a SaMD 510k submission?
For a connected Software as a Medical Device (SaMD) undergoing 510(k) review, what defines a comprehensive cybersecurity documentation package that sufficiently demonstrates a "secure by design" appro...
How does the FDA 90-day review clock for a 510k actually work?
While the FDA’s goal for a 510(k) review is 90 calendar days, this timeline represents "FDA Days" and often differs significantly from the total time to clearance. For sponsors of devices like a Class...
How much does a 510k submission cost with MDUFA fees?
When planning a 510(k) submission for a new medical device, such as a Class II AI-powered diagnostic software, accurately forecasting costs is a critical step for financial planning and securing inves...
What is the total cost of a 510k submission including consultant fees?
When calculating the total cost of a 510(k) submission, how can sponsors develop a comprehensive budget that accurately forecasts expenses beyond the standard FDA user fee? For a Class II device, such...
How to effectively search the FDA 510k database for predicate devices?
Beyond basic keyword searches, what advanced, multi-step strategies can medical device sponsors employ to effectively navigate the FDA 510(k) database and identify an optimal predicate device? For a n...
What cybersecurity documentation does the FDA require for a 510k?
For a 'cyber device'—such as a cloud-connected patient monitor or smart infusion pump—what are the fundamental cybersecurity documentation components that the FDA expects to see within a 510(k) premar...
What are common reasons for a 510k Refuse to Accept (RTA) letter?
What are the most common administrative and content-related omissions that can lead to a 510(k) submission receiving a Refuse to Accept (RTA) letter from the FDA? The RTA policy is designed to act as...
How to write a strong substantial equivalence rationale for a 510k submission?
When preparing a 510(k) submission for a new medical device that has technological differences compared to its predicate, what are the key elements of a robust Substantial Equivalence (SE) rationale? ...