Regulatory Q&A Forum
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How does the FDA eSTAR program change 510k submission requirements?
Given the mandatory transition to the eSTAR template for 510(k) submissions, how should regulatory teams fundamentally restructure their preparation process for a Class II device, such as a connected ...
What is the average 510k review time after an FDA AI request?
When a medical device manufacturer receives an Additional Information (AI) request for a 510(k) submission, the 90-day FDA review clock is placed on hold, creating significant timeline uncertainty. Wh...
How do I determine if a device modification requires a new 510k submission?
When modifying a 510(k)-cleared device, such as updating the software of an infusion pump to add a new clinical feature, how should a manufacturer systematically determine if the change can be documen...
When is a new 510k required for a medical device modification?
When a manufacturer of a 510(k)-cleared device—such as an infusion pump or a diagnostic catheter—implements a modification, what is a robust, defensible framework for determining if the change require...
How to respond to an FDA Additional Information (AI) request for a 510k?
When a medical device sponsor receives a complex Additional Information (AI) request for a 510(k) submission, particularly one that challenges a core component like the choice of predicate and require...
How to write a substantial equivalence comparison table for a 510k?
In constructing a 510(k) substantial equivalence (SE) comparison table, what strategic approaches can a sponsor take to ensure the table functions not just as a list of features, but as a compelling, ...
How much does a 510k submission cost including consultant and testing fees?
When planning a 510(k) submission, how can a medical device sponsor create a realistic budget that accounts for the full spectrum of costs beyond the standard FDA user fee? Beyond this initial, fixed ...
What performance data is needed for a software as a medical device 510k?
When preparing a 510(k) submission for a Software as a Medical Device (SaMD), such as an AI algorithm that analyzes medical images for diagnostic purposes, how should a manufacturer strategically desi...
What are the most common reasons for an RTA hold on a 510k submission?
To prevent a Refuse to Accept (RTA) hold on a 510(k) submission, what are the most critical yet frequently overlooked deficiencies that sponsors should address? Beyond basic administrative checklist i...
How to avoid a Refuse to Accept (RTA) hold from the FDA?
Given that a Refuse to Accept (RTA) hold on a 510(k) submission is an administrative rejection that occurs before any substantive scientific review, what are the most effective proactive strategies an...
What is the FDA 510k review clock after submitting an AI response?
After a sponsor of a Class II medical device, such as a diagnostic imaging software, submits a comprehensive response to an FDA Additional Information (AI) request, restarting the 510(k) review clock ...
What is the 2024 FDA user fee for a standard 510k submission?
When budgeting for a new Class II device submission, such as a next-generation infusion pump or a novel diagnostic assay, accurately accounting for the FDA user fee is a critical project management st...
How do I respond to an FDA Additional Information (AI) request?
When a sponsor of a Class II medical device, such as a diagnostic imaging software, receives a complex Additional Information (AI) request from the FDA, what is a comprehensive strategic framework for...
What biocompatibility testing is required for a 510k surface device?
When preparing a 510(k) for a surface device with direct skin contact, such as a reusable surgical instrument or a topical wound dressing, how should sponsors develop and document a comprehensive, ris...
When does the FDA require clinical performance data for a 510k?
When preparing a 510(k) submission for a device with significant technological differences from its predicate—such as a diagnostic IVD incorporating novel biomarkers or an implantable device made from...
How do I qualify for the small business discount for 510k user fees?
For small medical device companies, particularly startups preparing their first 510(k), qualifying for reduced MDUFA user fees through the FDA’s Small Business Determination (SBD) program is a critica...
How to justify substantial equivalence using multiple predicate devices?
When a new medical device, such as a cardiac ablation catheter, incorporates technology from multiple legally marketed devices—for instance, combining the handle design from one predicate with the sen...
How much does a 510k submission cost including consultant fees?
For a medical device company, particularly a startup preparing its first 510(k) for a Class II device like a new surgical instrument or diagnostic software, how can a project manager develop a compreh...
How to justify substantial equivalence with different materials than the predicate?
When a medical device sponsor prepares a 510(k) submission for a device, such as a catheter or surgical implant, that incorporates a significant material change from its predicate—for instance, using ...
How to choose the best predicate device for a 510k submission?
When preparing a 510(k) submission for a new device, such as a novel handheld ultrasound probe, sponsors frequently encounter a strategic dilemma where potential predicate devices have conflicting str...