Regulatory Q&A Forum
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How to determine the necessary performance testing for a 510k?
When developing a 510(k) submission for a device with technological differences from its predicate—such as an infusion pump incorporating updated software and a new user interface—how can sponsors con...
How do I justify substantial equivalence with multiple predicate devices?
When pursuing a 510(k) using a 'split predicate' strategy, such as for an orthopedic screw combining a novel thread design from one predicate with a unique biocompatible coating from another, what is ...
For sponsors of Class I or low-risk Class II devices, navigating the FDA's General Controls for labeling can present subtle but significant compliance risks. Beyond simply listing the device name, wha...
For a medical device manufacturer, particularly one developing a novel technology like an AI-powered diagnostic software or a new type of wearable sensor, what is a systematic process for determining ...
For a small medical device company or startup, successfully navigating the Medical Device User Fee Amendments (MDUFA) Small Business Determination (SBD) process is often a critical financial step befo...
How do you respond to an FDA Additional Information (AI) request for a 510k?
When a sponsor receives an Additional Information (AI) request for a 510(k) submission, such as for a Class II diagnostic imaging software, what is a comprehensive framework for developing a strategic...
What cybersecurity documentation does FDA require for a 510k submission?
When preparing a 510(k) for a 'cyber device,' such as a Software as a Medical Device (SaMD) or a network-connected monitor, how can sponsors construct a cybersecurity documentation package that provid...
What is the average review time for a 510k 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 restarts. While this is a standard part of the process, it creates signifi...
How to properly document substantial equivalence to multiple predicate devices?
When a medical device sponsor develops a novel product by combining key features from two or more legally marketed devices—such as integrating a specific sensor technology from one cleared device with...
How to determine substantial equivalence with an older predicate device?
When preparing a 510(k) for a modern device, such as a digital patient monitoring system, how can a sponsor establish substantial equivalence to a predicate cleared decades ago that lacks data for cur...
How do you determine substantial equivalence for a 510k submission?
When preparing a 510(k) for a device with technological differences from its predicate, such as an orthopedic implant with a novel surface coating, how can a sponsor build a scientifically robust and ...
For a small medical device company aiming to qualify for the FDA’s Small Business Determination (SBD) program to reduce premarket submission user fees, what are the critical steps and common pitfalls ...
For manufacturers of novel food ingredients, such as a new plant-based protein or a fermentation-derived flavoring agent, what are the comprehensive steps and best practices for establishing a defensi...
What is the FDA's current 510k review timeline in 2024?
While Medical Device User Fee Amendments (MDUFA) performance goals establish a target for the number of 'FDA days' to review a 510(k) submission, regulatory project managers must plan for a 'Total Tim...
What is the cost difference for a 510k small business user fee?
For medical device companies, particularly startups, how is eligibility for the MDUFA small business discount on a 510(k) user fee determined, and what are the key procedural steps and common pitfalls...
How does the FDA calculate the 90-day 510k review clock?
While the FDA’s performance goal for a 510(k) review is 90 calendar days, this target often creates confusion as it only reflects the time the submission is actively under FDA review. The total time f...
For a sponsor developing a novel medical device, such as a Class II diagnostic Software as a Medical Device (SaMD), what are the best practices for structuring a Pre-Submission (Q-Sub) package to elic...
For a medical device startup planning a submission in fiscal year 2025 (which begins October 1, 2024), what are the critical strategic considerations and procedural steps for successfully obtaining Sm...
What are the most common reasons for a 510k 'Refuse to Accept' letter?
Beyond ensuring basic administrative requirements like correct eCopy formatting are met, what specific, high-risk documentation areas should sponsors meticulously review to prevent a 510(k) Refuse to ...
What are the most common reasons for an RTA hold on a 510k submission?
When preparing a 510(k) submission for a Class II device, such as an orthopedic implant or a device with software, what are the most common yet avoidable deficiencies that lead to a Refuse to Accept (...