Regulatory Q&A Forum
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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...
How do I choose the best predicate device for my 510k submission?
When developing a 510(k) submission for a device incorporating novel features, such as an electrosurgical device with a new tissue-sensing feedback algorithm, what is the most effective analytical fra...
What is the average FDA 510k review time in 2024?
While the FDA's MDUFA performance goal for a 510(k) submission is a standard benchmark, experienced sponsors know that the "total time to clearance" often extends beyond this target due to holds and r...
How much does a 510k submission cost with FDA fees in 2024?
When building a financial plan for a new Class II medical device, such as a novel surgical instrument or a software platform, how should a sponsor strategically navigate the mandatory FDA 510(k) user ...
What are the 2024 MDUFA user fees for a 510k submission?
For medical device companies preparing a 510(k) submission, what are the key procedural considerations for correctly identifying and paying the appropriate Medical Device User Fee Amendments (MDUFA) f...
How can I prove substantial equivalence if my 510k predicate device is old?
When preparing a 510(k) submission for a modern medical device, such as a connected infusion pump or a diagnostic Software as a Medical Device (SaMD), a manufacturer might select a predicate device th...
When does a modification to a cleared device require a new 510k?
When a manufacturer modifies a 510(k)-cleared device, such as updating the software or changing a material component in an infusion pump, what is the detailed analytical framework for deciding between...
What are the total costs for a 510k beyond the FDA user fees?
When a medical device manufacturer, particularly a startup, develops a budget for a 510(k) submission, how can they accurately forecast the total investment beyond the publicly listed FDA user fees? S...
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 ...