Blue Goat CyberSMMedical Device Cybersecurity
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    Comparison guide

    RTA vs Deficiency Letter

    Both can stall a 510(k) - but they hit at different review stages and the clock behaves very differently.

    The details

    Side-by-side breakdown

    Dimension Refuse-To-Accept (RTA) Deficiency Letter
    Review stage Day 1-15 administrative screening. Day 60-90 substantive review.
    Trigger Submission is administratively incomplete (e.g. cybersecurity package missing). Reviewer needs more information to make a clearance decision.
    Clock impact Review clock does not start. You have 180 days to respond before withdrawal. Clock stops on the day the letter issues. Resumes when the FDA accepts your response.
    Typical cybersecurity causes Missing SBOM, missing threat model, missing labeling, no SPDF documentation. Inadequate threat-model coverage, weak pen-test scope, VEX inconsistencies, postmarket plan gaps.
    Response window 180 days; multiple resubmissions allowed. FDA-specified; typically 180 days but can be shorter.
    Avoidance strategy Use the eSTAR checklist + a pre-submission cybersecurity audit. Build the cybersecurity package against the 2026 final guidance with full traceability to AAMI SW96 and IEC 81001-5-1.
    Guidance

    When to use which

    For an RTA, treat it as a checklist exercise. Map every missing item to the eSTAR cybersecurity section and resubmit within weeks, not months.

    For a deficiency letter, respond in one consolidated package addressing every comment with traceability to your risk file. Partial responses extend the clock and invite follow-ups.

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