Confirm the response deadline and review status in the actual FDA notice. Plan documentation, engineering fixes, retests, and manufacturer review against that deadline.
We review the hold letter, its deadline, and your existing evidence to define the technical response. The proposal identifies artifact updates, testing needs, manufacturer inputs, and dates. The FDA decides whether the response addresses its concerns.
Free 30-min call · Senior US expert · Mutual NDA before the call
275+
FDA submissions supported
Zero
cybersecurity rejections
24 hrs
Quote turnaround
Last updated
“Blue Goat's niche expertise in FDA-facing cybersecurity made all the difference. Their reports were built with the FDA's expectations in mind; it gave us confidence that we were submitting exactly…”
Scott Odland, Solutions Architect, Rhaeos
Trusted by medical device teams worldwide
Lifecycle scope
What's in your hold-letter response
The proposal identifies included deliverables, exclusions, manufacturer inputs, and review responsibilities for this engagement.
01
Hold-letter triage on the discovery call
Senior reviewer reads your letter, maps every finding to required artifacts, and returns a written closure plan with effort estimate.
02
FDA 2026 guidance aligned
Every response is written against the February 2026 final premarket cybersecurity guidance and Section 524B(b)(1)-(3).
03
Evidence mapped for resubmission
Updated cybersecurity evidence is organized with response and page references for your regulatory team to review and assemble. We do not promise that a hold will be lifted.
04
Targeted, not exhaustive
We identify the documentation and testing needed to address the letter, including dependencies on other evidence. The proposal records scope and exclusions.
05
Direct reviewer-channel format
Cover letter and redlines structured the way cybersecurity reviewers want: finding → response → evidence → page reference.
06
Fixed fee, hold-to-close
One quote covers the response and any follow-up exchanges with the FDA until the cybersecurity hold is lifted.
Common FDA findings
What FDA cybersecurity hold letters usually ask for
Hold letters cluster around a handful of recurring asks. Recognizing the pattern in yours shortens the response cycle.
Threat model rewrite with multi-patient harm view
Single-device STRIDE submissions are getting held for missing fleet-level harm analysis. Most common ask under the February 2026 final guidance.
SBOM work + optional VEX communication
Component list without affected/not-affected/fixed/under-investigation status for each listed CVE is the second most common hold trigger.
Documented patch delivery mechanism
524B(b)(1) requires a written description of how patches reach fielded devices. Verbal process descriptions get held; controlled outputs don't.
Pen test mapped to the threat model
Reviewers want to see each pen test finding traced back to a threat-model entry. Standalone pen test reports get held for traceability.
Blue Goat Cyber vs. the alternatives
What you actually get versus a generic regulatory consultant or a re-spin in-house while the clock burns.
Capability
Blue Goat Cyber
Generic regulatory consultant
In-house
Hold-letter response track record
Routine - written for the reviewer who sent it
Treats hold like any other AI letter
First time under hold pressure
Speed under deadline
Dates agreed after letter and evidence review
Hourly, drifts with scope
Competes with launch work
Point-by-point response mapping
Mirrors hold-letter exactly
General rewrite, items missed
Built from scratch under pressure
Evidence package
Updated SPDF + SBOM/VEX + threat model + pen test
Documentation only, no fresh testing
Multiple owners, integration gaps
Pricing model
Fixed fee, revisions included
Hourly + change orders
Hidden internal cost
What happens after you book the call
1Scoping
Review your letter and evidence
Discuss architecture, available records, access, responsibilities, and target dates. Agree confidential handling before transferring device material.
2Proposal
Agree deliverables, fee, and dates
The proposal identifies included work, exclusions, manufacturer inputs, and delivery milestones. The 24-hour quote turnaround is separate from delivery, remediation, and review time.
3Agreed dates
Prepare the response evidence
Update the artifacts and testing identified by the letter review. Deliver a point-by-point response with evidence references for your regulatory team to review and submit. The FDA decides the outcome.
"Blue Goat's niche expertise in FDA-facing cybersecurity made all the difference. Their reports were built with the FDA's expectations in mind; it gave us confidence that we were submitting exactly what reviewers want to see."
Scott Odland, Solutions Architect, Rhaeos
Support matched to your scope
If the FDA raises a cybersecurity question, we answer it at no extra cost until the cybersecurity portion is closed.
Mutual NDA before the call
We sign a mutual NDA before the initial call so you can share device details, architecture, and FDA correspondence freely.
Fixed-fee quote within 24 hours of the call
The quote identifies deliverables, assumptions, and dates. Quote turnaround is separate from the time needed to deliver the work.
Senior US engineers, fixed fee
Senior-led cybersecurity work within the agreed scope. Your team reviews the evidence and owns risk, release, and submission decisions.
Common questions
Who you're talking to
Christian Espinosa, Founder & CEO
MBA, CISSP · U.S. Air Force Academy graduate · 30+ years in cybersecurity
Christian leads the senior medical device cybersecurity team behind 275+ FDA submissions supported, zero cybersecurity rejections. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.
30-minute call with a senior medical device cybersecurity expert. Fixed-fee quote within 24 hours of the scoping call. Delivery and review dates are agreed separately.