Meet the FDA postmarket cybersecurity guidance and Section 524B: SBOM monitoring, vulnerability triage, VEX, and coordinated disclosure for devices on the market.
One fixed fee
Unlimited retests
Deficiency responses covered
If the FDA raises a cybersecurity question, we answer it at no extra cost until the cybersecurity portion is closed.
275+ devices supported · No cybersecurity-related rejections to date
CISA KEV adds catalogued exploited CVEs on a rolling basis. A monthly review cadence isn't fast enough anymore - reviewers and customers expect SBOM-triggered triage within days.
Full postmarket cybersecurity program built to the FDA Postmarket Management of Cybersecurity in Medical Devices guidance and Section 524B(b)(1) - coordinated vulnerability disclosure (CVD), SBOM monitoring, threat intel, patch management, and FDA reporting. 275+ devices supported.
Postmarket cybersecurity management plan
Coordinated vulnerability disclosure (CVD) program
Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.
01
Postmarket guidance aligned
Built to FDA Postmarket Management of Cybersecurity in Medical Devices guidance and Section 524B(b)(1) - controlled, uncontrolled risk, and compensating controls all covered.
02
Coordinated vulnerability disclosure
Public CVD policy, intake workflow, triage SLA, and disclosure timelines - modeled on ISO/IEC 29147 and 30111, accepted by FDA reviewers.
03
SBOM monitoring + VEX (powered by GoatWatch)
Your shipping SBOM is matched daily in GoatWatch, our purpose-built postmarket platform, against NVD, CISA KEV, and vendor advisories. New CVEs triaged, VEX statements regenerated, and customer comms drafted on a fixed cadence.
04
Patch + update governance
Decision framework for emergency patches, planned updates, and end-of-support - every decision documented and audit-ready.
05
FDA reporting workflows
When a vulnerability triggers an FDA report (uncontrolled risk, MDR-eligible event), the workflow, template, and timeline are already in place.
06
Fixed fee, annual program
Monthly retainer or annual fixed fee. No per-CVE invoicing. Every quarter you get a written postmarket program review.
Common FDA findings
Postmarket gaps we find on most programs
When we audit an existing postmarket cybersecurity program, these are the gaps that show up first - and the ones FDA inspectors notice.
No CVD intake or public policy
No security@ address, no published disclosure policy, no triage SLA. Researchers either go public or go away - both are bad outcomes.
SBOM shipped but not monitored
An SBOM was generated for the submission and never looked at again. New CVEs against shipped components are not being detected, scored, or VEX'd.
No uncontrolled-risk decision path
When a vulnerability crosses the uncontrolled-risk threshold, there is no documented path to an FDA postmarket report - so it does not get filed.
Patches not authenticated end-to-end
Software updates ship without signature verification on the device side, or without rollback. A 524B(b)(1) finding waiting to happen.
Legacy devices with no end-of-support plan
Devices past their supported life are still in clinical use, with no documented compensating controls or sunset communication to customers.
Customer comms ad-hoc and inconsistent
Every CVE triggers a fresh internal debate about what to tell customers. No template, no cadence, no audit trail of what was disclosed when.
Blue Goat Cyber vs. the alternatives
What you actually get versus a reactive MDR vendor or running postmarket monitoring on a spreadsheet.
Capability
Blue Goat Cyber
Reactive MDR vendor
In-house
Built to FDA postmarket guidance + 524B(b)(1)
Mapped to every clause, reviewer-ready
Generic SOC/MDR playbook
Built from scratch, often incomplete
Coordinated Vulnerability Disclosure (CVD) program
Policy, intake, triage, comms - operated for you
Not offered
Hard to staff, easy to neglect
SBOM + VEX kept current per release
Continuous, with per-CVE VEX statements
Static SBOM at handoff
Ages quickly without governance
Pricing model
Fixed-fee program, no per-CVE invoicing
Per-alert / per-incident billing
Unbudgeted internal time
Quarterly reviewer-format evidence
Included, audit-ready
Tickets only, no narrative
Pulled together at audit time
What happens after you book the call
1Day 0
Mutual NDA + 30-min discovery call
Mutual NDA, then a 30-minute call to map your devices in-market, existing postmarket controls, SBOM coverage, and any open CVEs or customer disclosures.
2Days 1-14
Program stand-up
CVD policy published, security@ intake live, your SBOM loaded into GoatWatch with NVD/KEV/vendor feeds wired up, and the patch/update decision framework documented inside your QMS.
3Ongoing
Triage, VEX, and FDA reporting
New CVEs triaged within SLA, VEX statements regenerated, customer comms drafted, and FDA postmarket reports filed when thresholds are met. Quarterly written program review.
"Thoroughly enjoyed working with Blue Goat Cyber! Very knowledgeable and professional. Would work with again without hesitation!"
- Eugene Yu, Director of Quality Assurance, RAQA Consultant
Cybersecurity deficiency remediation included
If the FDA raises a cybersecurity deficiency, we fix it at no additional cost. 275+ devices supported.
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
No sales pressure. After the call, you get a concrete written strategy mapped to Section 524B and the FDA February 2026 final guidance.
Senior US engineers, fixed fee
Senior-led delivery on every FDA-facing artifact. No offshoring, no hourly billing. Revisions included. Every artifact is eSTAR-ready.
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+ devices supported. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.