FDA Refuse to Accept (RTA) for Cybersecurity? Resubmit in Weeks
FDA Refuse to Accept (RTA) cybersecurity response services - resubmit in weeks, not months.
An RTA resets the FDA clock to zero. Every week before you refile is a week your competitors keep shipping - we move in days, not months.
An RTA on cybersecurity grounds means your 510(k) never made it past the FDA acceptance checklist - usually a missing SPDF, SBOM, threat model, or Section 524B attestation. We rebuild the cybersecurity section eSTAR-ready and get you resubmitted fast. Free 30-min discovery call.
Free 30-min call · Senior US expert · Mutual NDA before the call
FDA submissions supported
250+
Cybersecurity rejections
0
Quote turnaround
24 hrs
Last updated
“The timeliness of this project exceeded my expectations-this was not my experience with other vendors. Blue Goat Cyber delivered a thorough, detailed report and complete testi…”
Tim Sandberg, Vice President of IT Operations, Matrix One
Trusted by medical device teams worldwide
Lifecycle scope
What we rebuild for your RTA resubmission
Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.
01
Full RTA checklist coverage
Every cybersecurity item on the FDA acceptance checklist is present, labeled, and formatted exactly as reviewers expect in eSTAR.
02
FDA 2026 guidance aligned
Built to the February 2026 final premarket cybersecurity guidance and Section 524B(b)(1)-(3) - no second RTA on cyber grounds.
03
SBOM with VEX, ready to attach
Machine-readable SPDX or CycloneDX SBOM, NTIA minimum elements (now stewarded by CISA), plus VEX statements addressing every CVE in shipping software.
04
STRIDE threat model
End-to-end threat model with multi-patient harm, updateability, and use-environment views. Aligned to AAMI TIR57 / ANSI/AAMI SW96.
05
Pen test mapped to threat model
Device, cloud, mobile, and wireless attack surfaces tested independently. Findings traced back to threat model and risk file.
06
Fixed fee, unlimited retests
One quote covers rebuild, retest, and any follow-up exchanges until the cybersecurity section is accepted.
Common FDA findings
Why cyber-grounded RTAs land in the first place
The RTA letter usually names a checklist line. The underlying root cause is almost always one of these - and we close all six in the rebuild.
No Section 524B attestation in eSTAR
The attestation block isn't present, or it's there but the supporting evidence sections are empty. Acceptance reviewer flags it on the first pass.
SBOM missing entirely or wrong format
Submission shipped without an SBOM, or with a non-machine-readable PDF instead of SPDX/CycloneDX. Auto-checklist fail.
Threat model not attached
A threat model exists internally but never made it into the eSTAR cybersecurity attachments. Reviewer can't accept what isn't there.
Pen test report scope mismatch
Pen test report covers only firmware while the device clearly has cloud and mobile interfaces. Reviewer rejects on incomplete scope.
SPDF documented but not in eSTAR
Secure Product Development Framework written for internal use, not attached as a controlled output in the submission. Easy RTA trigger.
Cybersecurity labeling missing
No customer security guide, no SBOM disclosure, no end-of-support communication. Reviewer cites missing transparency under 524B(b)(2).
Blue Goat Cyber vs. the alternatives
What you actually get versus a generic regulatory consultant or scrambling to fix the cyber RTA findings in-house.
Capability
Blue Goat Cyber
Generic regulatory consultant
In-house
RTA cybersecurity-checklist coverage
Every cyber RTA item, mapped and closed
Regulatory focus, cyber items left thin
First time mapping the checklist
Speed to resubmission
Reviewer-ready package in 2-4 weeks
Hourly, drifts with scope
Competes with engineering work
eSTAR-attachable deliverables
Drop-in for resubmission
Word docs that need reformatting
Reformatted each time
Track record
250+ submissions, zero cyber rejections
Variable, cyber-specific track unclear
First-submission risk
Pricing model
Fixed fee, unlimited revisions until accepted
Hourly + change orders
Hidden internal cost
RTA checklist triage
How we triage every RTA checklist cybersecurity gap
What happens after you book the call
1Day 0
Mutual NDA + 30-min RTA scoping
We sign a mutual NDA, then walk your RTA letter, checklist gaps, and any prior cybersecurity work to scope the rebuild.
2Day 1
Point-by-point rebuild plan + fixed-fee quote
Point-by-point rebuild plan mapped to every checklist gap in your RTA letter, each gap tied to the artifact that closes it, with a fixed-fee quote to resubmit.
3Weeks 1-4
eSTAR-ready cybersecurity rebuild
Full cybersecurity section rebuilt: SPDF, SBOM with VEX, threat model, pen test, and Section 524B attestation - dropped straight into eSTAR.
"The timeliness of this project exceeded my expectations-this was not my experience with other vendors. Blue Goat Cyber delivered a thorough, detailed report and complete testing faster than I anticipated, without compromising quality."
- Tim Sandberg, Vice President of IT Operations, Matrix One
Cybersecurity deficiency remediation included
If the FDA raises a cybersecurity deficiency, we fix it at no additional cost. 250+ FDA submissions, zero cybersecurity rejections to date.
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. Unlimited revisions. 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 250+ FDA submissions, zero cybersecurity rejections. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.