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    FDA RTA - Cybersecurity

    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.

    • Discovery call covers every RTA checklist gap
    • Complete SPDF rebuild (eSTAR-ready)
    • SBOM (SPDX or CycloneDX) with VEX
    • STRIDE threat model + risk assessment
    • Penetration test report (device, cloud, wireless)
    • Section 524B attestation + traceability

    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

    • Intuitive
    • Natera
    • bioMérieux
    • Inogen
    • VitalConnect

    Trusted by medical device teams worldwide

    Intuitive Surgical logo
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    Inogen logo
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    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

    1. 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.

    2. 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.

    3. 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

    Christian Espinosa, Founder & CEO of Blue Goat Cyber

    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.

    RTA'd on cybersecurity? Let's resubmit.

    30-minute call with a senior medical device cybersecurity expert. Fixed-fee quote to resubmit within 24 hours of the call.

    Replies in 1 business dayMutual NDA firstUS-based senior engineerNo sales pitch