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    PMA & De Novo Cybersecurity

    PMA & De Novo Cybersecurity Submissions

    PMA and De Novo cybersecurity submission services aligned to the FDA February 2026 final guidance.

    PMA and De Novo reviewers expect a multi-patient harm view and an operational postmarket program at the time of filing - not promises. Submissions that ship without them are drawing Major Deficiency Letters.

    Higher-risk submissions need deeper cybersecurity evidence - multi-patient harm views, complete pen-test scope, and a fielded postmarket cybersecurity management plan. We own all of it for PMA and De Novo, aligned to Section 524B and the FDA February 2026 final guidance. 250+ submissions, zero cyber rejections.

    • PMA & De Novo cybersecurity sections
    • Multi-patient harm threat model
    • Full-scope penetration testing
    • SPDF + QMSR / ISO 13485 integration
    • Postmarket cybersecurity management plan
    • Major Deficiency / hold-letter response support
    • Fixed fee, quoted in 24 hrs
    • No hourly billing
    • No change orders
    • 2-4 wk turnaround
    • Unlimited revisions

    Free 30-min call · Senior US expert · Mutual NDA before the call

    250+
    FDA submissions supported
    0
    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

    • Intuitive
    • Natera
    • bioMérieux
    • Inogen

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    Lifecycle scope

    What's different about PMA & De Novo cybersecurity

    Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.

    01

    Multi-patient harm view

    Threat model includes a multi-patient harm analysis required for higher-risk devices - not just the single-patient view sufficient for many 510(k)s.

    02

    Full pen-test scope

    Device, cloud, mobile, wireless, BLE/RF, and any clinical workflow integrations. Independent testers, documented scope, and reviewer-ready findings.

    03

    SPDF inside your QMS

    Secure Product Development Framework integrated with QMSR (21 CFR 820), ISO 13485 design controls, and your ECO/change management process.

    04

    Postmarket plan that holds up

    Vulnerability monitoring, CVD procedures, patch authentication, rollback, and Section 524B(b)(1) postmarket reporting - operational before market.

    05

    Major Deficiency response

    If a Major Deficiency Letter or hold lands, we author the point-by-point response, cover letter, and traceability matrix inside your 180-day clock.

    06

    Pre-Sub (Q-Sub) support

    We help you frame the cybersecurity questions for a Pre-Submission meeting so reviewer expectations are locked in before you file.

    Common FDA findings

    Where PMA & De Novo cyber submissions get stopped

    Higher-risk pathways get deeper FDA review. These are the cybersecurity gaps that trigger Major Deficiency Letters on PMA and De Novo submissions.

    Single-patient threat model only

    Threat model considers harm to one patient but not the multi-patient cascade - the failure mode FDA expects to see addressed on PMA-class devices.

    Pen test scope misses cloud or RF

    Device-only pen test with no cloud API or wireless coverage. Reviewers flag the missing attack surface and the submission stalls.

    SPDF documented but not integrated

    SPDF exists as a standalone document with no traceability into design controls, ECOs, or risk management. Reviewers ask for the integration evidence.

    Postmarket plan is aspirational

    Postmarket cybersecurity management plan describes what you intend to do, not what is operational. Reviewers want evidence the program exists today.

    No interoperability or compensating controls

    Device connects to clinical networks or shared infrastructure with no documented compensating controls for the connected environment.

    Risk file not updated for cybersecurity

    ISO 14971 risk file does not include cybersecurity-driven hazards or controls. Mandatory under AAMI TIR57 alignment and called out by reviewers.

    Blue Goat Cyber vs. the alternatives

    What you actually get versus a PMA consultant without cyber depth, or building Class III cyber evidence in-house.

    Capability Blue Goat Cyber PMA consultant without cyber depth In-house
    Class III / De Novo cyber experience Submissions across Class II + III + De Novo Cyber treated as add-on to regulatory work Built clause-by-clause from statute
    SPDF + threat model + SBOM + VEX Integrated, reviewer-format Piecemeal across subcontractors Multiple owners, integration gaps
    Postmarket commitments documented CVD + monitoring + patch SLAs Premarket only Deferred until audit
    Submission track record 250+, 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

    What happens after you book the call

    1. 1Day 0

      Mutual NDA + 30-min PMA / De Novo scoping

      Mutual NDA, then a 30-minute call to map your device classification, intended use, multi-patient exposure, and the cybersecurity evidence the reviewer will expect.

    2. 2Day 1

      Written strategy + fixed-fee quote

      Point-by-point cybersecurity strategy mapped to Section 524B and the FDA February 2026 final guidance, plus a fixed-fee quote covering threat model, pen test, SPDF, and postmarket plan.

    3. 3Weeks 2-12

      Reviewer-ready submission package

      Multi-patient threat model, full-scope pen test, SPDF integrated into your QMS, and postmarket cybersecurity management plan - delivered in eSTAR-attachable format.

    "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

    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.

    Ready to talk to a senior expert?

    30 minutes with a senior medical device cybersecurity engineer. Mutual NDA signed before the call. No pitch - we'll tell you straight if you don't need us.

    Replies in 1 business dayMutual NDA firstUS-based senior engineerNo sales pitch
    CallBook my free 30-min discovery call