Our Services BASED ON New LDT Rule Phaseout Policy
Phase 1 - Compliance Required by May 6, 2025
Audit and gap assessment of operations for QSR compliance
Assistance with QSR compliance (Reporting, Records compliance)
Portfolio Review for business considerations and prioritization of products for compliance
Risk Classification for Priority Products and assignment of FDA Product codes in preparation for Establishment Registration and Device Listing for Phase 2
Prepare, submit and lead Pre-submissions and meetings with FDA, where needed, to gain agreement on device classification, in preparation for Device Listing, IDE and /or PMA and 510(k) submissions.
Phase 2 - Compliance Required by May 6, 2026
Perform Establishment and Registration Listing
Assist with IVD Labeling Requirements and review and approval of labeling
Prepare and submit Investigational Device Exemption for LDTs to be used investigationally (prior to PMA approval or 510(k) clearance – i.e., to collect clinical data in support of future submission)
Phase 3 - Compliance Required by May 6, 2027
Assist with requirements for developing and provide support for implementing system of Design Controls, Purchasing and Supplier controls, Established Acceptance activities and CAPA.
Assist with Records requirements (Part 11, retention policies)
Phase 4 - Compliance Required by November 6, 2027
Prepare and manage Premarket submissions for High Risk LDTs and down classification evaluation.
Prepare, manage and lead Pre-submissions for FDA feedback on appropriate classification, where needed.
Phase 5 - Compliance Required by May 6, 2028
Prepare and manage Premarket submissions for Medium Risk LDTs
Prepare, manage and lead Pre-submissions for FDA feedback on submission requirements, where needed
Evaluate Low Risk IVDs for exemption from Premarket approval and document rationales.
Post-Compliance Audit Support
We can provide support through your post-compliance phase and perform audits, as needed