[cturitzin]

Yeah we've hired a consultant. The stuff that has been most frustrating is very domain specific.

For our product category (sleep apnea diagnosis) the FDA has an unwritten rule that all devices must run a clinical study compared to existing tools.

The hard part has been extracting the exact details that would make an acceptable study in their eyes (testing environments, statistical methods...)

Also it seems like the testing standards have evolved over time and this isn't documented either. Only way we've been able to learn the standards is by giving the FDA a proposal and getting feedback on it.

We've gotten a few FOIA'ed 510ks of similar devices. Unfortunately they are 90% redacted and not very helpful.

Looking back on it, it may have been worth it to seek out a person who had gone through this exact experience before. That could have saved some time/effort.