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Friday In-Focus · 3 October 2025

Friday In-Focus State of the Art – From Claims to Strategy

A look at how 2025 FDA policy shifts, staffing cuts, the shutdown, and AI tools are affecting device submissions, inspections, and regulatory strategy.

Ty Benson, co-host; helps startups and small to mid-sized companies bring new technologies to marketMichelle Lott, co-presenter; senior regulatory/quality consultant8,086-word transcript

Summary

What the session covered

The session reviewed what the presenters see happening at FDA in 2025, starting with the administration’s regulatory freeze, the 10-to-1 deregulation order, and reductions in force. They described how those actions are affecting medical devices by looking first at food and drugs, then predicting similar deregulation pressure on CDRH. They explained that de novos are still being granted, but new regulation numbers can be placeholders, so companies may be unable to use recent de novos as predicates because special controls and decision summaries are not fully available. They also discussed the public comment process for removing regulations and guidance, the practical difficulty of submitting comments, and examples of FDA using outdated guidance alongside newer standards. The conversation covered staffing turmoil and the October 1 government shutdown, which stopped FDA from accepting new submissions or fees, including FY26 registration fees. They reviewed foreign inspection plans and the paused unannounced-inspection pilot, then turned to guidance updates, 510(k) and pre-submission review times, and FDA’s use of AI tools such as ELSA and PREDICT. They closed with Q&A, including uncertainty about Q-Submissions during the shutdown and the need to verify AI-generated feedback.

The slides

The slides

Slides coming soonThe deck for this session is not on file yet.

Take these with you

Six checks

Track FDA guidance directlyCheck the FDA guidance database yourself instead of relying only on FDA emails or press releases.
Validate de novo predicatesBefore using a de novo as a predicate, confirm the regulation and special controls are actually available, because current de novos may have placeholder regulation numbers.
Plan around fee timingMap submission and registration fee decisions to the fiscal year and shutdown risk, since FDA cannot accept new fees or submissions during the freeze.
Keep inspection readinessMaintain readiness for both domestic and foreign inspections, including unannounced foreign facility inspections once the pilot resumes.
Scrutinize AI-assisted feedbackWhen FDA feedback looks odd, check it against the applicable regulation, guidance, and standards rather than assuming the reviewer or AI got it right.
Engage in deregulation commentsUse the open public comment process to flag outdated guidance or regulations and explain what should be revised or removed.

Transcript

Full transcript

Edited for readability: filler words, false starts and Zoom housekeeping removed. Times run from the start of the recording.

00:13
Sean Smith

Hey! Hello.

01:01
Sean Smith

And we're trying to get back in, and it says the host has a lot of meetings. Okay, I'm gonna end… I'm gonna end this one.

How to cite this session

Benson T., Lott M. Friday In-Focus State of the Art – From Claims to Strategy. MedTech Leading Voice, Friday In-Focus, 3 October 2025.

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