S2 · Planning validation

Evidence plan

Your study plan set against what cleared devices in your code actually reported — element by element, with the pages.

The stage

Development: you are planning the validation study or a Pre-Submission.

The question this week

“What will our validation have to show, and what should we ask the FDA before we run it?”

Who it is for

  • Regulatory and clinical leads planning a validation study
  • Teams preparing a Pre-Submission (Q-Sub) meeting
  • Statisticians who want the precedent before they size the study

The problem

  • Studies are designed without seeing what peers in the same code reported, so elements the FDA usually sees are missed.
  • Pre-Submission questions come out vague, and the one meeting is spent on things the record already answers.
  • Reading the precedent by hand takes weeks of someone senior's time.

You send

  • Your intended use
  • Your draft validation plan or protocol outline
  • The product code, if known (S1 settles it if not)

Under a signed confidentiality agreement, held on the consultant’s machine only and deleted by a date you agree.

You receive

  • Thirteen evidence elements — sample size, cohort demographics, design, sensitivity, specificity, AUC, reference standard, comparator, sites, prospective collection, outcomes
  • For each: how often cleared summaries in your code state it, and up to three passages where they did, with the K-number and page
  • Your plan beside the precedent, in your words
  • Candidate Pre-Submission questions drawn from where your plan and the precedent diverge

Format: PDF and Word, every statement footnoted. Typical turnaround: one to two weeks from receiving the plan.

What it is not

  • A protocol — your clinical and statistical leads own the study design
  • A judgment that any evidence is sufficient

The FDA decides. Every deliverable says so on its cover.

What usually comes next

S3, once the study reports exist.

S3 · Validation gap review →

Talk through S2 for your device

The first S1 brief for your device is free. A twenty-minute call is enough to start: what the device does, where you are, and the date you are working to.