The more innovative the technology, the more compelling the science, and the less the existing regulatory framework knows how to handle it.
Perhaps, there is no established endpoint to measure against. Maybe there is no performance goal to derive from decades of prior submissions. No clear pathway that anyone has walked before.
Standard approaches were designed for standard problems. When your device is new, old approaches can leave you exposed.
We've built regulatory pathways where none existed
BSC® specializes in the statistical and regulatory challenges that arise when innovation outpaces precedent. We've developed novel endpoints from scratch, constructed performance goals from literature and real-world data, designed studies for technologies FDA had never reviewed, and built analytical frameworks that became the template for submissions that followed.
This work requires the ability to anticipate what a reviewer will ask about a method they've never seen, to justify an approach with no direct precedent, and to build confidence in a pathway before anyone has walked it. It requires more than a biostatistician; it requires a problem solver.
Common scenarios we’ve navigated
Novel device with no predicate — We help define what evidence FDA needs, build the analytical framework to generate it, and construct the statistical justification that supports a first-of-kind submission
No established endpoint or performance goal — We develop defensible endpoints grounded in clinical literature, expert consensus, and historical data, and work with sponsors to gain FDA alignment before pivotal studies begin
Unprecedented regulatory pathway — We map the statistical strategy to the regulatory landscape, engage with FDA through Pre-Sub meetings, and build the evidentiary case for a pathway that doesn't yet have a roadmap
Real-world evidence integration — We design RWE strategies that meet FDA's evolving expectations, integrating observational data with clinical evidence in ways that are methodologically sound and regulatorily defensible
Propensity score matching and causal inference — When randomization isn't possible or ethical, we design and implement propensity-based analyses that rigorously control for confounding, support causal claims, and satisfy regulatory expectations for non-randomized comparisons
Adaptive trial designs — We design trials that can learn and adjust as data accumulates — modifying sample size, allocation ratios, or stopping rules at pre-specified interim points — while preserving Type I error control and maintaining regulatory defensibility throughout
What we do in these engagements
Novel endpoint development and validation
Performance goal development from literature and RWE
Regulatory pathway mapping and Pre-Sub strategy
Bayesian and adaptive design for unprecedented scenarios
Real-world evidence study design and integration
Scientific justification documentation
FDA engagement strategy and meeting support
Precedent research and cross-industry benchmarking
Innovation deserves a statistical partner who can keep up
The risk with a novel device isn't just regulatory uncertainty — it’s bringing the wrong statistical team to a problem they've never seen. Generic methods applied to unprecedented challenges produce generic outcomes. At best, delays. At worst, the rejection of science deserves approval.
BSC has built its reputation on exactly these situations. We don’t default to the textbook when the textbook doesn't apply. We build the framework your program needs — methodologically rigorous, regulatory defensible, and designed to give your innovation the best possible path forward.
Your device is cutting-edge. Your strategy should be too.

Starting a Trial
The decisions you make before enrolling the first subject define everything that follows.

Running a Study
Enrollment is just the beginning. Keeping it on track is where the real work starts.

Breaking New Ground
There's no predicate to reference.

Stuck or In Trouble
If you’re on this page, something has gone wrong, and you need help. Let's fix it.

Preparing to Submit
Your data is in. What happens next determines whether it's enough.
WHAT CLIENTS SAY
“They listen the first time. I’ve never had to go back and respell out what I needed."
”They work to understand the problem and leverage the information that is already there.”
Former FDA Regulator
WHAT CLIENTS SAY
"Battle ground tested."
"There is nothing that David and team haven’t seen over the years – the good, bad, and ugly.”
Vice President, Clinical Operations
WHAT CLIENTS SAY
"Get stuff done when you have to do something no one else has done before."
"They aren’t afraid to tackle difficult scenarios in compressed timelines."
CEO, Medical Device Company















