Diagnostic & IVD Risk Assessment

Diagnostics, read past the clearance

Diligence across IVD 510(k), De Novo and PMA pathways, LDT and CLIA status: clinical validity and utility, reimbursement coding and lab workflow. An automated Quick Screen within 24 hours; full reports in 48, reviewed by a physician and a biomedical engineer.

24hQuick Screen
IVD/LDT/CLIAAll pathways
PLA/CPTCoding review
MD + BMEFull reports
A·A
Full reports are reviewed by Arvind Ravinutala, MD (practicing physician, P&T Committee Chair) and Aswini Ravinutala, BME (biomedical engineer, 10+ years in medical devices). The Quick Screen is automated. Specialist consultation is available when an engagement needs it.

The Problem

For diagnostics, coverage matters as much as clearance

FDA authorization is only half the path. CPT and PLA codes, LCD coverage and lab workflow fit drive revenue, and AI-enabled tests add validation questions of their own.

LDT status

A federal court vacated FDA's 2024 LDT rule in March 2025, and FDA rescinded it in September 2025. LDTs remain under CLIA, so diligence checks whether a test's claims, marketing and distribution fit that status.

Coding gap

Tests can clear FDA without a PLA or CPT code, or sit in Category III for years. Without a payable code, a revenue model built on list price needs a second look.

Clinical utility vs analytical validity

FDA's review centers on analytical and clinical validity. Payers, MolDx in particular, also ask for clinical utility: does the result change management? Sensitivity and specificity alone don't answer that.

MolDx / MAC coverage variance

Palmetto MolDx, Novitas, and other MACs have divergent LCDs. A test "covered by Medicare" may not be covered in the geographies your target actually sells.

Lab workflow fit

A test that wins a KOL's lab won't scale to a hospital automated chemistry line. Throughput, interfaces, sample type, and middleware connectivity gate real adoption.

AI/ML validation drift

Locked vs adaptive algorithms, validation cohort representativeness, postmarket performance monitoring. FDA's December 2024 final guidance on predetermined change control plans sets out what a planned-update pathway needs.

Regulatory Pathways We Cover

Every diagnostic pathway, assessed differently

IVDs, LDTs and CLIA-only workflows carry different evidence bars. A full report reads each against its own.

IVD 510(K)

Moderate-risk IVD

Substantial equivalence for IVDs. Analytical validity, clinical validity, predicate integrity, and risk-based controls matter most.

Class IItypicalPredicaterequired
PMA / De Novo

High-risk / Novel IVD

Companion diagnostics, some tumor markers, novel indications. Clinical study design, PMA panel risk and payer alignment shape the read.

Class IIIor novelClinicalevidence expected
LDT

Lab-Developed Test

Regulated under CLIA. FDA's 2024 rule to phase LDTs into device oversight was vacated in March 2025. Risk sits in validation documentation and in whether claims or distribution move a test outside LDT status.

CLIAoversightVacated2024 FDA rule
CLIA

Lab Certification

CLIA complexity categorization, proficiency testing, inspection readiness, personnel qualification. Required regardless of FDA pathway.

2yrcertification cycleCMSenforced

What a Diagnostic Report Examines

What a full report examines for a diagnostic

Full reports read the same 20-category framework on every company and summarize it in a composite Vantage Index. For a diagnostic, these are the areas that get the closest read. Some inputs, like financials, come from the company or the buyer.

DomainWhat we're looking at
Reimbursement & CodingPLA/CPT code status, MolDx LCD coverage, MAC variance, payer policy, gap-fill vs crosswalk, prior-auth burden
Clinical Validity & UtilityAnalytical validity (precision, accuracy, LoD), clinical validity (sensitivity/specificity), clinical utility (management impact, health-econ evidence)
Regulatory Pathway IntegrityPredicate choice, LDT status and claims, CDx companion strategy, pre-submission correspondence, labeling alignment with intended use
Lab Operations & WorkflowThroughput, automation fit, LIS/middleware integration, sample type and stability, CLIA complexity, interpretation time
AI/ML Validation & MonitoringTraining/validation cohort representativeness, locked vs adaptive, performance monitoring plan, drift detection, subgroup performance, predetermined change control
IP & Freedom-to-OperateAssay-method patents, algorithm protection, FTO on gene sequences (post-Myriad), trade secrets for reagent formulation
Commercial & Market AccessPhysician ordering patterns, hospital-reference-lab send-out decisions, direct-contract sales model, payer contracting strategy
Financial & OperationalCOGS, reimbursement-per-test, denial rate, days-sales-outstanding, capacity utilization — provided by the company or buyer

Pricing Ladder

Start with a Quick Screen, or go straight to a full report

Start with an automated Quick Screen, delivered within 24 hours of a complete intake. Move to a full report when the deal moves: 48-hour turnaround, reviewed by Arvind Ravinutala, MD, and Aswini Ravinutala, BME.

Quick Screen

24 hours
$5,000
Automated triage
  • Six independent signals
  • Each linked to its source records
  • No composite score or verdict
  • Fee credits toward a full report
Start Quick Screen

Founder Report

48 hours
$7,500
For founders
  • Eight domains, 28 sections
  • Comparable companies from public records
  • Physician and engineer review
  • 30-min debrief
See a sample evaluation

Diligence Report

48 hours
$20,000
Deal diligence
  • Eight domains with cohort comparables
  • Claims cited to their source records
  • Physician and engineer review
  • MD debrief; fee credits toward a License
Order Diligence Report

M&A Report

48 hours
$25,000
Corporate development & BD
  • Everything in the Diligence Report
  • Integration risk
  • Reference-contact review
  • 60-min strategy session
Order an M&A Report

Running diligence across a fund or portfolio? See Vantage Licenses →

Want continuous monitoring post-close? Surveillance from $1,500/mo →

Diagnostic Intelligence Library

What we've been writing about

Articles on diagnostic-specific risks in diligence. Written by Arvind and Aswini.

Put a diagnostic through Vantage this week

Buy a Quick Screen and give us the target and a data-room link (or just the intended-use statement) on the intake form. The Quick Screen arrives within 24 hours of a complete intake. Prefer to talk first? Book a free 20-minute call.