“…Surprisingly most FMH testing remains performed with the manual microscopic method of Kleihauer Betke Braun with variable assay precision in the range of 25 ->100% (more of a qualitative assay in performance), clearly not acceptable for F cell HbF content assay, which requires the <5% CV precision afforded to rare event analysis by flow cytometry [2]. Furthermore given the IVD status of the Quick Quant (IQ Products, Groningen, NL), FETAL Cell Count (IQ Products, Groningen, NL) and Fetal HEMOGLOBIN kits (Thermo Fisher Scientific, USA); these future regulations will severely restrict the use of LDT assays that do not perform in some superior fashion compared to the commercial IVD solutions, which in FMH testing has never been reported [15,16,22]. What is the mostly likely course for an IVD company, two separate assays or a single improved assay?…”