The purpose of this paper is to describe gaps found in programmatic verification activities for safety-critical systems based on field programmable gate array (FPGA) technology; specifically, by comparing the more mature methods used by other regulated industries that commonly use FPGAs and those mandated in the traditional software-based framework of the legacy commercial nuclear power generating industry. This paper also describes the strategies used by NuScale Power, LLC (NuScale) to fill the identified gaps, while maintaining its conformance to IEEE 1012-2004. In addition, the purpose of this paper is to inform and encourage consideration of why the 2004 version of IEEE 1012 is outdated for its application to the commercial nuclear power industry, especially as adoption of non-microprocessor based digital technology becomes widespread. Currently, the regulatory process for ensuring quality and safety for digital plant protection systems specifies independent verification and validation (IV&V) as outlined in IEEE 1012-2004 and endorsed by Regulatory Guide 1.168, Revision 2. Simply put, the reason to move away from the 2004 version and adoption of the 2016 version is due to the holistic systems-based life cycle that is inclusive of hardware, software, and their interfaces, which is now specified in the new version of IEEE 1012 (version 2016). The systems-based strategy is a key factor needed to ensure functional safety and quality throughout the verification and validation process. This is especially true for FPGA-based systems, as there is a tendency to think this technology should be treated only as hardware. This paper will identify critical differences between the versions of IEEE 1012 and explain why the NuScale IV&V program is looking outside of the commercial nuclear industry for methods better suited to FPGA-based I&C systems. In closing, this paper is intended to describe portions of the NuScale IV&V program that meets the requirements specified in IEEE 1012-2004, but also combines innovation with lessons learned from nonnuclear industries used to develop FPGA-based safety I&C systems.