I have heard FDA staff in multiple online conventions saying that the expectation for HF work is the same. So one way to frame the question is this: can you get the same level of data doing a remote study that you could for an in-person study? If not, you're unlikely to have much success with the FDA going down that route. There are somewhat safe evaluations depending on your exact situation (for example, the moderator behind the glass in a market research facility talking with a mic to the participant in the main room).
If the device is used for open surgical procedures, I would think most of the end users would be vaccinated by now as well, no?