AI/ML Predetermined Change Control Plan Guidance
Three Hyman, Phelps & McNamara staffers, a medical device regulation expert and two attorneys, say a recent FDA draft guidance on predetermined change control plans (PCCP) for artificial intelligence/machine learning (AI/ML)-enabled device software functions (ML-DSF) is intended to reduce the need for prior FDA authorization of modifications to the software functions. Writing in their firm’s FDA Law Blog, the three give the history of the development of PCCPs and an overview of the draft guidance.
“PCCPs provide a new mechanism for introducing certain significant changes to an ML-DSF,” the three write. “The use of a PCCP is not required; a manufacturer can continue to implement significant device changes via supplemental submissions to FDA. However, including a PCCP can speed up the process of making post-market software modifications and potentially reduce costs by avoiding additional marketing submissions.”
The online post concludes that FDA recommends that manufacturers discuss the PCCP strategy with it through the Q-Submission program before submitting a marketing submission with a PCCP.