Device Regulators Guide on Change Control Plans for Device Software

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The International Medical Device Regulators Forum (IMDRF), of which FDA is a founding member, has published a final document outlining global principles for Predetermined Change Control Plans (PCCPs), a regulatory approach intended to streamline updates to medical device software while maintaining safety and regulatory oversight. The “Essential Principles and Content of Predetermined Change Control Plans” document was prepared by the group’s software as a medical device working group,

The framework describes how manufacturers can seek advance authorization for specific, planned software modifications that would otherwise require separate regulatory review before implementation. Under a PCCP, manufacturers would identify the planned changes, establish protocols and acceptance criteria for implementing those changes, and assess their potential impact on the device's safety and performance.

IMDRF said the approach is designed to help regulators keep pace with the rapid evolution of software-based medical devices by allowing certain pre-approved updates to be deployed more quickly. The group said PCCPs could improve patient access to software enhancements, reduce administrative burdens for manufacturers and regulators, and encourage earlier collaboration between industry and regulatory agencies.

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