Low PCCP Use Could be ‘Missed Opportunity’: Study
Researchers from several universities say that low use of predetermined change control plans (PCCPs) for AI-enabled medical devices could be a missed opportunity for improving device performance. The researchers report on a cross-sectional study describing PCCP use among AI-enabled medical devices and the comprehensiveness of public reporting documenting PCCPs that was published in JAMA Health Forum. The researchers say that PCCPs allow manufacturers to quickly implement device modifications while prespecifying plans for mitigating risk.
The study found that only 5% of AI-enabled medical devices had an FDA-authorized PCCP during the 2023-2025 study period. The researchers said they observed a modest increase in PCCP use starting in 2025. “Among devices with PCCPs,” the report says, “public reporting of PCCP elements was reasonably high: nearly three-quarters reported all FDA-recommended elements. Additionally, many manufacturers used multiple methods to communicate updates to users.”
The researchers found that the PCCP authorization process was generally accessible to manufacturers with differing levels of experience; experience with AI-enabled devices was not associated with PCCP use, nor did manufacturers undergo meaningfully different review times when submitting a PCCP.
“Nonetheless,” they conclude, “low overall adoption indicates that there remain unidentified barriers to PCCP use or that certain AI-enabled devices may simply be unamenable to prespecified design changes that preserve safety and effectiveness.”