Study finds low PCCP utilization among AI-enabled devices

Study finds low PCCP utilization among AI-enabled devices

Study finds low PCCP utilization among AI-enabled devices

https://www.raps.org/resource/study-finds-low-pccp-utilization-among-ai-enabled-devices.html

Publish Date: 2026-05-29 10:41:00

Source Domain: www.raps.org

  • Most manufacturers of AI-enabled medical devices are not using predetermined change control plans (PCCPs) to manage changes throughout the device’s lifecycle, according to a study published in JAMA Health Forum.
  • From 2023 to 2025, out of 794 AI-enabled medical devices reviewed, only 5.4% (43 devices) had FDA-authorized PCCPs.
  • The FDA issued final guidance on PCCPs for AI/ML software products in December 2024, focusing on proactive planning for product updates without new premarket applications.
  • Only 72% of the authorized PCCPs included all four key elements recommended by the FDA: modification list, modification protocols, notification plan, and impact assessment.
  • The low adoption of PCCPs suggests a “missed opportunity” to improve device performance, as these plans can help mitigate risk and allow for quick implementation of modifications.
  • Identified barriers to the use of PCCPs remain unidentified despite the process being generally accessible to manufacturers of varying experience levels.