Implementing Predetermined Change Control Plans (PCCP) for Continuously Learning Medical AI

Core clinical engineering and protocols for FDA GMLP & Change Control Plans.

The Regulatory Challenge of Adaptive Medical AI

Historically, FDA medical device regulations assumed static software: any change to an algorithm required a new 510(k) premarket notification. However, modern AI algorithms improve continuously as they encounter diverse patient populations. The FDA's Predetermined Change Control Plan (PCCP) framework establishes a legal mechanism for adaptive SaMD.

Automating Safe In-Production Re-Training

AgenticSaMD implements automated pipeline verification for PCCPs: when updated hospital data triggers automated retraining, the candidate model is subjected to automated regression test suites evaluating sensitivity, specificity, and demographic fairness. Only models that strictly meet pre-approved performance criteria are promoted to clinical production.

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