PCCP: Opportunity for risk practitioners to shine

Risk practitioners in MedTech now have a unique opportunity to help accelerate development and post-market improvement of AI/ML enabled medical devices while also reducing the regulatory burden.

PCCP, or Pre-Determined Change Control Plan, is a novel regulatory approach that allows device manufacturers to include planned changes in their initial submission and avoid additional submissions in the post-market phase when these changes are implemented.

This is even more important for AI/ML enabled medical devices, which are expected to learn from new data in real-world applications to improve both user experience and performance without compromising patient safety.

As an example, Apple recently utilized a tailored PCCP approach in their regulatory submissions to receive advance clearance for their planned post-market changes. In case of the Hearing Aid Function, they focused on features to improve user experience. In the Sleep Apnea Notification function (SANF), on the other hand, they focused on improving the performance of the core AI model based on real-world data. In both cases, they proposed a rigorous verification and validation plan, and labeling updates.

Risk managers can play a key role in planning these modifications using a risk-based approach. They can help develop testing and implementation protocols. Finally, they can help articulate the overall benefits and risks to convince the FDA that these planned changes would improve safety and effectiveness.

Risk practitioners therefore have an opportunity to become more strategic and influential by playing a proactive role. They can collaborate with regulatory professionals, product developers and clinicians right from the start of product development.

Listen to the 22-minute audio summary above that covers the following topics:

* Key differences between FDA’s draft and final PCCP guidance

* Lessons learned from Apple’s tailored approach to PCCP

* Understanding benefits and risks of PCCPs

* Opportunities for risk practitioners

* Challenges in implementing PCCPs

Disclaimer

This article was prepared with the help of Google NotebookLM, an artificial intelligence research assistant, using the following sources:

* FDA Draft and Final Guidance: PCCP for AI/ML enabled devices.

* Apple De Novo: Hearing Aid Feature, Decision Summary.

* Apple 510k: Sleep Apnea Notification Feature (SANF).

* Caption Health De Novo: Automated Ejection Fraction Software.

* Notes created using Google NotebookLM in response to user prompts.

All output(s), including the audio summary, were reviewed by a human for accuracy and relevance. This article is intended for educational purposes only and should not be considered as regulatory advice.

If you liked this post, consider becoming a free or paid subscriber to Let’s Talk Risk!.

This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit naveenagarwalphd.substack.com/subscribe