Skip to content

Menu

LexBlog, Inc. logo
CommunitySub-MenuPublishersChannelsProductsSub-MenuBlog ProBlog PlusBlog PremierMicrositeSyndication PortalsAboutContactResourcesSubscribeSupport
Join
Search
Close

FDA Publishes Principles for AI and ML in Medical Devices

By Jodi G. Daniel on October 29, 2021
Email this postTweet this postLike this postShare this post on LinkedIn

On October 27, 2021, the U.S. Food and Drug Administration (FDA) in collaboration with Health Canada, and the UK’s Medicines and Healthcare products Regulatory Agency (MHRA), published Guiding Principles for the use of artificial intelligence and machine learning (AI/ML) in medical devices.   The principles are designed to support good machine learning practices (GMLP) and to help promote safe, effective, and high-quality medical devices that use AI/ML. The FDA is accepting public comment on these principles on an ongoing basis.

FDA notes that AI/ML technologies have the potential to transform health care by deriving new and important insights from the vast amount of data generated during the delivery of health care every day. They use software algorithms to learn from real-world use and in some situations, may use this information to improve the product’s performance. However, they also present unique considerations due to their complexity and the iterative and data-driven nature of their development.

There are 10 guiding principles:

  1. Multi-Disciplinary Expertise Is Leveraged Throughout the Total Product Life Cycle
  2. Good Software Engineering and Security Practices Are Implemented
  3. Clinical Study Participants and Data Sets Are Representative of the Intended Patient Population
  4. Training Data Sets Are Independent of Test Sets
  5. Selected Reference Datasets Are Based Upon Best Available Methods
  6. Model Design Is Tailored to the Available Data and Reflects the Intended Use of the Device
  7. Focus Is Placed on the Performance of the Human-AI Team
  8. Testing Demonstrates Device Performance During Clinically Relevant Conditions
  9. Users Are Provided Clear, Essential Information
  10. Deployed Models Are Monitored for Performance and Re-training Risks Are Managed

FDA notes that these guiding principles address the unique nature of medical device products that incorporate AI/ML and are intended to lay the foundation for GMLP to cultivate future growth in medical devices using AI/ML.  The agency also notes that there are areas where the International Medical Device Regulators Forum (IMDRF), international standards organizations, and other collaborative bodies could work to advance GMLP.

While these are not regulatory requirements, we encourage medical device manufacturers that incorporate AI/ML in their devices to consider these principles in the development and deployment of such technology.

Photo of Jodi G. Daniel Jodi G. Daniel

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She…

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She leads the firm’s Digital Health Practice and provides strategic, legal, and policy advice to all types of health care and technology clients navigating the dynamic regulatory environment related to technology in the health care sector to help them achieve their business goals. Jodi is a contributor to the Uniform Law Commission Telehealth Committee, which drafts and proposes uniform state laws related to telehealth services, including the definition of telehealth, formation of the doctor-patient relationship via telehealth, creation of a registry for out-of-state physicians, insurance coverage and payment parity, and administrative barriers to entity formation.

Read more about Jodi G. DanielEmail
Show more Show less
  • Posted in:
    Health Care
  • Blog:
    Health Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

LexBlog, Inc. logo
Facebook LinkedIn Twitter RSS
Real Lawyers
99 Park Row
  • About LexBlog
  • Careers
  • Press
  • Contact LexBlog
  • Privacy Policy
  • Editorial Policy
  • Disclaimer
  • Terms of Service
  • RSS Terms of Service
  • Products
  • Blog Pro
  • Blog Plus
  • Blog Premier
  • Microsite
  • Syndication Portals
  • LexBlog Community
  • 1-800-913-0988
  • Submit a Request
  • Support Center
  • System Status
  • Resource Center

New to the Network

  • Boston ERISA & Insurance Litigation Blog
  • Stridon News and Insights
  • Taft Class Action & Consumer Insights
  • Labor and Employment Law Insights
  • Age of Disruption
Copyright © 2022, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo