Predetermined Change Control Plan
FDA mechanism to pre-authorize specific modifications to AI/ML-enabled devices.
Definition
A Predetermined Change Control Plan (PCCP) is a document, included in a marketing submission, that describes planned modifications to an AI/ML-enabled device, the methods used to develop, validate, and implement those modifications, and the impact on the device.What this means in practice
PCCPs let manufacturers update AI/ML models within an authorized envelope without a new submission, while preserving safety and effectiveness controls.Use cases
1 scenarioContinuous learning chest-X-ray triage SaMD
ML & RA teamThe sponsor includes a Predetermined Change Control Plan in the 510(k): allowed modifications (retraining cadence, new sites), the protocol (data governance, performance thresholds), and impact assessment.
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1 entryLatest in MedTech
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Primary references
3 sources- 1
FDA PCCP GuidanceVerifiedFDAfda.gov
- 2
FDA - AI/ML-Enabled Medical DevicesVerifiedFDAfda.gov
- 3
IMDRF - Software as a Medical DeviceVerifiedIMDRFimdrf.org
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