Predetermined Change Control Plan Adoption and Documentation Transparency in FDA-cleared Radiology Artificial Intelligence/Machine Learning Devices.
Authors
Affiliations (2)
Affiliations (2)
- Department of Radiology, SUNY Upstate Medical University, Street Address, Syracuse, NY.
- Department of Pathology, SUNY Upstate Medical University, Syracuse, NY.
Abstract
Purpose To characterize Predetermined Change Control Plan (PCCP) adoption and documentation transparency among U.S. Food and Drug Administration (FDA)-cleared radiology artificial intelligence/machine learning (AI/ML)-devices (2015-2025). Materials and Methods A cross-sectional systematic scoping review was conducted with linked data from FDA AI/ML-enabled device databases through April 2026. PCCP documentation completeness was scored by two independent observers (intraclass correlation coefficient: 0.93) using an 8-point rubric (possible scores, 0-8) derived from FDA's final PCCP guidance (December 2024). Identified PCCP devices underwent manual verification against FDA regulatory summaries. Results Among FDA-listed AI/ML-device submissions, 1080/1394 (77.5%) were radiology submissions, and nearly all cleared via 510(k) review. Across all FDA panels, 170 devices were cleared with a PCCP. Radiology led AI/ML-specific PCCP adoption (34/37 radiology PCCP devices, 91.9%). Among the PCCP-cleared radiology AI devices, 22/34 (65%) were cleared in 2025 alone following the final FDA guidance. Discrepancies between FDA's public database and individual summaries required manual adjudication for 9/34 (27%) of devices. PCCP documentation scores ranged from 0 to 8 (mean, 5), with most modifications focused on data retraining, compatibility expansion, and algorithm optimization. Continuous monitoring of device performance and predefined drift triggers for retraining were absent from public summaries. Conclusion PCCP adoption increased in radiology after issuance of the final FDA guidance, yet public lifecycle controls, particularly monitoring performance metrics and trigger thresholds, were limited. Standardized PCCP reporting of lifecycle controls are suggested as a condition of PCCP authorization to enable systematic postmarket monitoring as this pathway scales. ©RSNA, 2026.