The need for a system view to regulate artificial intelligence/machine learning-based software as medical device

Sara Gerke, Boris Babic, Theodoros Evgeniou, I. Glenn Cohen

    Research output: Contribution to journalArticlepeer-review

    26 Scopus citations

    Abstract

    Artificial intelligence (AI) and Machine learning (ML) systems in medicine are poised to significantly improve health care, for example, by offering earlier diagnoses of diseases or recommending optimally individualized treatment plans. However, the emergence of AI/ML in medicine also creates challenges, which regulators must pay attention to. Which medical AI/ML-based products should be reviewed by regulators? What evidence should be required to permit marketing for AI/ML-based software as a medical device (SaMD)? How can we ensure the safety and effectiveness of AI/ML-based SaMD that may change over time as they are applied to new data? The U.S. Food and Drug Administration (FDA), for example, has recently proposed a discussion paper to address some of these issues. But it misses an important point: we argue that regulators like the FDA need to widen their scope from evaluating medical AI/ML-based products to assessing systems. This shift in perspective—from a product view to a system view—is central to maximizing the safety and efficacy of AI/ML in health care, but it also poses significant challenges for agencies like the FDA who are used to regulating products, not systems. We offer several suggestions for regulators to make this challenging but important transition.

    Original languageEnglish (US)
    Article number53
    Journalnpj Digital Medicine
    Volume3
    Issue number1
    DOIs
    StatePublished - Dec 1 2020

    All Science Journal Classification (ASJC) codes

    • Medicine (miscellaneous)
    • Computer Science Applications
    • Health Informatics
    • Health Information Management

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