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Accepted for/Published in: JMIR Medical Informatics

Date Submitted: Oct 15, 2024
Date Accepted: Mar 27, 2025

The final, peer-reviewed published version of this preprint can be found here:

Regulatory Insights From 27 Years of Artificial Intelligence/Machine Learning–Enabled Medical Device Recalls in the United States: Implications for Future Governance

Chen WP, Teng WG, Benson C, Yen YJ, Lian JY, Sing M, Chen PT

Regulatory Insights From 27 Years of Artificial Intelligence/Machine Learning–Enabled Medical Device Recalls in the United States: Implications for Future Governance

JMIR Med Inform 2025;13:e67552

DOI: 10.2196/67552

PMID: 40644609

PMCID: 12274014

Navigating artificial intelligence/machine learning regulatory challenges from 1997 to 2024: insights into medical device recalls in the U.S.

  • Wei Pin Chen; 
  • Wei-Guang Teng; 
  • C.Kuo Benson; 
  • Yu-Jui Yen; 
  • Jian-Yu Lian; 
  • Matthew Sing; 
  • Peng-Ting Chen

ABSTRACT

Background:

Artificial Intelligence/Machine Learning (AI/ML) has revolutionized the healthcare industry, particularly in the development and use of medical devices. The FDA has authorized over 878 AI/ML-enabled medical devices, reflecting a growing trend in both quantity and application scope. Understanding the distinct challenges, they present in terms of FDA regulation violations is crucial for avoiding recalls effectively. This is particularly pertinent for proactive measures regarding medical devices.

Objective:

This study explores the impact of AI/ML on medical device recalls, focusing on the distinct causes associated with AI/ML-enabled devices compared to other device types. Recall information associated with 510k-cleared devices was obtained from OpenFDA. Three recall cohorts were established: "All 510K devices recall", "software-related devices recall", and "AI/ML devices recall".

Methods:

Recall information for 510k-cleared devices was obtained from OpenFDA. AI/ML-enabled medical devices were identified based on FDA listings. Three cohorts were established: "All 510K devices recall," "software-related devices recall," and "AI/ML devices recall." Root cause analysis was conducted for each recall event.

Results:

The results indicate that while the top five recall root causes are relatively similar across the three control groups, the proportions vary, with AI/ML devices showing a higher impact. Design and development-related factors contribute significantly to recalls in AI/ML devices, emphasizing the importance of thorough planning, user feedback incorporation, and validation during the development process to reduce the probability of recalls. In addition, changes in software, including design changes and control change, also contribute substantially to recalls in AI/ML devices.

Conclusions:

In conclusion, this study provides valuable insights into the unique challenges and considerations associated with AI/ML-enabled medical device recalls, offering guidance for manufacturers to enhance verification plans and mitigate risks in this rapidly evolving technological landscape.


 Citation

Please cite as:

Chen WP, Teng WG, Benson C, Yen YJ, Lian JY, Sing M, Chen PT

Regulatory Insights From 27 Years of Artificial Intelligence/Machine Learning–Enabled Medical Device Recalls in the United States: Implications for Future Governance

JMIR Med Inform 2025;13:e67552

DOI: 10.2196/67552

PMID: 40644609

PMCID: 12274014

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