What goes in an FDA Predetermined Change Control Plan (PCCP)?

A PCCP describes, in advance, the modifications you intend to make to an AI/ML device function, how you will implement them (the modification protocol), and the impact assessment showing the device stays safe and effective within those bounds — letting you…

register 09 · Compliance pins· FDA PCCP
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Answer.

Healthcare regulation · FDA PCCP.

A PCCP describes, in advance, the modifications you intend to make to an AI/ML device function, how you will implement them (the modification protocol), and the impact assessment showing the device stays safe and effective within those bounds — letting you update the model without a new marketing submission for changes inside the plan. The key is pre-specified, bounded change with monitoring. Planisphere's drift evidence shows whether the model stayed inside its declared bounds; it does not author or clear the PCCP.

Cite-anchor: FDA — Marketing Submission Recommendations for a Predetermined Change Control Plan for AI-Enabled Device Software Functions · Final guidance issued 2024-12-03; Description of Modifications, Modification Protocol, Impact Assessment

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The mark behind the answer.

FDA PCCP can require evidence around clinical workflows, ePHI boundaries, change control, or patient-impacting decisions…

Predetermined Change Control Plan · drift-bounded model updates.

→ Full reference for FDA PCCP

Try FDA PCCP with a free test key.

Start with the free sandbox. Planisphere measures model behaviour and emits a reproducible, sha-pinned record — it does not certify, file, or give legal advice.

API ·

When FDA PCCP asks for proof, hand over records — not assurances.

record the duty · seal the receipt · verify offline

Planisphere records each duty event — an output marked, a disclosure shown, a review made — and seals it into a receipt that verifies offline against our published keys. You send hashes, never content. A record is evidence a third party can check; it is not a certification and not a legal determination.

See how a record is checked