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How to Survive FDA’s Predetermined Change Control Plan

To thrive, medical device companies must adopt CI/CD practices, design flexible systems, and integrate risk management throughout their product lifecycle.
Erez Kaminski
MD+DI
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September 10, 2024
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This article originally appeared in MD+DI on September 10, 2024.

It’s rare to hear the private sector applauding a regulatory agency, but the FDA’s Predetermined Change Control Plan (PCCP) deserves recognition. This initiative could be one of the most transformative in the agency’s history, driving innovation in medical devices while enhancing patient safety through continuous improvement.

However, a shakeout is on the horizon that will expose those companies with IT environments that were originally built on 1990s infrastructure. These IT systems never envisioned the cloud or AI, today’s volume of users, or the demands of modern applications. Over the coming years, it will become clear which manufacturers have successfully transformed their aging infrastructures with the right FDA compliance software to fully leverage the benefits of the PCCP. The difference will be immediately obvious when you compare the number of annual releases or versions on the app store. Companies that adapt will release updates frequently and incorporate AI/ML. However, most companies will struggle to make this transition, and, as a result, won’t be able to harness the PCCP. These companies will find themselves left behind by more agile manufacturers.

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