Classifying an AI/ML Device Before Any Pathway Is Chosen
Placeholder lead — risk class drives everything downstream.
- I / II / III: Device classes (placeholder caption)
- ~97%: Class II share of AI/ML clearances (placeholder caption)
- Risk to patient: Determinant (placeholder caption)
- FDA CDRH: Regulator (placeholder caption)
How risk class gets assigned
Placeholder body text — short stand-in for full explanation.
Does a Substantially Equivalent Predicate Device Exist?
Placeholder lead — predicate availability forks the pathway.
- 510(k) archive: Predicate database (placeholder caption)
- Same intended use: Equivalence test (placeholder caption)
- De Novo eligible: No predicate outcome (placeholder caption)
- PMA required: High risk override (placeholder caption)
Why the predicate question matters
Placeholder body text — short stand-in for full explanation.
Three Pathways, Three Very Different Review Postures
Placeholder lead — 510(k), De Novo, and PMA diverge sharply.
- Substantial equivalence: 510(k) basis (placeholder caption)
- Novel, moderate risk: De Novo basis (placeholder caption)
- Clinical trial evidence: PMA basis (placeholder caption)
- 510(k): Fastest pathway (placeholder caption)
What routes a device to each track
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Review Timelines and Evidence Burden by Pathway
Placeholder lead — each track runs its own clock and dossier.
- ~3–6 months: 510(k) review (placeholder caption)
- ~8–12 months: De Novo review (placeholder caption)
- ~18–30 months: PMA review (placeholder caption)
- Clinical trial data: PMA evidence (placeholder caption)
Evidence stacks grow with risk
Placeholder body text — short stand-in for full explanation.
Time-to-Market vs. Evidence Burden — the Core Tradeoff
Placeholder lead — faster pathways demand less proof, not more.
- Low: 510(k) burden (placeholder caption)
- Moderate: De Novo burden (placeholder caption)
- High: PMA burden (placeholder caption)
- New predicate created: De Novo precedent (placeholder caption)
Why pathway choice is strategic
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Placeholder highlight — De Novo clearance becomes a future predicate.