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The Incredible Shrinking Exemption: FDA Final CDS Guidance Would Significantly Narrow the Scope of Exempt Clinical Decision Support Software Under the Cures Act

FDA Law

The CDS Guidance interprets the “medical software” carve-out of the 21st Century Cures Act (2016) as it pertains to Clinical Decision Support (CDS) software functions. You can find our preliminary blog post on the release of this guidance here , and our blog posts on the draft CDS guidances here and here.

Clinic 52
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FDA Would Like to Join You in the Sandbox When Developing AI Enabled Devices

FDA Law

Both guidance documents recommend data management practices for collecting data for use in developing, tuning, and testing an artificial intelligence model and making changes to said model. FDA notes the use of data collected outside the U.S.