The Landscape Is Shifting
Healthcare AI operates in one of the most complex regulatory environments in existence. Understanding what's permitted, what's changing, and what remains prohibited is essential before deploying any AI system.
"The FDA has cleared over 1,000 AI/ML-enabled medical devices. Zero of them use large language models for clinical decision-making. That's not a coincidence."
— FDA Digital Health Center of Excellence, 2025 ReportWhat's Coming
FDA Deregulation Takes Effect
Clinical decision support tools that meet certain criteria will no longer require FDA clearance. Documentation AI and workflow tools gain clearer pathways.
EU AI Act Full Enforcement
Medical AI classified as high-risk. Requires risk management, technical documentation, human oversight, and audit trails.
State AI Laws Proliferate
California, Colorado, and others implementing AI-specific healthcare regulations. Patchwork compliance becomes mandatory.
Current Constraints
FDA SaMD Pathway
Software as a Medical Device requires 510(k) or De Novo clearance for diagnostic AI. LLMs face unique challenges: non-deterministic outputs, hallucination risk, and training data opacity.
HIPAA Compliance
Patient data used for AI must meet strict privacy requirements. Cloud LLM APIs may create BAA complications. On-premise deployment often required.
21 CFR Part 11
Electronic records and signatures in clinical settings require audit trails, access controls, and validation. AI-generated documentation must meet these standards.
State Practice Acts
Medical practice laws vary by state. AI cannot practice medicine. Human oversight requirements differ by jurisdiction and care type.
Critical Constraint
No LLM-based system has been FDA-cleared for clinical decision-making. AI can assist documentation and workflows, but clinical judgments require human oversight.
Built for healthcare compliance from day one
Guardian monitors AI outputs for hallucination and drift. AgentOps provides 21 CFR Part 11 compliant audit trails. Steer enforces clinical safety guardrails at runtime. Together they address every regulatory requirement on this page.