Public comment periodCloses Oct 19, 2026
The FDA’s 26 GenAI questions.What the public is saying.
Public feedback on the regulation of generative AI-enabled medical devices.
123 responses so far to the FDA’s GenAI questions.
Over the first 55 days, industry contributed 75 of 123 submissions (61%), more than all other groups combined. Academia / other contributed the fewest, with 10. There are 7 days remaining before comments close on October 19.
Views on the FDA’s approach to GenAI.
One dot per filing. Select a column to read what they said.
FDA GenAI feedback over time.
The largest daily total was 14 submissions on August 18, the opening day. The next busiest days were September 4 and September 8, with 9 and 8 submissions respectively. With 7 days remaining, the total stands at 123.
The FDA GenAI questions getting the most attention.
Of the FDA’s 26 questions, these three appear most often across 123 public submissions so far. Counts show references, not agreement; each card also highlights leading recommendations or positions in the coded filings.
Does a two-axis framework, AI device activity and the consequence of relying on an incorrect output, capture the dimensions of risk?
45 of 123 filings name itWhen the foundation model’s developer changes the model, how does the device maker detect it and respond, so safety and effectiveness are not compromised?
44 of 123 filings name itTop themes shaping the FDA GenAI discussion.
A synthesis of the top emerging themes across public submissions. These themes connect several FDA questions and will evolve as new submissions are reviewed. Counts show submissions raising each theme, not agreement.
Public feedback on all 26 FDA GenAI questions.
Explore each question and the submissions that discuss it.
Does a two-axis framework, AI device activity and the consequence of relying on an incorrect output, capture the dimensions of risk?
45 of 123 filings name itHow should the continuum from non-directive to action-directing outputs, and the risk that changes along it, be accounted for?
32 of 123 filings name itWhen clinical information goes straight to the patient, does the risk change, and what safeguards help without underestimating patients?
31 of 123 filings name itShould it matter whether the clinician using the AI is a generalist or a specialist?
24 of 123 filings name itHow is risk assessed when a conversation starts with non-directive information and drifts into action-directing?
31 of 123 filings name itHow should under-escalation be weighed against over-escalation?
35 of 123 filings name itIs the two-step approach, benchmark the AI, then confirm it in clinical use, the right way to evaluate these devices?
33 of 123 filings name itShould an AI device’s position on the risk map help decide how much evidence it must bring before market?
21 of 123 filings name itDo the ten benchmark competencies, from clinical knowledge to generalizability, add up to enough evidence of safety and effectiveness?
40 of 123 filings name itHow can a benchmark score be shown to predict real-world behavior?
36 of 123 filings name itWhen can a device be confirmed without a prospective clinical study, and what earns that lighter path?
31 of 123 filings name itHow do you get statistically meaningful performance numbers when synthetic inputs are mixed with real ones?
28 of 123 filings name itWhere is synthetic data good enough, and where is it not?
28 of 123 filings name itFor open-ended AI outputs, who is the performance comparator: a clinician panel, generalists, specialists, or the human-AI team?
32 of 123 filings name itCould the AI be measured against what would have happened without it: unaided judgment, a delayed specialist, or no intervention?
29 of 123 filings name itWhat role should independent third parties play?
35 of 123 filings name itDoes the approach still work for devices built on other model architectures, such as multimodal vision-language models and world models?
19 of 123 filings name itCan greater premarket uncertainty about a GenAI device’s benefit-risk profile be accepted through greater reliance on postmarket monitoring?
41 of 123 filings name itHow should an AI device be monitored after launch, and what sets the cadence?
55 of 123 filings name itCould AI supervisory agents help carry out postmarket monitoring?
42 of 123 filings name itWhat roles should clinicians and institutions play in monitoring, without diluting manufacturer accountability?
38 of 123 filings name itWith the premarket competency assessment as the baseline, which post-deployment changes need re-evaluation, and how much?
40 of 123 filings name itHow can a change-control plan cover changes that cannot be fully specified in advance?
30 of 123 filings name itWhen the foundation model’s developer changes the model, how does the device maker detect it and respond, so safety and effectiveness are not compromised?
44 of 123 filings name itWho’s saying what?
All audiences shown for comparison.Provisional mapping: industry includes startups, large companies and consultants; practitioners includes clinicians and health systems. Academia is shown separately. Filings are not a representative population survey.
The conditions matter.
How much autonomy is accepted?
Highest accepted autonomy, compared across two consequence levels.
Two debates worth watching.
Two themes drawn from the FDA’s questions.The public submissions behind the FDA GenAI discussion.
Browse the filings, contributors and original source documents.
Explore the 26 FDA questions
Counts show coverage among the selected audience, not agreement.