FDA Publishes Digital Health and Artificial Intelligence Glossary

October 11, 2024

Reading Time : 2 min

On September 26, 2024, FDA published a compilation of commonly used terms in the digital health, artificial intelligence (AI), and machine learning space and their definitions, available here.1   FDA intends the glossary to be used for general education purposes. The definitions are either directly from, or adapted from, various public sources, including consensus standard organizations and published literature, and FDA includes references to those sources in the glossary.

FDA publishes this glossary amid growing discussion of a need for a set of national standards applicable to AI.  The agency has already made notable progress in adapting its regulatory framework for AI’s novel attributes. As part of the glossary, the agency defines one of issues that continues to concern FDA: data drift. FDA defines “data drift” as “the change in the input data distribution a deployed model receives over time, which can cause the model’s performance to degrade. This occurs when the properties of the underlying data change. Data drift can affect the accuracy and reliability of predictive models.”  FDA explains that AI-enabled medical products can experience data drift due to statistical differences between the data used for model development and data used in clinical operation due to variations between medical practices or context of use between training and clinical use, and changes in patient demographics, disease trends and data collection methods over time. 

One way to avoid data drift is to conduct what FDA terms “AI performance monitoring.” FDA defines AI performance monitoring as the process of regularly collecting and analyzing data on the use of a deployed AI system to evaluate its performance in accomplishing its intended tasks in real-world settings.” Although this concept of AI performance monitoring is already incorporated into the total lifecycle management for AI-enabled medical devices, FDA has indicated that the agency needs expanded authority to adequately regulate the use of AI, in particular for AI-enabled medical devices.2

FDA plans routine updates to the glossary. FDA welcomes stakeholders to submit feedback by emailing digitalhealth@fda.hhs.gov.


1 FDA, Digital Health and Artificial Intelligence Glossary – Educational Resource (Sept. 26, 2024), https://www.fda.gov/science-research/artificial-intelligence-and-medical-products/fda-digital-health-and-artificial-intelligence-glossary-educational-resource.

2 Government Accountability Office (GAO), Federal Regulation: Selected Emerging Technologies Highlight the Need for Legislative Analysis and Enhanced Coordination, GAO-24-106122 (Jan. 25, 2024), https://www.gao.gov/products/gao-24-106122.

Share This Insight

Previous Entries

Eye on FDA

December 22, 2025

On December 18, 2025, the Food and Drug Administration (FDA) released a final guidance entitled “Processes and Practices Applicable to Bioresearch Monitoring Inspections.” The guidance was issued to comply with the Food and Drug Omnibus Reform Act of 2022, which directs FDA to issue guidance describing the processes and practices applicable to inspections of sites and facilities inspected under FDA’s Bioresearch Monitoring (BIMO) inspection program, to the extent that is not covered in already available FDA guides and manuals. The BIMO program was established to assess and monitor the conduct and reporting of FDA-regulated research as well as postmarketing activities through on-site inspections, investigations and Remote Regulatory Assessments.

...

Read More

Eye on FDA

December 15, 2025

On December 5, 2025, FDA announced its Technology-Enabled Meaningful Patient Outcomes (TEMPO) for Digital Health Devices Pilot, a new voluntary pilot that seeks to accelerate innovation and expand access to digital health devices for people living with chronic conditions. Under TEMPO, FDA will evaluate a new, risk-based enforcement approach that supports digital health devices intended for use to improve patient outcomes in cardio-kidney-metabolic, musculoskeletal and behavioral health conditions. Under the pilot, participating manufacturers may request that the agency exercise enforcement discretion for certain requirements, such as premarket authorization and investigational device requirements, while manufacturers collect and share real-world data demonstrating the device’s performance.

...

Read More

Eye on FDA

November 5, 2025

Last week, FDA released draft guidance titled “Scientific Considerations in Demonstrating Biosimilarity to a Reference Product: Updated Recommendations for Assessing the Need for Comparative Efficacy Studies.” This draft guidance reflects an evolution in FDA’s approach to determining whether a comparative clinical study with efficacy endpoints (a comparative efficacy study or CES) is necessary to support a demonstration of biosimilarity. Specifically, the agency notes that a comparative analytical assessment (CAA) is generally more sensitive when it comes to detecting differences between products than a CES.

...

Read More

Eye on FDA

October 27, 2025

On October 23, 2025, FDA released its final guidance regarding Patient-Focused Drug Development: Selecting, Developing, or Modifying Fit-for-Purpose Clinical Outcome Assessments. The guidance is the third guidance in a four-part series of FDA guidance focused on patient-focused drug development (PFDD) that describe how stakeholders, such as patients, caregivers, researchers, medical product developers and others can submit patient experience data and other relevant information that can be used for medical product development and regulatory decision making.

...

Read More

© 2025 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.