Regulation of clinical Artificial Intelligence (AI) in the Age of Agents: Unconfined Non-Deterministic Clinical Software (UNDCS) systems for healthcare

Регулирование клинического искусственного интеллекта (ИИ) в эпоху агентных систем: неограниченное недетерминированное клиническое программное обеспечение (UNDCS) для здравоохранения
C. C. Terence Tan, Dinesh Visva Gunasekeran, Cheng Ooi Low, Gabrielle Sze Yee Sim, Danella Yaoxin Foo, Robert J. T. Morris, Tien Yin Wong
2026-02-23

clinical artificial intelligenceclinical decision support systemslarge language modelsmedical device regulationunconfined non-deterministic clinical software
In a recent article, Weissman et al. 1 examined the extent to which artificial intelligence (AI)-based large language models (LLMs) generate clinical decision support (CDS) outputs that meet the criteria of regulated medical devices 1 and called for new regulations for LLM-based CDS systems. In this manuscript, we respond to the proposed considerations highlighting those that have been addressed by existing guidelines and would not need new frameworks, as well as the need for new regulations of “generalized” CDSS that are not anchored to specific clinical indications. We contextualise this regulatory gap with an overview of the literature distinguishing between confined and unconfined AI systems. We also outline specific areas in which new regulations may be required, along with risk mitigation strategies that could be incorporated in new guidelines.
1
Existing guidelines already address some regulatory considerations for LLM-based clinical decision support and may not require entirely new frameworks.
2
New regulations may be needed for unconfined non-deterministic clinical software, alongside risk-mitigation strategies incorporated into future guidelines.
3
The emergence of generalized clinical decision support systems not anchored to specific clinical indications creates a regulatory gap.
4
The manuscript distinguishes confined from unconfined, non-deterministic clinical AI systems to contextualize regulatory challenges in healthcare.

Unconfined Non-Deterministic Clinical Software (UNDCS) systems for healthcare, including generalized AI-based clinical decision support systems

Regulatory requirements, gaps, and risk-mitigation strategies for generalized unconfined AI clinical decision support systems

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2026-02-23
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C. C. Terence Tan
Dinesh Visva Gunasekeran
Cheng Ooi Low
Gabrielle Sze Yee Sim
Danella Yaoxin Foo
Robert J. T. Morris
Tien Yin Wong
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