Challenges in the postmarket surveillance of clinical prediction models.
Open accessAbstract
Predictive artificial intelligence (AI) models enhance clinical workflows with applications such as prognostication and decision support, yet suffer from postdeployment performance challenges due to dataset shifts. Regulatory guidelines emphasize the need for continuous monitoring, but actionable strategies are lacking. A significant issue is postdeployment assessment of predictive AI models due to confounding medical interventions where effective interventions modify outcomes, introducing bias into performance assessment. This can falsely suggest model decay, leading to unwarranted updates or decommissioning, harming clinical outcomes. Proposed solutions include withholding model outputs, monitoring outcomes as surrogates, or including clinician interventions in models, each with ethical or practical limitations. The lack of effective solutions for this problem can lead to an abundance of models that cannot be later evaluated, tuned, or withdrawn if they become ineffective, leading to patient harm. Advanced causal modeling to assess counterfactual outcomes may offer a reliable validation method. Until effective methods for postdeployment monitoring of predictive models are developed and validated, decisions on model updates should consider the causal pathways and be evidence based, ensuring the sustained utility of AI models in dynamic clinical environments.
AI snapshot
Written from the paper’s full text.
TL;DR
Postmarket surveillance of clinical prediction models is confounded by confounding medical interventions: when effective interventions alter outcomes, observed model performance can falsely appear to decay. The paper reviews proposed surveillance solutions and argues that causal modeling of counterfactual outcomes is needed before apparent performance drives model updates or decommissioning.
Key findings
- Once deployed, a predictive model becomes part of a causal pathway linking predictions to clinical actions and outcomes; effective interventions prevent predicted adverse events, making postdeployment performance estimates unreliable and potentially leading to unwarranted updates or decommissioning.
- Proposed solutions—withholding model outputs for a random subset, monitoring outcomes as surrogates, or including clinician intervention as a model term—each have ethical or practical limitations; including intervention can worsen the discrepancy if exchangeability assumptions are not met.
- Feng et al.’s CUSUM procedures can detect changes in calibration or predictive values, but their effectiveness decreases as clinician trust in model predictions increases, and they do not provide quantitative performance estimates or address complex scenarios such as recurrent predictions or multiple interventions.
- Causal modeling to assess counterfactual outcomes may offer a reliable validation method, but until such methods are developed and validated, decisions about retraining, recalibrating, or updating models should consider causal pathways and be evidence based.
Methods
- Perspective/commentary, not an empirical study; no primary data collection, sample, or formal statistical analysis is reported.
- The paper synthesizes regulatory guidance, previously proposed postdeployment surveillance strategies, and simulation findings from a previously published model (ref 4) to illustrate bias in observed performance (Fig. 1).
- No dataset, population, or quantitative methods are described.
Limitations
- The paper states that proposed surveillance solutions have ethical or practical limitations, and that CUSUM approaches lose effectiveness as clinician trust increases and do not provide quantitative estimates or handle complex scenarios.
- The paper states that advanced causal modeling is promising but not yet developed or validated, and that future work should embed postdeployment monitoring into randomized trials.
- Evident from the text: as a commentary, it presents no new empirical validation or numerical estimates; its arguments rely on cited simulations and conceptual reasoning.
Model-written summary. Check it against the paper before relying on it.
Integrity signals
Registry
Cites
Statistics
Claims the paper makes
2 of 10 cited sources checked · 2 supported · 0 flagged
- Findingcitation
Based on simulations using a previously published model, the bias in observed model performance estimates increases as the model becomes more successful in improving clinical outcomes.
“Based on simulations using a previously published model,4 the resulting bias in observed model performance estimates increases as the model becomes more successful in improving clinical outcomes (Fig. 1).”
Quote in the paperSubstantial claim1 of 1 sources checked- cites [4] Cummings BC, Blackmer JM, Motyka JR, External validation and comparison of a general ward deterioration index between diversely different health systems. Crit Care Med 2023; 51: 775– 786. DOI: 10.1097/CCM.0000000000005837. 36927631 PMC10187626 source
- Premisecitation
Predictive AI models may not generalize across settings or over time due to dataset shift.
“It is well-known that such models may not generalize across settings or over time due to changes in patient populations, practice patterns, and data processes — a phenomenon known as dataset shift.1”
Quote in the paperSubstantial claim1 of 1 sources checked- cites [1] Finlayson SG, Subbaswamy A, Singh K, The clinician and dataset shift in artificial intelligence. N Engl J Med 2021; 385: 283– 286. DOI: 10.1056/NEJMc2104626. 34260843 PMC8665481 source
- Findingnone given
The severity of the CMI problem worsens as clinician trust in the model increases.
“This is consequential because the severity of the problem of CMIs also worsens as clinician trust in the model increases (Fig. 1).”
Quote in the paperNot a substantial claim - Interpretationreasoning
Including clinician intervention as a predictor can exacerbate the problem if the exchangeability assumption is not satisfied.
“Including intervention as a predictor can exacerbate the problem if the exchangeability assumption is not satisfied.”
Quote in the paperSubstantial claim- The authors state this as an assumption: The exchangeability assumption for including clinician intervention as a model term requires that subjects receiving and not receiving treatment are conditionally exchangeable given other model covariates, with faithful replication of the data-generating process and no unmeasured confounders.
- Rests on an assumption: Published prediction models are not typically developed in the same way as causal models for estimating unbiased treatment effects.
- Interpretationnone given
Proposed solutions for postdeployment surveillance (withholding outputs, monitoring outcomes as surrogates, including clinician interventions) each have ethical or practical limitations.
“Proposed solutions include withholding model outputs, monitoring outcomes as surrogates, or including clinician interventions in models, each with ethical or practical limitations.”
Quote in the paperNot a substantial claim
- Interpretationreasoning
The lack of effective solutions for postdeployment monitoring can lead to an abundance of models that cannot be later evaluated, tuned, or withdrawn if they become ineffective, leading to patient harm.
“The lack of effective solutions for this problem can lead to an abundance of models that cannot be later evaluated, tuned, or withdrawn if they become ineffective, leading to patient harm.”
Quote in the paperSubstantial claim - Interpretationreasoning
Strategies to address more complex scenarios, such as recurrent predictions or multiple interventions, remain unknown.
“Strategies to address more complex scenarios, such as recurrent predictions or multiple interventions, also remain unknown.”
Quote in the paperSubstantial claim - Interpretationreasoning
Effective interventions that prevent predicted adverse events alter the rates of the events being predicted.
“If the interventions are effective, adverse events will be prevented, and this, in turn, will alter the rates of the events being predicted.”
Quote in the paperSubstantial claim - Interpretationreasoning
If artifactual performance decays are interpreted naively, they may lead to updating or abandoning the model, harming clinical outcomes.
“This can falsely suggest model decay, leading to unwarranted updates or decommissioning, harming clinical outcomes.”
- Also stated in: § Introduction · hedged
“If interpreted naively, the artifactual performance decays may lead to actions such as updating the model or abandoning the model entirely, both at a detriment to clinical outcomes.”
Quote in the paperSubstantial claim - Also stated in: § Introduction · hedged
- Interpretationcitation
The CUSUM procedure for monitoring positive and negative predictive values does not apply in more general scenarios, including when a model's goal is to increase the use of treatments already in active use.
“However, it does not apply in more general scenarios, including when a model’s goal is to increase the use of treatments in active use (e.g., allocating existing clinical interventions to patients at high risk of some adverse outcome).”
Quote in the paperSubstantial claim0 of 1 sources checked- cites [7] Feng J, Subbaswamy A, Gossmann A, Designing monitoring strategies for deployed machine learning algorithms: navigating performativity through a causal lens. Proceedings of the Third Conference on Causal Learning and Reasoning. Los Angeles, CA: PMLR, 2024: 587– 608 (https://proceedings.mlr.press/v236/feng24a.html).
Not checked in the free run.
- Interpretationreasoning
Causal methods can isolate changes in clinical outcomes directly attributable to a model rather than to secular trends or contemporaneous practice changes.
“Such methods can also isolate changes to clinical outcomes that are directly attributable to a model (rather than to secular trends or contemporaneous practice changes); these effects remain the best gauge of a model’s impact.”
Quote in the paperSubstantial claim - Interpretationnone given
Observed improvements in patient outcomes after model deployment may be due to seasonal or epidemiologic changes or other shifts in clinical practice.
“Observed improvements in patient outcomes may also be due to seasonal or epidemiologic changes or other shifts in clinical practice.”
Quote in the paperNot a substantial claim - Interpretationreasoning
Confounding medical interventions introduce bias into postdeployment performance assessment, making model predictions appear incorrect.
“A significant issue is postdeployment assessment of predictive AI models due to confounding medical interventions where effective interventions modify outcomes, introducing bias into performance assessment.”
- Also stated in: § Introduction · plain
“These interventions, also called confounding medical interventions (CMIs), lead to model predictions appearing incorrect on subsequent evaluation.”
Quote in the paperSubstantial claim- Rests on an assumption: A common objective of deploying predictive models is to prompt interventions that reduce the risk of adverse outcomes predicted by the model.
- Also stated in: § Introduction · plain
- Interpretationreasoning
Validating models against counterfactual outcomes may enable consistent postdeployment validation despite effective interventions.
“Advanced causal modeling to assess counterfactual outcomes may offer a reliable validation method.”
- Also stated in: § Considerations for Effective Postdeployment Surveillance · hedged
“If a model’s degraded performance over time is driven by clinicians acting on model predictions to avert adverse outcomes, validating models against counterfactual outcomes — outcomes that would have occurred had a clinician not intervened — may enable consistent postdeployment validation despite effective interventions.”
Quote in the paperSubstantial claim - Also stated in: § Considerations for Effective Postdeployment Surveillance · hedged
- Interpretationnone given
Once a predictive model is implemented in a clinical workflow, it becomes part of a causal pathway linking its predictions to clinical actions and outcomes.
“The most pertinent among the issues is that once a model is implemented into a clinical workflow, it becomes part of a causal pathway linking the model’s predictions to clinical actions and resulting outcomes.”
Quote in the paperSubstantial claim - Premisecitation
Simulation results suggest that the effectiveness of the CUSUM procedure proposed by Feng et al. decreases as clinician trust in model predictions increases.
“However, simulation results suggest that the effectiveness of the CUSUM procedure decreases as clinician trust in the model predictions increases.”
Quote in the paperSubstantial claim0 of 1 sources checked- cites [6] Feng J, Gossmann A, Pennello GA, Petrick N, Sahiner B, Pirracchio R. Monitoring machine learning-based risk prediction algorithms in the presence of performativity. Proceedings of The 27th International Conference on Artificial Intelligence and Statistics. Valencia, Spain: PMLR, 2024: 919– 927 (https://proceedings.mlr.press/v238/feng24b.html).
Not checked in the free run.
- Classified as probably not a substantial claim. 9
- May combine two claims. 4
Probably not a substantial claim: may not pass S4 (based). May combine two claims.
Interpretationnone givenRegulatory guidelines emphasize the need for continuous monitoring, but actionable strategies are lacking.
“Regulatory guidelines emphasize the need for continuous monitoring, but actionable strategies are lacking.”
Quote in the paperNot a substantial claimMay combine two claims.
InterpretationcitationBoth CUSUM approaches provide a statistical test for change in model performance but do not provide quantitative estimates of model performance and magnitude of change.
“In addition, both approaches provide a statistical test to determine whether or not a change in model performance has occurred, but do not provide quantitative estimates of model performance and the magnitude of change.”
Quote in the paperSubstantial claim0 of 2 sources checked- cites [6] Feng J, Gossmann A, Pennello GA, Petrick N, Sahiner B, Pirracchio R. Monitoring machine learning-based risk prediction algorithms in the presence of performativity. Proceedings of The 27th International Conference on Artificial Intelligence and Statistics. Valencia, Spain: PMLR, 2024: 919– 927 (https://proceedings.mlr.press/v238/feng24b.html).
Not checked in the free run.
- cites [7] Feng J, Subbaswamy A, Gossmann A, Designing monitoring strategies for deployed machine learning algorithms: navigating performativity through a causal lens. Proceedings of the Third Conference on Causal Learning and Reasoning. Los Angeles, CA: PMLR, 2024: 587– 608 (https://proceedings.mlr.press/v236/feng24a.html).
Not checked in the free run.
Probably not a substantial claim: may not pass S2 (checkable).
InterpretationreasoningModern approaches leveraging causal inference may enable postdeployment monitoring that is less susceptible to these challenges.
“Modern approaches leveraging advances in causal inference may enable postdeployment monitoring that is less susceptible to these challenges.”
Quote in the paperNot a substantial claimProbably not a substantial claim: may not pass S3 (load-bearing).
Interpretationnone givenWithholding model outputs for a random subset of patients enables accurate ongoing estimation of model performance and effects.
“Although this solution enables accurate ongoing estimation of a model’s performance and effects, it raises ethical concerns”
Quote in the paperNot a substantial claimProbably not a substantial claim: may not pass S3 (load-bearing).
PremisecitationA prior White House executive order called for post-market oversight of AI-enabled health care technology algorithmic system performance against real-world data.
“and a prior White House executive order3 called for “post-market oversight of AI-enabled health care-technology algorithmic system performance against real-world data.””
Quote in the paperNot a substantial claim0 of 1 sources checked- cites [3] Biden JR. Executive order on the safe, secure, and trustworthy development and use of artificial intelligence. October 30, 2023 (https://www.federalregister.gov/documents/2023/11/01/2023-24283/safe-secure-and-trustworthy-development-and-use-of-artificial-intelligence). Rescinded on January 20, 2025.
Not checked in the free run.
Classified as probably not a substantial claim.
PremisecitationFeng et al. proposed a score-based CUSUM procedure within a causal framework to identify changes in model calibration after deployment.
“Feng et al. proposed a new score-based cumulative sum (CUSUM) procedure within a causal framework to identify a change in the model calibration after deployment.6”
Quote in the paperSubstantial claim0 of 1 sources checked- cites [6] Feng J, Gossmann A, Pennello GA, Petrick N, Sahiner B, Pirracchio R. Monitoring machine learning-based risk prediction algorithms in the presence of performativity. Proceedings of The 27th International Conference on Artificial Intelligence and Statistics. Valencia, Spain: PMLR, 2024: 919– 927 (https://proceedings.mlr.press/v238/feng24b.html).
Not checked in the free run.
May combine two claims.
InterpretationreasoningMonitoring clinical outcomes as a surrogate for model performance is limited because lack of observed improvements after deployment is not necessarily due to poor model performance; it may reflect low clinician trust/adoption or lack of effective interventions.
“While an accurate model paired with an effective intervention can improve clinical outcomes, a lack of observed improvements after model deployment is not necessarily due to poor model performance. It may instead reflect low levels of clinician trust or model adoption, or a lack of effective interventions for model-targeted conditions.”
Quote in the paperSubstantial claimProbably not a substantial claim: may not pass S3 (load-bearing).
PremisecitationFeng et al. proposed a CUSUM procedure to monitor changes in positive and negative predictive values.
“Feng et al. also proposed a CUSUM procedure to monitor changes in the positive and negative predictive values.7”
Quote in the paperNot a substantial claim0 of 1 sources checked- cites [7] Feng J, Subbaswamy A, Gossmann A, Designing monitoring strategies for deployed machine learning algorithms: navigating performativity through a causal lens. Proceedings of the Third Conference on Causal Learning and Reasoning. Los Angeles, CA: PMLR, 2024: 587– 608 (https://proceedings.mlr.press/v236/feng24a.html).
Not checked in the free run.
Probably not a substantial claim: may not pass S2 (checkable).
InterpretationreasoningA key to these approaches is to separately consider the effects of model recommendations on clinician decisions and the effects of those decisions on predicted outcomes.
“A key to these approaches is to separately consider the effects of model recommendations on clinician decisions and the effects of those decisions on predicted outcomes.”
Quote in the paperNot a substantial claimProbably not a substantial claim: may not pass S4 (based).
InterpretationreasoningThe presumption with these recommendations is that monitored models, if they decay in performance, should be updated to restore accuracy or decommissioned.
“The presumption with these recommendations is that monitored models, if they decay in performance, should be updated to restore accuracy or decommissioned.”
Quote in the paperNot a substantial claimClassified as probably not a substantial claim.
PremisecitationThe FDA's Good Machine Learning Practice recommends that deployed models are monitored for performance.
“The U.S. Food and Drug Administration (FDA)’s Good Machine Learning Practice for Medical Device Development2 recommends that “deployed models are monitored for performance,””
Quote in the paperSubstantial claim0 of 1 sources checked- cites [2] U.S. Food and Drug Administration. Good machine learning practice for medical device development. October 27, 2021 (https://www.fda.gov/medical-devices/software-medical-device-samd/good-machine-learning-practice-medical-device-development-guiding-principles).
Not checked in the free run.
May combine two claims.
InterpretationreasoningBecause clinicians typically administer interventions to patients predicted to be at high risk, the intervention variable often contributes positively to model-predicted risks, resulting in a larger discrepancy between model output and observed labels.
“This is because clinicians typically administer interventions to patients for whom a high risk of the adverse outcomes is predicted; hence, the intervention variable often contributes positively to model-predicted risks. This results in an even larger discrepancy between the model output and the observed labels that it will be evaluated against.”
Quote in the paperSubstantial claim- Rests on an assumption: Clinicians typically administer interventions to patients for whom a high risk of the adverse outcomes is predicted.
The authors state this as an assumption.
The exchangeability assumption for including clinician intervention as a model term requires that subjects receiving and not receiving treatment are conditionally exchangeable given other model covariates, with faithful replication of the data-generating process and no unmeasured confounders.
“This approach, which is akin to adjusting away the effects of clinician interventions, assumes that subjects receiving and not receiving treatment are conditionally exchangeable given other model covariates. For this assumption to be valid, the data-generating process must be faithfully replicated in the prediction model, and there must be no unmeasured confounders.”
The paper relies on this without support.
A common objective of deploying predictive models is to prompt interventions that reduce the risk of adverse outcomes predicted by the model.
“This is because a common objective of deploying predictive models is to prompt interventions that reduce the risk of adverse outcomes predicted by the model.”
The paper relies on this without support.
Clinicians typically administer interventions to patients for whom a high risk of the adverse outcomes is predicted.
“This is because clinicians typically administer interventions to patients for whom a high risk of the adverse outcomes is predicted; hence, the intervention variable often contributes positively to model-predicted risks.”
The paper relies on this without support.
Published prediction models are not typically developed in the same way as causal models for estimating unbiased treatment effects.
“This is rarely true for published prediction models, which are not typically developed in the same way as causal models for estimating unbiased treatment effects.”
Claims other papers make about this one
Each is checked against this paper’s own text: does it say what the citing paper says it does?
Postimplementation model drift due to changes in clinician behavior is a widely recognized challenge in the evaluation of clinical prediction models with no standard solution.
“Postimplementation model drift due to changes in clinician behavior is a widely recognized challenge in the evaluation of clinical prediction models with no standard solution.29”
From Multicenter Prospective Validation of an Updated Proprietary Sepsis Prediction Model (2026) · cites this paper as [29]
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Flagged first, then by citations
Research works printed but not linked: 1
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- Authors
- Ansari, S., Baur, B., Singh, K., & Admon, A. J.
- Affiliations
- University of Michigan (US)
- University of California San Diego (US)
- Venue
- NEJM AI
- Publisher
- Massachusetts Medical Society
- Published
- 2025-04-24
- Volume
- 2
- Issue
- 5
- ISSN
- 2836-9386 (ISSN-L)
- PMC
- PMC12380398
- OpenAlex
- W4409768187
- Semantic Scholar
- 5eb6831fd3ccae9b0b2f9e2df6ea59a17ba49ea9
- Cited by
- 22
- References
- 5
- Citations by year
- 2026: 17 · 2025: 5
- FWCI
- 5.26
- Type
- journal article
- Language
- en
- Open access
- green
- www.ncbi.nlm.nih.gov
- Locations
- NEJM AI (publishedVersion)
- PubMed (publishedVersion)
- Europe PMC (PubMed Central) (acceptedVersion)
- PubMed Central (acceptedVersion)
- Funders
- National Heart, Lung, and Blood Institute (K01HL155404, K08HL155407)
- Topics
- Health Sciences › Medicine › Health Informatics › Artificial Intelligence in Healthcare and Education
- Physical Sciences › Computer Science › Artificial Intelligence › Machine Learning in Healthcare
- Social Sciences › Safety Research › Ethics and Social Impacts of AI
- Keywords
- postmarket surveillance, clinical prediction model, predictive artificial intelligence, distribution shift, continuous monitoring, causal models, potential outcomes, clinical decision support, outcome prediction
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