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FDA-CMS TEMPO Pilot Program for AI Mental Health Devices

FDA-CMS TEMPO 试点计划
FDA, CMS·Published 2026-11-03·Checked by 管理员 on 2026-11-03

The FDA and CMS jointly launched the TEMPO pilot program, allowing AI-enabled mental health devices to commercialize based on a Quality Management System without immediate premarket authorization. Acting as a regulatory middle ground and de facto sandbox using real-world data, it could reshape US digital health regulation. A commentary was published in npj Digital Medicine on 3 November 2026.

What it means for you

  • AI mental health products can commercialize via a QMS without immediate premarket authorization, lowering market entry barriers
  • Companies must establish and maintain a compliant medical device Quality Management System as the entry requirement
  • Participation entails real-world data obligations that will inform future US digital health regulatory rules
  • What to do

    LegalAssess whether your AI mental health products qualify for the TEMPO pilot and plan an application path
    ComplianceEstablish or upgrade a Quality Management System meeting FDA requirements
    EngineeringDesign real-world data collection and reporting mechanisms to support the pilot

    Key dates

    2026-11-03Published

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