Internal review · feasibility

TruAssure for Medical Device V&V: Feasibility, Approach and Timeline

Yes, within a clear scope: the AI and agentic software functions in a medical device, or a device that is itself AI software (SaMD).

Shan Konduru · 10 November 2026 · for review and action
10 weeksto a usable pilot with a design partner
26 weeksto a regulated-ready release (2.0-MD)
~52engineer-weeks across three phases
3things to build: traceability, signed records, tool validation
Short answer

Yes, for AI and agentic device software

TruAssure can be extended to V&V the AI and agentic software functions inside a medical device, or a device that is itself AI software (SaMD). That means the clinical assistants, triage and documentation agents, and decision support built on LLMs. Its core design already matches what regulators ask for: evidence from independent sources rather than the agent's own account, repeatable runs, statistical reliability, and a release gate.

It is not a general-purpose replacement for traditional device V&V tooling (embedded firmware, hardware-in-the-loop, electrical safety, usability labs). For those, it would sit beside the existing tools and feed them evidence.

Three things have to be built before a manufacturer could use it in a regulated submission: requirement and hazard traceability, tamper-evident records with attributable sign-off, and a validation package for TruAssure itself as a QMS tool. We estimate about 6 months to a first regulated-ready release (2.0-MD), with a usable pilot on a non-regulated or pre-submission project at about 10 weeks.

Starting point

What carries over from TruAssure 1.6.2

Most of the testing engine a regulated AI V&V tool needs already exists, because TruAssure was built to judge agents from evidence, not from their own claims.

Capability todayWhy it matters for device V&V
Five-stage verdict per checkpoint (goal, plan, action, end state, output), first failing stage recordedMaps a test result to the software function that failed, which a 62304 anomaly record needs
Independent evidence kept apart: agent trace, action-boundary observer (MCP/REST proxy, OpenTelemetry), before/after state snapshots, outputsObjective evidence that does not depend on the system under test reporting truthfully
Evidence seams SE-01 to SE-07 (silent write, phantom success, output vs action, identity propagation)Catches the failure modes that matter most in clinical agents: claiming an order was placed when it was not, writing to a record without authority
Structured failure codes with severity rulesLets defects be classified and routed by code, ready to link to hazards
Reliability (pass^k) and Wilson confidence rangesGives a statistically stated performance claim instead of a single pass, needed for non-deterministic models
Robustness: input perturbations (casual, formal, indirect, noisy phrasings) and injected faultsEvidence for foreseeable misuse and degraded conditions
Parity and run comparison (SE-06)Shows a model, prompt or deployment change did not regress, the core of change control
Release gate with a written policy; JUnit for CIAn objective, recorded pass/fail decision at release
Execution report and JSON record built in code, never by a model; personal details maskedA reproducible test report; masking supports HIPAA/GDPR handling of test data
Grader calibration (Cohen's kappa, CE-02); "not evaluated" counts as failureAn LLM grader can be justified with measured agreement, and it never passes by default
Scenario packs: prompt injection, privacy, unsafe writes, escalation, abstention, jailbreakStarting content for security (FDA cybersecurity, IEC 81001-5-1) and safety-boundary tests
95% line-and-branch coverage gate, mypy strict, pinned CI actionsA disciplined development baseline that helps when TruAssure itself must be validated
The bar

What medical device V&V asks of a test framework

Regulators do not certify test tools. They judge the manufacturer's evidence, so TruAssure must produce evidence that fits these frameworks and must itself be validated for its intended use.

Standard or ruleWhat it asks of V&V evidence
IEC 62304 (software lifecycle)Software safety class A, B or C sets the rigour; traceability from requirements to verification; system-level testing; verified risk controls; anomaly records; regression after change
ISO 14971 (risk management)Every hazard's risk control is verified for implementation and effectiveness; residual risk is recorded
ISO 13485 and FDA QMSR (21 CFR 820, which brings ISO 13485 into US law from 2 February 2026)Design verification and validation records; validation of computer software used in the quality system, proportionate to its risk
FDA Computer Software Assurance guidanceRisk-based assurance of the tool itself: intended use, risk to patient and quality, then scripted or unscripted testing
21 CFR Part 11Electronic records that are attributable, with secure audit trails and signatures tied to a person and a meaning
FDA AI-enabled device software functions (draft, January 2025) and PCCP guidance (final, December 2024)Performance on representative data with subgroup analysis, uncertainty stated, monitoring, and a predetermined plan for model changes
EU MDR with the EU AI ActAI in a medical device is high-risk AI: data governance, logging, accuracy and robustness, human oversight; obligations for products under Annex I apply from August 2027
IEC 81001-5-1 and FDA premarket cybersecurity guidanceSecurity testing of health software, including prompt injection and data leakage for LLM features
IEC 62366-1 (usability)Mostly outside TruAssure; it can supply use-error scenarios but not formative or summative usability studies
These are stated from our working knowledge as of 10 November 2026, not re-read for this note. Regulatory Affairs should confirm current editions and status before we quote them to a client.
Gap analysis

Gaps to close

The testing engine is strong. The gaps are in traceability, record integrity and the tool's own validation. Today a scenario has an id, test types and a severity, but no requirement or hazard id. Runs are stored as plain files with no signatures. The only launch record is launched_by: "ta console", not a named person.

NeedTodayExtensionSize
Requirement and hazard traceabilityScenarios tagged by test type onlyrequirements: and hazards: fields in the catalog schema; import from a requirements or ALM tool (CSV, ReqIF, Jama, Polarion, Azure DevOps); a trace matrix in the report; a gate rule: every safety-class C requirement has a passing testM
Risk-based test selectionSeverity per failure codeSeverity linked to ISO 14971 hazard severity; test depth set by software safety class; residual-risk summary per hazardM
Tamper-evident records (Part 11)Plain files, manifest written lastHash chain over every evidence file, a signed run manifest, and an append-only audit log of every actionM
Attributable sign-offNo user identityNamed reviewer and approver with signature meaning (reviewed, approved), using the client's SSO; the gate verdict needs a signed approval for a releaseM
Statistical acceptance criteriapass^k, Wilson rangesPre-declared acceptance criteria per claim (for example sensitivity lower bound 95% CI ≥ 0.90); sample-size helper; subgroup results by demographic and siteM
Clinical reference dataCatalogs written by the teamGoverned test datasets: version, source, consent basis, train/test separation check, sequestration of the final test setM
Change control for models (PCCP)Compare and parity runsA change-impact report: model, prompt or retrieval change → affected requirements → mandatory re-runs → pass against the PCCP's limitsS
Clinical scenario packsGeneric packs (privacy, injection, escalation)Packs for clinical agents: dosing and units, contraindications, escalation to a clinician, abstention outside the intended use, hallucinated citations, PHI leakageM
Grader qualificationCohen's kappa on consistency verdictsCalibration of rubric verdicts too, against clinician-labelled sets; a documented rule for when a human must adjudicateS
Tool validation package95% coverage, strict typing, CIIntended-use statement, tool risk assessment (CSA), requirements spec, IQ/OQ scripts, a validation report, and a change procedure for every TruAssure releaseL
Submission-ready outputsEngineering and execution reportsReport templates matching the 62304 software verification report and the FDA AI-enabled device performance sectionS

S = 1 to 2 weeks, M = 3 to 5 weeks, L = 6 weeks or more, for one engineer.

Approach

Extend, not fork

The testing engine stays as it is, and a medical device layer is added on top, along with a vault for records and a sign-off step. All of it ships as a validated, long-term-support line (2.0-MD).

Medical device evidence flows from client inputs to signed reports Shaded: new for the medical line. Plain: in TruAssure today, or supplied by the client. Requirements (client ALM) Jama, Polarion, ReqIF or CSV Hazard analysis ISO 14971 risk controls Clinical test data versioned and sequestered TruAssure engine Today (1.6.2) Catalog, runner, five-stage verdicts Evidence seams SE-01 to SE-07 pass^k, robustness, parity, release gate New: medical device layer Trace links to requirements and hazards Safety-class depth, acceptance criteria Clinical packs, model change impact Evidence vault Hash-chained evidence, signed run manifest, append-only audit log Review and e-signature Named reviewer and approver through client SSO; the release gate needs an approval Trace matrix requirement to test to result 62304 verification report per software item and class AI performance report subgroups, CIs, PCCP limits Tool validation package (CSA), under everything above Intended use, tool risk assessment, IQ/OQ scripts, validation report

The client's requirements, hazards and data come in at the top. Every result is traced back to them, sealed in the vault and signed before it reaches a report.

Five principles shape the build:

  1. Trace everything. Every scenario names the requirement and hazard it verifies, and the gate refuses a release that leaves a safety-class C requirement untested.
  2. Deterministic first. Safety-relevant checks use state, action and content checks, which are already TruAssure's strength. An LLM grader is used only where its measured agreement with clinicians meets a pre-set threshold.
  3. A human signs. Agents and graders can propose verdicts, but a named person reviews and approves them. This also answers the EU AI Act's human-oversight expectation.
  4. Claims are statistical. Acceptance criteria are declared before the run, as confidence bounds, with subgroup results.
  5. Validate the tool once, per release. We ship the validation package. Each client runs a short IQ/OQ in its own environment and records its intended use.
Plan and timeline

Three phases, 26 weeks, a go/no-go at week 10

The plan has three phases over 26 weeks, about 52 engineer-weeks in total. A go/no-go at week 10 caps the commitment before the regulated work starts.

A regulated-ready 2.0-MD release in 26 weeks, pilot results at week 10 Assumes a start on 1 December 2026 with two engineers; every date moves with the start Dec Jan Feb Mar Apr May Jun Dec 1 to Feb 7 Feb 8 Feb 8 to Apr 4 Apr 5 Apr 5 to May 30 May 31 Phase 1 · Pilot foundation Gate 1 · pilot readout, go/no-go Phase 2 · Regulated records Gate 2 · QA Part 11 review Phase 3 · Validation and release 2.0-MD release
  1. Phase 1 · Pilot foundation (weeks 1 to 10, 20 engineer-weeks). Requirement and hazard fields in the catalog, CSV import, the trace matrix in the report, pre-declared acceptance criteria with subgroup results, and a first clinical scenario pack. Run it on the design partner's AI agent in a non-regulated setting. Exit: a trace matrix and performance report the partner's QA team accepts as useful.
  2. Phase 2 · Regulated records (weeks 11 to 18, 16 engineer-weeks). The evidence vault (hash chain, signed manifest, audit log), SSO identity and e-signatures on review and gate approval, risk-based test depth by safety class, grader qualification against clinician labels, and the model change-impact report. Exit: QA's Part 11 gap assessment shows no open critical findings.
  3. Phase 3 · Validation and release (weeks 19 to 26, 16 engineer-weeks). The tool validation package (CSA), IQ/OQ scripts, report templates for 62304 verification and AI performance, Jama and Polarion connectors, and the 2.0-MD long-term-support release. Exit: a signed validation report for 2.0-MD.

People: 2 engineers throughout; an RA/QA lead at about half time; a clinical SME at about a quarter time. Code is not the slow part here. Regulated documentation and the partner's review cycles are, so phases 2 and 3 carry the most schedule risk.

Risks

Risks, assumptions and what we should not claim

Do not claim that TruAssure is "FDA approved", "62304 certified" or "compliant". Tools are not cleared. The accurate line is: TruAssure produces V&V evidence designed to support a manufacturer's 62304, 14971 and Part 11 obligations, and comes with a validation package the manufacturer completes for its own intended use.
RiskEffectMitigation
An LLM grader judges a safety-relevant output wronglyFalse pass on a clinical claimSafety-class C checks use deterministic checks or clinician adjudication; LLM grading only where its measured agreement meets a pre-set threshold
No domain expertise in the teamScenario packs miss real clinical hazardsBring in a clinical SME and an RA/QA lead from week 1; validate packs with a design partner
Clinical data access and PHIPilot stalls on data agreementsStart on synthetic or public de-identified data; run TruAssure inside the client's boundary (it already runs fully offline)
Scope creep into firmware, hardware and usability testingTimeline doublesState the scope as AI and software functions; integrate with, not replace, existing tools
Regulations moving (FDA AI draft guidance, EU AI Act dates)Rework of report templatesKeep templates as data; review with RA at each phase gate
Validation drag on every TruAssure releaseSlower release cadence for the medical lineA separate long-term-support line (2.0-MD) with a defined change procedure; the main line keeps moving

Assumptions: two engineers plus part-time QA/RA and a clinical SME; one design partner with a real AI-enabled device project; Innominds owns the medical line (see the ownership move to the corporate repository).

For action

Decisions needed from the review team

Please send comments and decisions to Shan Konduru. The editable source of this page is docs/medical-device/TruAssure-Medical-Device-VV-Assessment.docx in the TruAssure repository.
Sources

Sources

TruAssure capabilities are taken from the 1.6.2 codebase (README, catalog schema, core/ modules) as of 10 November 2026. Regulatory references are from working knowledge and need RA confirmation: IEC 62304:2006+A1:2015, ISO 14971:2019, ISO 13485:2016, FDA QMSR (21 CFR 820), 21 CFR Part 11, FDA Computer Software Assurance guidance, FDA AI-enabled device software functions draft guidance, FDA PCCP guidance, EU MDR 2017/745, EU AI Act 2024/1689, IEC 81001-5-1, IEC 62366-1.