Towards a Post-Market Monitoring Framework for Machine Learning-based Medical Devices: A case study

After a machine learning (ML)-based system is deployed in clinical practice, performance monitoring is important to ensure the safety and effectiveness of the algorithm over time. The goal of this work is to highlight the complexity of designing a monitoring strategy and the need for a systematic framework that compares the multitude of monitoring options. One of the main decisions is choosing between using real-world (observational) versus interventional data. Although the former is the most convenient source of monitoring data, it exhibits well-known biases, such as confounding, selection, and missingness. In fact, when the ML algorithm interacts with its environment, the algorithm itself may be a primary source of bias. On the other hand, a carefully designed interventional study that randomizes individuals can explicitly eliminate such biases, but the ethics, feasibility, and cost of such an approach must be carefully considered. Beyond the decision of the data source, monitoring strategies vary in the performance criteria they track, the interpretability of the test statistics, the strength of their assumptions, and their speed at detecting performance decay. As a first step towards developing a framework that compares the various monitoring options, we consider a case study of an ML-based risk prediction algorithm for postoperative nausea and vomiting (PONV). Bringing together tools from causal inference and statistical process control, we walk through the basic steps of defining candidate monitoring criteria, describing potential sources of bias and the causal model, and specifying and comparing candidate monitoring procedures. We hypothesize that these steps can be applied more generally, as causal inference can address other sources of biases as well.

Is this model reliable for everyone? Testing for strong calibration

In a well-calibrated risk prediction model, the average predicted probability is close to the true event rate for any given subgroup. Such models are reliable across heterogeneous populations and satisfy strong notions of algorithmic fairness. However, the task of auditing a model for strong calibration is well-known to be difficult -- particularly for machine learning (ML) algorithms -- due to the sheer number of potential subgroups. As such, common practice is to only assess calibration with respect to a few predefined subgroups. Recent developments in goodness-of-fit testing offer potential solutions but are not designed for settings with weak signal or where the poorly calibrated subgroup is small, as they either overly subdivide the data or fail to divide the data at all. We introduce a new testing procedure based on the following insight: if we can reorder observations by their expected residuals, there should be a change in the association between the predicted and observed residuals along this sequence if a poorly calibrated subgroup exists. This lets us reframe the problem of calibration testing into one of changepoint detection, for which powerful methods already exist. We begin with introducing a sample-splitting procedure where a portion of the data is used to train a suite of candidate models for predicting the residual, and the remaining data are used to perform a score-based cumulative sum (CUSUM) test. To further improve power, we then extend this adaptive CUSUM test to incorporate cross-validation, while maintaining Type I error control under minimal assumptions. Compared to existing methods, the proposed procedure consistently achieved higher power in simulation studies and more than doubled the power when auditing a mortality risk prediction model.

Monitoring machine learning (ML)-based risk prediction algorithms in the presence of confounding medical interventions

Monitoring the performance of machine learning (ML)-based risk prediction models in healthcare is complicated by the issue of confounding medical interventions (CMI): when an algorithm predicts a patient to be at high risk for an adverse event, clinicians are more likely to administer prophylactic treatment and alter the very target that the algorithm aims to predict. Ignoring CMI by monitoring only the untreated patients--whose outcomes remain unaltered--can inflate false alarm rates, because the evolution of both the model and clinician-ML interactions can induce complex dependencies in the data that violate standard assumptions. A more sophisticated approach is to explicitly account for CMI by modeling treatment propensities, but its time-varying nature makes accurate estimation difficult. Given the many sources of complexity in the data, it is important to determine situations in which a simple procedure that ignores CMI provides valid inference. Here we describe the special case of monitoring model calibration, under either the assumption of conditional exchangeability or time-constant selection bias. We introduce a new score-based cumulative sum (CUSUM) chart for monitoring in a frequentist framework and review an alternative approach using Bayesian inference. Through simulations, we investigate the benefits of combining model updating with monitoring and study when over-trust in a prediction model does (or does not) delay detection. Finally, we simulate monitoring an ML-based postoperative nausea and vomiting risk calculator during the COVID-19 pandemic.

Sequential algorithmic modification with test data reuse

After initial release of a machine learning algorithm, the model can be fine-tuned by retraining on subsequently gathered data, adding newly discovered features, or more. Each modification introduces a risk of deteriorating performance and must be validated on a test dataset. It may not always be practical to assemble a new dataset for testing each modification, especially when most modifications are minor or are implemented in rapid succession. Recent works have shown how one can repeatedly test modifications on the same dataset and protect against overfitting by (i) discretizing test results along a grid and (ii) applying a Bonferroni correction to adjust for the total number of modifications considered by an adaptive developer. However, the standard Bonferroni correction is overly conservative when most modifications are beneficial and/or highly correlated. This work investigates more powerful approaches using alpha-recycling and sequentially-rejective graphical procedures (SRGPs). We introduce novel extensions that account for correlation between adaptively chosen algorithmic modifications. In empirical analyses, the SRGPs control the error rate of approving unacceptable modifications and approve a substantially higher number of beneficial modifications than previous approaches.