Governance planlow tiersynthetic scenario

Clinic no show prediction (scenario s04m2, governance level M2 partial)

Status

54%DONE
7 done3 in progress3 open

Risk profile

Clinical proximityAutonomyHarm severityThird party relianceChange over timeData sensitivity

Items by phase

Governance
2
Before deployment
4
After go live
5
Change
2

Items citing each framework

CHAI Responsible AI Guide
11
NIST AI RMF
10
EU AI Act
9
JC and CHAI RUAIH
9
ISO/IEC 42001
8
CHAI Assurance Standards
7
ONC HTI-1
5
WHO AI for health
4
CHAI Applied Model Card
3
FDA PCCP
1

Governance and accountability2 of 2 done

✓G01Name an accountable owner for the toolgovernance leadNIST AI RMFJC and CHAI RUAIHEU AI Act+3

Do Assign one named role as accountable for the tool across its life. Document who decides on risk and who runs day to day oversight.

Evidence Owner named in the AI inventory entry.

Sources

  • NIST AI RMF GOVERN 2.1 and 2.3 (N03)
  • NIST AI RMF GOVERN 3.2 (N04)
  • JC and CHAI RUAIH Element 1, leadership (J01)
  • JC and CHAI RUAIH Element 5, voluntary blinded reporting (J09)
  • EU AI Act Article 17, quality management system (E07)
  • WHO AI for health Principle 4, responsibility and accountability (W04)
  • ISO/IEC 42001 Clause 5, leadership and AI policy (I01)
  • ISO/IEC 42001 Annex A.3, internal organization (I02)
  • CHAI Responsible AI Guide Stage 4, assess (R18)
  • CHAI Responsible AI Guide Governance foundation (R21)
  • CHAI Responsible AI Guide Stakeholder roles (R22)
✓G02Review the tool in a multidisciplinary governance groupgovernance leadJC and CHAI RUAIHNIST AI RMFISO/IEC 42001+2

Do Present the tool to a group that spans clinical, safety, IT, privacy, compliance and executive roles. Record the decision and conditions.

Evidence Committee minutes or approval record.

Sources

  • JC and CHAI RUAIH Element 1, leadership (J01)
  • JC and CHAI RUAIH Element 1, policy and board (J02)
  • NIST AI RMF GOVERN 2.1 and 2.3 (N03)
  • ISO/IEC 42001 Clause 5, leadership and AI policy (I01)
  • CHAI Responsible AI Guide Stage 1, safety (R07)
  • CHAI Responsible AI Guide Stage 2, accountability (R14)
  • CHAI Responsible AI Guide Governance foundation (R21)
  • CHAI Assurance Standards Governance principle (A13)

Before deployment1 of 4 done

P01Document intended use and limitsclinical ownerNIST AI RMFJC and CHAI RUAIHEU AI Act+4

Do Write the intended use, intended users, target population and out of scope uses. State the performance the tool is meant to deliver in this setting.

Evidence Intended use statement or model card on file.

Sources

  • NIST AI RMF MEASURE 3.1 and 3.3 (N10)
  • NIST AI RMF MEASURE 4.2 and 4.3 (N11)
  • JC and CHAI RUAIH Element 6, risk and bias process (J10)
  • EU AI Act Article 13, transparency and information to deployers (E04)
  • ONC HTI-1 170.315(b)(11), source attributes (H01)
  • WHO AI for health Principle 3, transparency, explainability and intelligibility (W03)
  • CHAI Responsible AI Guide Stage 1, usefulness (R01)
  • CHAI Responsible AI Guide Stage 1, transparency (R05)
  • CHAI Responsible AI Guide Stage 2, transparency (R12)
  • CHAI Applied Model Card Uses and directions (M02)
P02Identify and document risks and biasesquality safety leadJC and CHAI RUAIHNIST AI RMFEU AI Act+4

Do List prospective risks and biases with emphasis on safety and access. Record the mitigations and the residual risk accepted.

Evidence Risk register entry.

Sources

  • JC and CHAI RUAIH Element 6, risk and bias process (J10)
  • NIST AI RMF MEASURE 3.1 and 3.3 (N10)
  • EU AI Act Article 9, risk management system (E01)
  • ONC HTI-1 170.315(b)(11), risk analysis (H02)
  • ISO/IEC 42001 Annex A.5, assessing impacts of AI systems (I03)
  • CHAI Responsible AI Guide Stage 1, fairness (R03)
  • CHAI Responsible AI Guide Stage 1, safety (R07)
  • CHAI Responsible AI Guide Stage 2, safety (R10)
  • CHAI Applied Model Card Warnings (M03)
✓P08Protect patient data and set patient transparencyprivacy officerJC and CHAI RUAIHONC HTI-1WHO AI for health+4

Do Protect patient data from unauthorized use or release. Where the tool directly affects care, notify patients and families, explain how their data are used, and obtain consent where relevant. Address transparency for staff.

Evidence Disclosure text, consent workflow and privacy review.

Sources

  • JC and CHAI RUAIH Element 2, patient privacy and transparency (J13)
  • ONC HTI-1 170.315(b)(11), governance (H04)
  • WHO AI for health Principle 1, protect human autonomy (W01)
  • WHO AI for health Principle 3, transparency, explainability and intelligibility (W03)
  • ISO/IEC 42001 Annex A.8, information for interested parties (I06)
  • CHAI Responsible AI Guide Stage 1, security and privacy (R06)
  • CHAI Responsible AI Guide Stage 2, security and privacy (R15)
  • CHAI Assurance Standards Stage 6, transparency (A10)
  • CHAI Applied Model Card Resources (M09)
P09Define who may use the tool and train themtraining leadSet by local policyJC and CHAI RUAIHEU AI ActISO/IEC 42001+2

Do Define which roles may use the tool. Decide whether training is needed before rollout and whether it must recur. Provide role specific documentation.

Evidence Access rules and training record.

Sources

  • JC and CHAI RUAIH Element 7, education and training (J12)
  • EU AI Act Article 26, obligations of deployers (E08)
  • ISO/IEC 42001 Annex A.8, information for interested parties (I06)
  • ISO/IEC 42001 Annex A.9, use of AI systems (I07)
  • CHAI Responsible AI Guide Stage 1, usefulness (R02)
  • CHAI Responsible AI Guide Stage 4, assess (R18)
  • CHAI Responsible AI Guide Governance foundation (R21)
  • CHAI Assurance Standards Governance principle (A13)

After go live2 of 5 done

✓O01Write the monitoring planquality safety leadSet by local policyNIST AI RMFJC and CHAI RUAIHEU AI Act+3

Do Name the metrics, the responsible parties, the review frequency and the escalation route. Cover functionality and behavior, comparison of outputs to known parameters, use case outcomes, confidence and data currency.

Evidence Monitoring plan with named metrics, owners and frequency.

Sources

  • NIST AI RMF GOVERN 1.5 (N01)
  • NIST AI RMF MEASURE 2.4 (N07)
  • NIST AI RMF MEASURE 2.6 (N08)
  • NIST AI RMF MANAGE 4.1 (N15)
  • JC and CHAI RUAIH Element 4, monitoring policy (J05)
  • EU AI Act Article 9, risk management system (E01)
  • EU AI Act Article 12, record keeping (E03)
  • EU AI Act Article 26, obligations of deployers (E08)
  • ONC HTI-1 170.315(b)(11), risk mitigation (H03)
  • ISO/IEC 42001 Annex A.6, AI system life cycle (I04)
  • CHAI Responsible AI Guide Stage 6, deploy and monitor (R20)
✓O02Scale monitoring frequency to riskquality safety leadSet by local policyJC and CHAI RUAIH

Do Monitor more often when the tool is close to a clinical decision. Administrative tools can be checked periodically.

Evidence Monitoring frequency recorded against the risk tier.

Sources

  • JC and CHAI RUAIH Element 4, risk based frequency (J06)
O05Open a channel for users to report problems and appeal outputsquality safety leadNIST AI RMFONC HTI-1CHAI Responsible AI Guide

Do Give end users and affected communities a way to report problems and appeal outcomes. Capture user input and overrides.

Evidence Reporting channel and appeal procedure.

Sources

  • NIST AI RMF MEASURE 3.1 and 3.3 (N10)
  • NIST AI RMF MANAGE 4.1 (N15)
  • ONC HTI-1 170.315(b)(11), feedback and export (H05)
  • CHAI Responsible AI Guide Stage 2, fairness (R13)
O06Report adverse events and errorsquality safety leadJC and CHAI RUAIHNIST AI RMFEU AI Act+3

Do Report adverse events and ongoing errors to leadership and to the vendor. Record events in the internal incident system. Send locally found issues to the vendor.

Evidence Incident process that names the tool.

Sources

  • JC and CHAI RUAIH Element 4, adverse event reporting (J08)
  • NIST AI RMF MANAGE 4.3 (N16)
  • NIST AI RMF GOVERN 4.3 (N05)
  • EU AI Act Article 26, obligations of deployers (E08)
  • EU AI Act Articles 72 and 73, post market monitoring and serious incident reporting (E09)
  • WHO AI for health Principle 4, responsibility and accountability (W04)
  • CHAI Responsible AI Guide Stage 2, safety (R10)
  • CHAI Responsible AI Guide Stage 2, safety (R11)
  • CHAI Assurance Standards Stage 6, security (A11)
O08Prepare incident response and recoveryquality safety leadNIST AI RMFEU AI ActCHAI Responsible AI Guide+1

Do Follow procedures to respond to and recover from a previously unknown risk. Communicate incidents and errors to relevant parties, including affected communities. Record the response.

Evidence Incident response procedure and test or tabletop record.

Sources

  • NIST AI RMF MANAGE 2.3 (N12)
  • NIST AI RMF MANAGE 4.3 (N16)
  • NIST AI RMF MANAGE 4.1 (N15)
  • EU AI Act Articles 72 and 73, post market monitoring and serious incident reporting (E09)
  • CHAI Responsible AI Guide Stage 2, safety (R10)
  • CHAI Assurance Standards Stage 5, security (A07)
  • CHAI Assurance Standards Stage 6, security (A11)

Change and retirement2 of 2 done

✓C02Control change management for retraining and updatesclinical ownerNIST AI RMFEU AI ActISO/IEC 42001+3

Do Put local retraining, retuning and continuous learning under change management. Revalidate before a changed model is used.

Evidence Change control procedure for the tool.

Sources

  • NIST AI RMF MANAGE 4.1 (N15)
  • NIST AI RMF MANAGE 3.1 and 3.2 (N14)
  • EU AI Act Article 15, accuracy, robustness and cybersecurity (E06)
  • ISO/IEC 42001 Annex A.6, AI system life cycle (I04)
  • FDA PCCP Description of modifications (F01)
  • FDA PCCP Modification protocol (F02)
  • FDA PCCP Impact assessment (F03)
  • CHAI Responsible AI Guide Stage 2, accountability (R14)
  • CHAI Assurance Standards Stage 5, security (A07)
  • CHAI Assurance Standards Stage 6, safety (A12)
✓C05Review the governance plan on a schedulegovernance leadSet by local policyNIST AI RMFEU AI ActISO/IEC 42001+1

Do Plan periodic review of this governance plan and define the roles for it.

Evidence Scheduled review in the AI inventory.

Sources

  • NIST AI RMF GOVERN 1.5 (N01)
  • EU AI Act Article 17, quality management system (E07)
  • ISO/IEC 42001 Clauses 9 and 10, performance evaluation and improvement (I09)
  • CHAI Assurance Standards Stage 5 and 6, safety (A08)

This plan maps your answers to requirements in published governance documents. Medon is a planning aid that supports your governance committee and counsel. Each mapping to a source document carries a review status.

References

  1. National Institute of Standards and Technology. Artificial Intelligence Risk Management Framework (AI RMF 1.0). NIST AI 100-1. 2023. https://doi.org/10.6028/NIST.AI.100-1
  2. The Joint Commission and Coalition for Health AI. Guidance on the Responsible Use of AI in Healthcare (RUAIH). 17 September 2025. https://digitalassets.jointcommission.org/api/public/content/dcfcf4f1a0cc45cdb526b3cb034c68c2
  3. European Parliament and Council of the European Union. Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act). Official Journal of the European Union, 12 July 2024. https://eur-lex.europa.eu/eli/reg/2024/1689/oj
  4. Office of the National Coordinator for Health Information Technology. Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1) Final Rule. 89 Fed. Reg. 1192 (4 January 2024). 45 CFR 170.315(b)(11).
  5. World Health Organization. Ethics and governance of artificial intelligence for health: WHO guidance. Geneva: WHO; 2021. https://iris.who.int/handle/10665/341996
  6. International Organization for Standardization and International Electrotechnical Commission. ISO/IEC 42001:2023 Information technology, Artificial intelligence, Management system. 2023. https://www.iso.org/standard/81230.html
  7. U.S. Food and Drug Administration. Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions. Guidance for Industry and FDA Staff. 2024. https://www.fda.gov/media/166704/download
  8. Coalition for Health AI. Responsible AI Guide. https://assets.ctfassets.net/7s4afyr9pmov/6e7PrdrsNTQ5FjZ4uyRjTW/c4070131c523d4e1db26105aa51f087d/CHAI_Responsible-AI-Guide.pdf
  9. Coalition for Health AI. Assurance Standards Guide (draft for public comment, June 2024). https://www.chai.org/blog/chai-releases-draft-responsible-health-ai-framework-for-public-comment
  10. Coalition for Health AI. Applied Model Card, documentation v0.1. https://mc.chai.org/v0.1/documentation.pdf ; template and schema at https://github.com/coalition-for-health-ai/mc-schema