Nicky Dickerhoff

As a neonatal nurse practitioner with nearly two decades of experience caring for some of our most vulnerable patients, I recognize that artificial intelligence has enormous potential to improve healthcare. But I also have serious concerns about who is developing these technologies, whose interests they serve, and who will ultimately bear the consequences when they fail.

There is absolutely a time and place for AI in medicine. It can help reduce administrative burdens, identify concerning clinical trends, improve diagnostic accuracy, and give healthcare professionals more time to do what we entered this profession to do: care for people.

But healthcare should not become another opportunity for large technology corporations to maximize profits at the expense of patients and healthcare workers.

The people driving the development, implementation, and oversight of these tools should be the physicians, nurses, advanced practice providers, and other frontline clinicians who understand the realities of patient care. We are the ones at the bedside. We understand the nuances of clinical decision-making, the limitations of standardized algorithms, and the devastating consequences that can follow when healthcare decisions prioritize efficiency over safety.

I urge the FDA to establish meaningful safeguards that require:

1. Frontline clinical leadership: Practicing healthcare professionals must have meaningful authority in the design, testing, validation, implementation, and ongoing evaluation of AI-enabled medical devices, rather than simply being consulted after products have already been developed.
2. Transparency and accountability: Developers must demonstrate clinical safety, disclose known limitations, and provide mechanisms for independent evaluation, adverse-event reporting, and ongoing monitoring.
3. Protection of clinical judgment: AI must support, not replace, the expertise and independent judgment of licensed healthcare professionals.
4. Protection against profit-driven misuse: AI should never become a justification for reducing staffing, increasing unsafe workloads, denying necessary care, or substituting automated recommendations for individualized clinical assessment.
5. Patient-centered outcomes: Success must be measured primarily through improvements in patient safety, clinical outcomes, equitable access, and quality of care—not corporate revenue, labor savings, or productivity metrics.

I am particularly concerned that healthcare organizations already facing enormous financial pressures will see AI as another means of doing more with less. We cannot allow technology to become an excuse to further stretch an already exhausted healthcare workforce or diminish the human relationships essential to safe, compassionate medicine.

Innovation is important. But innovation without accountability is not progress.

We need to stop treating healthcare as a business opportunity first and a human responsibility second.

The FDA has an opportunity to establish a framework that puts patients and the professionals who care for them at the center of medical AI development. Please ensure that these technologies are designed to serve the people who need them, not primarily the corporations that stand to profit from them.

Our patients deserve better than a healthcare system that continually asks how much money can be saved. We should be asking how many lives can be improved, how much suffering can be prevented, and how we can give clinicians the tools and resources to provide the safest possible care.

People before profits. Patients before productivity. Clinical judgment before corporate interests.