The majority of rehabilitation robotics are considered moderate-risk devices(R¨omer & Stuyt, 2007), which carry limited requirements to obtain FDA Approval or Conformite Europeenne (CE) Marking. In both the United States and Europe,devices that are considered to be “substantially similar” to alreadyapproved “predicate devices” are absolved from clinical testing requirements, or required to perform limited, less rigorous testing (Van Norman, 2016).