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510(k) Data Aggregation

    K Number
    K243578
    Date Cleared
    2025-03-06

    (107 days)

    Product Code
    Regulation Number
    888.3044
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The BEAR® (Bridge-Enhanced ACL Restoration) Implant is a bovine extracellular matrix collagen-based implant for treatment of anterior cruciate ligament (ACL) injuries. The BEAR® Implant is indicated for adults, adolescents and children with a complete or partial rupture of the ACL, as confirmed by MRI. Patients must have an ACL stump attached to the tibia to construct the repair. Children with open physes must have sufficient bone in the femoral and tibial epiphyses on either side of the intended tunnel locations to avoid disruption of the growth plates.

    Device Description

    The BEAR® Implant (nominal 22 mm in diameter and 44 mm in length) is cylindrical in shape and comprised of collagen and extracellular matrix derived from bovine connective tissue, which has been cleaned, disinfected and processed by a proprietary manufacturing method. The implant has been terminally sterilized by electron-beam irradiation and is intended to be used with up to 10 ml of autologous blood drawn during the surgical implantation procedure. The BEAR® Implant stabilizes the blood in the gap between the torn ligament ends. The BEAR® Implant is resorbed within 8 weeks and replaced with a fibrovascular repair tissue.

    Children with open physes must have sufficient bone in the femoral and tibial epiphyses to accommodate a 2.4 mm cannulated drill pin with at least 2-3 mm of bone on either side of the intended tunnel locations to avoid disruption of the growth plates.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device called the BEAR® (Bridge-Enhanced ACL Restoration) Implant. The submission aims to expand the indications for use of the device, rather than introduce a new device or a new AI/ML-based device. Therefore, the traditional acceptance criteria and study designs typically associated with AI/ML device evaluations (e.g., performance metrics like sensitivity/specificity, sample sizes for test sets in diagnostic tasks, expert ground truth adjudication) are not applicable in this context.

    This 510(k) focuses on demonstrating that the expanded indications for the existing BEAR Implant (use in patients under 14 and with partial ACL tears) are as safe and effective as its original indications. The studies conducted are clinical trials comparing outcomes between different patient subgroups.

    Here's an analysis based on the information provided, tailored to the context of a medical implant and expanded indications for use:

    1. A table of acceptance criteria and the reported device performance:

    The document doesn't explicitly state quantitative acceptance criteria in terms of specific performance metrics (e.g., a certain percentage improvement). Instead, the acceptance criterion for the expanded indications is to demonstrate non-inferiority or similar safety and effectiveness of the BEAR Implant in the new patient populations (under 14 years old and with partial ACL tears) compared to the currently approved population (14+ years old with complete ACL tears), for which the predicate device (the same implant under its prior clearance) was deemed safe and effective.

    The provided document summarizes the findings as follows:

    Criteria/Comparison SegmentReported Device Performance
    Effectiveness - Age Group (<14 vs. ≥14 years)At 1 and 2 years post-op, subjects <14 years had on average higher IKDC scores than subjects ≥14 years. This demonstrates a non-inferior outcome between the two age groups. A similar outcome was seen in the Lachman knee laxity test.
    Safety - Age Group (<14 years vs. 14-18 vs. 19+ years)Subjects in the youngest age group (<14 years) experienced rates of AEs, serious adverse events (SAE), and device-related AEs and SAEs that were similar to the oldest subjects (19+ years) and lower than 14-18-year-olds.
    Effectiveness - Tear Type (Partial vs. Complete ACL tears)There were no differences in effectiveness outcomes (IKDC Subjective, IKDC Physical Exam, Lachman) between subjects with partial ACL tears at baseline and those with complete ACL tears.
    Safety - Tear Type (Partial vs. Complete ACL tears)There were no differences in safety between subjects with partial ACL tears at baseline and those with complete ACL tears.
    Overall ConclusionThe BEAR Implant is as safe and effective in patients under 14 years of age as those over 14 years and as safe and effective in patients with partial ACL tears as those with complete ACL tears. Only slight modifications to the BEAR procedure are required and do not present new or increased risks. These data support the substantial equivalence of the BEAR Implant for the expanded indications.

    2. Sample sizes used for the test set and the data provenance:

    The "test set" here refers to the clinical data used to evaluate the expanded indications against the predicate. This comes from two studies: the BEAR III Study and the BRIDGE Registry.

    • Sample Size by Age Group (Pooled BEAR III and BRIDGE studies):

      • Subjects ≥ 14 Years Old:
        • Baseline: 167
        • Surgery: 148
        • 1 Year: 136
        • 2 Years: 89
      • Subjects < 14 Years Old:
        • Baseline: 3 (BEAR III) + 14 (BRIDGE) = 17
        • Surgery: 3 (BEAR III) + 15 (BRIDGE) = 18
        • 1 Year: 3 (BEAR III) + 7 (BRIDGE) = 10
        • 2 Years: 2 (BEAR III) + 6 (BRIDGE) = 8
    • Sample Size by Tear Type (BEAR III dataset alone):

      • Subjects with Complete Tear:
        • Baseline: 124
        • Surgery: 124
        • 1 Year: 114
        • 2 Years: 79
      • Subjects with Partial Tear:
        • Baseline: 27
        • Surgery: 27
        • 1 Year: 25
        • 2 Years: 12
    • Data Provenance:

      • BEAR III Study: Prospective, multicenter, single-arm cohort study conducted at 7 U.S. investigational sites.
      • BRIDGE Registry: Ongoing real-world observational registry with prospective arms, conducted at up to 30 U.S. sites.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This concept is not directly applicable to this type of device and study. The "ground truth" for an ACL repair implant is the objective and subjective clinical outcomes of the patients (e.g., successful healing, knee stability, patient-reported function, absence of adverse events). These are measured through standardized clinical assessments (IKDC scores, Lachman test) and adverse event reporting, performed by the investigators and clinicians managing the patients in the studies. The study design does not involve independent experts adjudicating "truth" in the way an imaging AI algorithm might.

    4. Adjudication method for the test set:

    Not applicable in the typical AI/ML context. Clinical outcomes are assessed directly by the study investigators and clinicians, and adverse events are reported according to study protocols. There is no external adjudication process described for establishing "ground truth" as there would be for, say, an imaging diagnosis.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    Not applicable. This is not an AI/imaging device. The study is a clinical trial evaluating an implant, not a diagnostic or assistive AI tool.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    Not applicable. This is not an AI/ML device.

    7. The type of ground truth used:

    The "ground truth" (or basis for effectiveness and safety) for this device and study comes from:

    • Clinical Outcomes Data: Measured using established tools like the IKDC Subjective Knee Evaluation score, IKDC Objective Physical Exam score, and Lachman knee laxity test.
    • Safety Data: Adverse Events (AEs), Serious Adverse Events (SAEs), Unanticipated Adverse Device Effects (UADEs), and device-related AEs and SAEs, reported during the clinical studies.

    8. The sample size for the training set:

    Not applicable in the AI/ML context. This is a clinical implant. The phrase "training set" is not used in the context of clinical trials for device clearance; rather, it refers to the data used to develop and validate the implant's design and manufacturing process, and prior clinical trials for its initial approval (like the BEAR II study mentioned for the predicate device DEN200035).

    9. How the ground truth for the training set was established:

    Not applicable in the AI/ML context. The "ground truth" for the predicate device (DEN200035) was established through the BEAR II Study, which was a clinical trial evaluating the implant's safety and effectiveness in its initially approved patient population (skeletally-mature patients ≥14 years with complete ACL tears), using similar clinical outcome measures and adverse event reporting.

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