K Number
DEN160006
Manufacturer
Date Cleared
2018-06-22

(870 days)

Product Code
Regulation Number
870.1252
Type
Direct
Reference & Predicate Devices
N/A
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The everlinQ® endoAVF System is indicated for the creation of an arteriovenous fistula (AVF) using the ulnar artery and ulnar vein in patients with minimum artery and yein diameters of 2.0 mm and less than 2.0 mm separation between the artery and vein at the fistula creation site who have chronic kidney disease and need hemodialysis.

Device Description

The everlinQ® endoAVF System (everlinQ®) consists of two single-use disposable magnetic catheters: a venous catheter and an arterial catheter, both of which are 6 Fr in diameter. The venous catheter contains an electrode for delivery of radiofrequency (RF) energy while the arterial catheter contains a ceramic backstop that serves as a mechanical stop for the electrode. The everlinQ® is used with a commercially available electrosurgical unit (ESU) and electrosurgical pencil.

AI/ML Overview

The EverlinQ® endoAVF system is a percutaneous catheter system indicated for the creation of an arteriovenous fistula (AVF) in the arm of patients with chronic kidney disease who need hemodialysis. The device's performance was evaluated through a pivotal study (NEAT Study) and a supportive Global Analysis, encompassing data from multiple clinical studies and commercial use.

Acceptance Criteria and Reported Device Performance

The primary effectiveness endpoint for the device was the percentage of patients with fistula maturation/usability at 3 months post-procedure. This was defined as an endoAVF that is free of stenosis or thrombosis, with brachial artery flow of at least 500 ml/min and at least 4 mm vein diameter (as measured by duplex ultrasound) OR the patient was dialyzed using 2 needles. The performance goal for this endpoint was set at 57.5%, derived from historical surgical AVF failure rates.

The primary safety endpoint was the percentage of patients who experienced one or more serious study device-related adverse events during the first 3 months following AVF creation, as adjudicated by an independent Clinical Events Committee (CEC). There was no formal hypothesis test associated with this safety endpoint.

Here's a table summarizing the acceptance criteria and reported device performance from the NEAT Study:

Acceptance Criteria CategorySpecific MetricAcceptance Criterion (Hypothesis/Goal)Reported Device Performance (NEAT Study)
EffectivenessPrimary effectiveness endpoint: Fistula maturation/usability at 3 months post-procedureLower bound of 90% CI for proportion of patients with fistula maturation/usability > 57.5%91.2% (52/57 subjects met the criteria) (82.4%, 96.5%) - Exact 90% Confidence Interval. Hypothesis Rejected (Performance Goal Met)
SafetyPrimary safety endpoint: Percentage of patients with one or more serious device-related adverse events at 3 months post-procedureNot a formal hypothesis test; evaluated for acceptable risk profile.1.67% (1/60 subjects experienced a serious device-related event) (0.04% - 8.94%) - Two-sided 95% exact binomial confidence interval.

Study Details Proving Device Meets Acceptance Criteria

The primary study used to demonstrate the device meets acceptance criteria was the Novel Endovascular Access Trial (NEAT Study), supplemented by a Global Analysis that pooled data from NEAT, FLEX, EU PMCF, and EASE studies, as well as commercial use data (COMM).

2. Sample Size and Data Provenance

  • Test Set (Clinical Studies):
    • NEAT Study (Pivotal): 60 "study cohort" subjects and 20 "roll-in" subjects. The primary effectiveness and safety analyses were performed on the 60 study cohort subjects.
    • Global Analysis (Supportive):
      • Pooled Safety Analysis Population: 125 subjects (from NEAT (N=60), FLEX (N=33), EU-PMCF (N=32)).
      • Pooled Effectiveness Analysis Population: 157 subjects (from NEAT (N=60), FLEX (N=33), EU-PMCF (N=32), EASE (N=32)).
      • COMM (Commercial data set): 79 subjects (not included in pooled safety/effectiveness due to data unavailability).
  • Data Provenance: The clinical studies were conducted in multiple countries:
    • NEAT: Canada, Australia, and New Zealand.
    • FLEX: Paraguay.
    • EU PMCF: Germany, England.
    • EASE: Paraguay.
    • COMM: England, Germany, Netherlands, Switzerland.
  • Retrospective/Prospective: All mentioned clinical studies (FLEX, NEAT, EU PMCF, EASE) were prospective, single-arm, multi-center studies. The commercial use data (COMM) was collected retrospectively from treating physicians.

3. Number of Experts and Qualifications for Ground Truth (Clinical Test Sets)

  • Clinical Events Committee (CEC): An independent CEC adjudicated all safety events (Serious Adverse Events and Significant Events).
  • Number of Experts: The CEC consisted of three independent physicians.
  • Qualifications of Experts: The physicians comprising the CEC had expertise in vascular surgery, interventional nephrology, and/or interventional radiology. Specific years of experience are not mentioned.

4. Adjudication Method for the Test Set

  • CEC Adjudication: The document states that "All procedural safety data and relevant post-procedure events were adjudicated by an independent CEC." The CEC Charter describes the event definitions and the adjudication process. It also mentions that "Each event was classified with respect to: 1. Relationship to the study device, 2. Relationship to the procedure, 3. Relationship to coil embolization, if used, 4. Relationship to a brachial artery closure device, if used, 5. Whether the event was an Unanticipated Adverse Device Effect, 6. Whether the event met the definition of a Significant Event."
  • The exact voting mechanism (e.g., 2+1, 3+1) is not explicitly stated beyond stating it was an "independent CEC." However, given the three-expert composition, it is highly likely that a consensus or majority vote mechanism was used.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

  • No MRMC study was performed. This device is a medical device for creating a fistula, not an AI/imaging diagnostic tool. Therefore, a comparative effectiveness study evaluating human readers' improvement with vs. without AI assistance is not applicable to this submission.

6. Standalone Performance (Algorithm Only)

  • Not Applicable. The EverlinQ® system is a physical medical device, not an algorithm or software. The document explicitly states: "The everlinQ® endoAVF System does not contain software." Therefore, standalone algorithm performance was not relevant or assessed.

7. Type of Ground Truth Used (Clinical Test Sets)

The "ground truth" for the clinical effectiveness and safety endpoints was primarily based on:

  • Clinical Assessments and Measurements:
    • Duplex Ultrasound: Used for measuring brachial artery flow (ml/min) and vein diameter (mm) for the primary effectiveness endpoint.
    • Direct Observation/Confirmation: Fistulography or duplex ultrasound verification confirmed successful endoAVF creation for procedural success.
    • Clinical Usability: Patient was dialyzed using 2 needles (part of the primary effectiveness endpoint and functional cannulation assessments).
    • Adjudicated Events: Safety events (SAEs, significant events) were adjudicated by the independent CEC based on medical records and definitions.
  • Outcome Data: Patency rates (primary, assisted primary, secondary, functional) and CVC exposure were tracked based on clinical outcomes.

8. Sample Size for the Training Set

  • Not Applicable/Not Explicitly Defined in this Context. The device is a physical medical device, not an AI/ML model that undergoes "training" on a "training set" in the computational sense. The "training" referred to in the document relates to the training of physicians in the proper use of the device, which occurred after initial study completion and was evaluated in a smaller, subsequent cohort.

9. How Ground Truth for Training Set was Established

  • Not Applicable. As noted above, there is no "training set" in the AI/ML sense to establish ground truth for. The "training" in the document refers to physician training on device usage. The impact of this physician training was observed in a small cohort, demonstrating a numerical reduction in SAEs related to brachial artery access. This outcome acted as an observed result rather than a "ground truth" derived for a training dataset.

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DE NOVO CLASSIFICATION REQUEST FOR EVERLINQ® ENDOAVF SYSTEM

REGULATORY INFORMATION

FDA identifies this generic type of device as:

Percutaneous catheter for creation of an arteriovenous fistula for hemodialysis access. This device is a single use percutaneous catheter system that creates an arteriovenous fistula (AVF) in the arm of patients with chronic kidney disease who need hemodialysis.

NEW REGULATION NUMBER: 21 CFR 870.1252

CLASSIFICATION: II

PRODUCT CODE: POK

BACKGROUND

DEVICE NAME: everlinQ® endoAVF System

SUBMISSION NUMBER: DEN160006

DATE OF DE NOVO: February 3, 2016

CONTACT: TVA Medical, Inc. 7000 Bee Cave Rd., Suite 250 Austin, TX 78746

INDICATIONS FOR USE

The everlinQ® endoAVF System is indicated for the creation of an arteriovenous fistula (AVF) using the ulnar artery and ulnar vein in patients with minimum artery and yein diameters of 2.0 mm and less than 2.0 mm separation between the artery and vein at the fistula creation site who have chronic kidney disease and need hemodialysis.

LIMITATIONS

The sale, distribution, and use of the everlinO® endoAVF System are restricted to prescription use in accordance with 21 CFR 801.109.

Only physicians trained and experienced in endovascular techniques, who have received appropriate training with the device, should use the device. Endovascular technique training and experience should include ultrasound vessel access in the arm, guidewire navigation, radiographic imaging, embolization coil placement, and access closure,

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The everlinQ® endoAVF System is contraindicated for patients with a distance between target artery and vein > 2mm, and patients with target vessels < 2mm in diameter.

The TVA Medical everlinQ® System is only to be used with the components specified in the labeling. Do not attempt to substitute a non-approved component or to use any component of this system with any other medical device system. Use of the system with other components, such as braided sheaths, may interfere with proper functioning of the device.

The 6F everlinQ System has only been evaluated for the creation of an AVF using the ulnar artery and ulnar vein. The device should not be used in place of a more distal AVF.

Adjunctive procedures are expected to be required at the time of the index procedure to increase and direct blood flow into the AVF target outflow vein to assist maturation. Care should be taken to proactively plan for any adjunctive procedures, such as embolization coil placement, when using the device.

PLEASE REFER TO THE LABELING FOR A MORE COMPLETE LIST OF WARNINGS, PRECAUTIONS AND CONTRAINDICATIONS.

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DEVICE DESCRIPTION

The everlinQ® endoAVF System (everlinQ®) consists of two single-use disposable magnetic catheters: a venous catheter and an arterial catheter, both of which are 6 Fr in diameter. The venous catheter contains an electrode for delivery of radiofrequency (RF) energy while the arterial catheter contains a ceramic backstop that serves as a mechanical stop for the electrode. The everlinQ® is used with a commercially available electrosurgical unit (ESU) and electrosurgical pencil.

Image /page/2/Figure/2 description: The image shows an electrosurgical generator, ground pad, electrosurgical pencil, and everlinQ endoAVF catheters. The electrosurgical generator has a display that reads "060 20 SEC". There is also a detailed diagram of the 6 Fr Rapid Exchange Venous Catheter and the 6 Fr Over-the-Wire Arterial Catheter, showing the electrode housing, radiofrequency electrode, embedded magnets, and electrode backstop.

Figure 1: everlinQ® endoAVF System

The venous and arterial catheters are inserted into the ulnar vein and ulnar artery, respectively. The two catheters are then aligned and rotated, and when they achieve the proper position, the magnets contained in each catheter attract to one another, approximating the vessels while simultaneously aligning the electrode with the backstop. Using the ESU, grounding pad, and electrosurgical pencil, RF energy can then be delivered through the electrode for tissue cutting. This energy creates a small, rectangular hole (approximately 5 mm x 1 mm) in the adjoining vessels, allowing blood to flow from the artery to the vein and thereby creating a nonsurgical, or endovascular, arteriovenous fistula (endoAVF).

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Image /page/3/Figure/0 description: The image shows an x-ray of two catheters, labeled as "Arterial Catheter" and "Venous Catheter". The arterial catheter is on top and appears to have regularly spaced, rectangular, radio-opaque markers. The venous catheter is below the arterial catheter and appears to be a single, continuous tube.

Figure 2: Proper alignment of the catheters

Please refer to the Instructions for Use for additional details.

SUMMARY OF NONCLINICAL/BENCH STUDIES

BIOCOMPATIBILITY/MATERIALS

The everlinQ® endoAVF System is an externally communicating device in contact with circulating blood with limited contact duration (< 24 hours). The biocompatibility testing summarized below was performed to demonstrate that the device is biocompatible for its intended use. All tests passed.

TestDescription (Method)
CytotoxicityMEM Elution Assay with L-929 Mouse Fibroblast Cells(ISO 10993-5)
SensitizationGuinea Pig Maximization(ISO 10993-10)
IrritationIntracutaneous Reactivity(ISO 10993-10)
Acute System ToxicityAcute Systemic Injection(ISO 10993-11)
HemocompatibilityASTM Hemolysis Assay - Direct Contact & Extract Methods(ASTM Method F756-08)Complement Activation C3a and SC5b-9 Determination of SC5b-9 Terminal Chain Complex (TCC) and C3a-desArg Present in Normal Human Serum Through Enzyme Immunoassay(ISO 10993-4)In-vivo Thromboresistance(evaluated as part of the animal studies)
PyrogenicityMaterial-mediated Rabbit Pyrogen(USP Rabbit Pyrogen Test Procedure, Section 151)Endotoxin-mediated (LAL)(AAMI ST72)
Table 1: Biocompatibility Testing Summary
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SHELF LIFE/STERILITY

The shelf-life of the everlinQ® endoAVF System has been established at 1 year based on accelerated aging testing equivalent to 1 year (13 months) in accordance with ASTM F 1980 - 07 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices. Following 2X sterilization, environmental conditioning per ISTA 2A, distribution simulation per ASTM D4169, and accelerated aging, the devices were visually inspected for damage, bubble leak tested per ASTM F2096, and package seals were tested per ASTM F88. Aged devices also underwent repeat engineering bench testing to confirm acceptable performance.

The everlinQ® endoAVF System is labeled as sterile and has a validated sterility assurance level (SAL) of 106. The everlinO® endoAVF System has been validated to be sterilized via ethylene oxide (EO). The sterilization cycle was validated using the half cycle method per ISO 11135-1:2007, and the EO and ECH residuals were shown to meet the limits specified by ISO 10993-7:2008.

ELECTROMAGNETIC COMPATIBILITY AND ELECTRICAL SAFETY

The electromagnetic compatibility and electrical safety of the everlinQ® endoAVF System was evaluated by demonstrating compliance to the following standards:

StandardName
AAMI / ANSIES60601-1:2005/(R)2012 andA1:2012,C1:2009/(R)2012 andA2:2010/(R)2012Medical Electrical Equipment - Part 1: GeneralRequirements For Basic Safety And EssentialPerformance
IEC 60601-1-2:2014Medical Electrical Equipment - Part 1-2:General Requirements For Basic Safety AndEssential Performance - Collateral Standard:Electromagnetic Disturbances - Requirementsand Tests
IEC 60601-2-2:2009Medical Electrical Equipment - Part 2-2:Particular Requirements For The Basic SafetyAnd Essential Performance of High FrequencySurgery Equipment And High FrequencySurgical Accessories

Table 2: Electrical Performance Testing Summary

MAGNETIC RESONANCE (MR) COMPATIBILITY

The everlinQ® endoAVF System is intended as a temporary use device and has not been tested for MR compatibility.

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SOFTWARE

The everlinQ® endoAVF System does not contain software. The device is intended to be used with a commercially available ESU, electrosurgical pencil, and grounding pad.

PERFORMANCE TESTING - BENCH

The everlinQ® endoAVF System was subjected to a series of bench tests to assess its functional performance. These tests were performed on final, sterilized product. The engineering bench testing summarized in Table 3 below was performed to demonstrate acceptable mechanical performance of the device for its intended use.

TestDescription/Acceptance Criteria
DimensionalVerificationElectrode WireDeployment(Distance)The distance from distal tip of electrode (toe) to catheter shaft mustmeasure .093" $\pm$ .010" when slide collar/electrode are in "fire"position.
Electrode WireDeployment(Angle)Angle between flattened surface of the electrode and the centerlineof the catheter shaft must measure 7.5° $\pm$ 2.5° when slidecollar/electrode are in "fire" position.
SimulatedUseSimulated UseConditioningTrack the device through a simulated worst-case anatomic modelusing the appropriate accessories (e.g. introducer sheaths).
Handle ActuationElectrodes must deploy from electrode housing when slide collar ispulled proximal to device and reside in "fire" position. Rotatingslide lock must permit electrode to be pulled into the proximalelectrode housing such that no part of the electrode protrudes nofurther than the outside diameter of the catheter.
Device AlignmentWith catheters magnetically apposed and electrode deployed,rotational and axial alignment must be held such that the electrodemaintains contact within the margins of the arterial backstop in100% of samples tested.
Energy DeliveryUpon application of energy, devices must create heat eddies at theactive electrode while exhibiting no degradation in insulativematerials near the active electrode. The test also evaluated theability of the device to deliver energy properly when used with thelabeled electrosurgical generator.
Tissue Cutting TestElectrodes must be able to create a transmural window measuring $\ge$1mm long and $\ge$ .25mm wide in tissue measuring $\ge$ 2.0mm thickwhen the device is used in conjunction with the labeledelectrosurgical unit at the required electrical settings.
Torque StrengthThe distal tip of the device was fixed, and the proximal end of thedevice was rotated until failure. The number of rotations to failureand the failure mode were characterized.
Torque ResponseThe catheters were rotated 360° clockwise and 360°counterclockwise within the anatomic model, and the process wasrepeated four times. The torque response was evaluated.
Visual InspectionFollowing simulated use, devices must be free from any damagethat would prevent it from normal function/use and devices mustmeet performance requirements established for all subsequentverification tests.

Table 3: Performance Testing (Bench) Summary

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Tensile StrengthBonds/joints shall maintain mechanical integrity during useEach bond/joint was tested against specifications based on the clinical use of the device
Corrosion ResistanceMetallic components of the catheter intended for fluid path contact shall show no signs of corrosion.
Leak TestingAir shall not leak into the hub assembly during aspirationThe hub or catheter shall not leak liquid
Catheter LubricityThe LTL for average pull force over five cycles will be < 50g when tested over a 10cm distance and 500g pinch force.
Visual InspectionCatheters must be free from any damage that would prevent it from normal function or use. This includes, but is not limited to fractures, cracks, kinks, tears, loose components, or inadvertent electrode deployment.
RadiopacityVisibility of the device and alignment under fluoroscopy was demonstrated by representative images taken during the animal studies.
CoatingIntegrityTestingCoatingDurability andCoverageParticulateAnalysisCoated venous and arterial catheters were stained with (b) (4) dye and evaluated for stain coverage after moderate finger rubbing.All test samples exhibited at least 90% stain coverage.
Average # of Particles(Per device pair) Diameter Size Range(μm) Test Group ≥ 10 ≥ 25 ≥ 50 Initial (T = 0) 6382 238 14 Aged (T = 1yr) 3171 152 20
Electrical PlugTestingCord TensileStrengthShroud TensileStrengthShroudCompressiveStrengthPeak tensile strength between the plug and the cord must be ≥ 5 lbf.Peak tensile strength between the plug and the shroud must be ≥ 5 lbf.Peak compressive strength between the plug and the shroud must be ≥ 5 lbf.

PERFORMANCE TESTING - ANIMAL &/OR CADAVER

Two main groups of studies were conducted to support the development of the everlin()® endoAVF System: (1) early testing using an early version of the device in a cadaver study along with three non-GLP acute animal studies and (2) a concluding eight-animal GLP chronic and acute study using the final device.

The non-GLP acute animal studies and cadaver study used an early version of the device that was similar to the final device design. These studies demonstrated that an endoAVF could be successfully created, there was no unintended tissue damage, and no thrombus formation was observed. These studies also demonstrated that the device could be successfully delivered to the desired location of the AVF using the labeled accessories and that the device was easy to use. The design and results of the GLP study are summarized in Table 4 below. The GLP study demonstrated that the endoAVF could be created safely with adequate blood flow through the fistula and no adverse

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histopathological findings at 30 days.

PurposeMethodsResults
Evaluate the acute andchronic safety, fistulablood flowcharacteristics, fistulapatency, handlingcharacteristics,visibility underfluoroscopy, thrombusformation, andhistopathologicalresponse at thetreatment site and off-target tissue sites ofthe final device designaccording to GoodLaboratory Practices• GLP• N=8 ovine models (N=4 acutestudy, N=4 chronic study).Acute Study• Insert, track, deploy, andactivate device to create asingle AVF in N=2 ovinemodels, then procedure timeand energy delivery wererecorded.• After creation, fistulasevaluated (by ultrasound,thermal dilution and/orfluoroscopy via contrastinjection) to determine patencyand fistula flow.• After 0-1 hour survival,necropsy performed to ensureno downstream tissue effects.• AVF site, vessels and tissue inproximity were histologicallyexamined to characterize thesetissues.• Insert, track, deploy, andactivate device to create 4 or 5AVFs in N=2 additional ovinemodels.• After 0-1 hour survival,necropsy performed in whichthe vessels were identified andAVFs photographed.Chronic Study• Insert, track, deploy, andactivate device to create asingle AVF in N=4 ovinemodels.• After creation, fistulasevaluated (by ultrasound,thermal dilution and/orfluoroscopy via contrastinjection) to determine patencyand fistula flow.• After 30 days survival, fistulasagain examined to determinepatency and fistula flow.• Necropsy performed to ensureno downstream tissue effects.• AVF site, vessels and tissue in• 14/15 attempts to create fistulas in the 8animals were successful. One attemptfailed due to a procedural mistakerelated to the ovine vasculature, and isnot relevant to the intended humananatomy.• All animals survived to the prescribedin-life survival.• There was no morbidity or majorunanticipated events that were relatedto the use of the device.• Fistulas were shown to be patent at 30days following AVF creation usingfluoroscopic imagery.• Blood flow was observed after fistulacreation and at 30 days.• There was no evidence of mechanicalor thermal injury extending beyond theimmediate treatment site following theprocedure, and fistula sites appeared toheal well by 30 days.• Arterial and venous ostia appearedacceptably uniform in size andappearance.• No gross findings in off-target ordownstream tissues which wereindicative of device or treatment relatedevents.• Histopathology in acute animals wasnegative for thromboembolic events inthe lungs or coronary bands.• Post-procedure histopathology oftreatment sites showed focalperforations in the artery and vein withperivascular hemorrhage intosurrounding fat, as well as treated edgesof the ostia characterized by focal mildcompressions and subtle thermalcoagulation. The observations appearedto be expected for the AVF creationprocedure and resolved with time.• Histopathology at 30 days showed thefistulae were patent and maturing, withno evidence of thromboemboligeneration, vascular remodeling, orinjury.• No bleeding was observed at 30 days.• No histopathological observationsrelated to the device were noted in theheart.
proximity were histologicallyexamined to characterize thesetissues.• Mechanical and thermal injury,inflammation, fibrin/thrombus,fibrosis, mineralization,necrosis, hemorrhage, andintimal proliferation wereevaluated.• Gross pathology of treatmentsites, subcutaneous tissues onthe downstream distal limb, andsystemic organs in acute andchronic studies.• Histopathology of acutetreatment sites, chronic• No histopathological findings related todevice safety were observed in thelungs. One small, localized fat emboluswas observed but was asymptomaticand deemed to be coincidental as it hasnot been observed to occur duringpercutaneous interventional proceduresin the arteries or veins in humans.

Table 4: Summary of GLP Preclinical Study

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SUMMARY OF CLINICAL INFORMATION

The everlinQ® System was primarily supported by a pivotal study entitled the "Novel Endovascular Access Trial" (NEAT Study). In addition, a supportive global analysis of clinical use of the everlinQ® System ("Global Analysis") was conducted that included data from 4 prospective clinical studies (FLEX, NEAT, EU PMCF and EASE) and 1 commercial use data set (COMM). A pooled analysis of the 4 prospective clinical studies was also presented. Details of the study designs and key clinical outcomes are provided in the following sections. The study names are defined as follows:

  • FLEX A Prospective Pilot Clinical Evaluation of the TVA FLEX-1 Device .
  • NEAT Novel Endovascular Access Trial .
  • EU PMCF Post Market Study of the everlinQ® endoAVF System .
  • EASE everlinQ® Endovascular Access System Enhancements Study .
  • COMM commercial use data set .
Data SourceDevice StudiedDates of IndexProcedures# Sites(Countries)TotalSubjectsSubjects in PooledAnalysis5
SafetyEffectiveness
FLEX16Fr FLEX-1Aug 2012-Sep20131 (Paraguay)333333
NEAT6Fr everlinQ®Jan 2014- Aug20156 (Canada)2 (Australia)606060
EASE24Fr everlinQ®May 2016 - Nov20161 (Paraguay)32032
EU-PMCF6Fr everlinQ®Sep 2016 - Aug20175 (Germany)3 (England)323232
COMM- All36Fr everlinQ®Feb 2015 - Jun20174 (England)16 (Germany)7900

Table 5: Clinical Data Sources

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COMM -Cannulated4Feb 2015 - Aug 20171 (Netherlands)1 (Switzerland)4500
Total Subjects5236125157
  • The FLEX-1 device was a previous version of the subject device. After the FLEX Study, design modifications 1. were made to improve ease of use (i.e. handle ergonomics and user interface). The overall mechanism of action and device function for creating an endoAVF has remained the same throughout all revisions of the 6Fr FLEX-1 and everlinO® devices.
    1. The EASE subjects were not included in the Pooled Safety Population, since the 4Fr system is a different product compared to the 6Fr systems used in the other data sources.
    1. No COMM subjects were included in the Pooled Safety or Effectiveness Populations because data were unavailable in the commercial cases, precluding pooling.
  • The COMM-Cannulated cases comprise the subset of COMM-All cohort where follow-up data were collected. 4. including safety data and cannulation data.
  • The total number of subjects is less than the sum of the "Total Subjects" column because the COMM -5 Cannulated subject cohort is a subset of all the commercial subjects included in the COMM-All data.

Primary Clinical Data Set: NEAT Study

Objective: The purpose of the NEAT Study was to evaluate the safety and effectiveness of the everlinO endoAVF System among subjects undergoing endoAVF creation.

Study Design: The NEAT study was a prospective, single-arm, multi-center study that enrolled 60 "study cohort" subjects and 20 "roll-in" subjects at 9 sites in Canada, Australia and New Zealand. Candidates for this study were subjects with chronic kidney disease (CKD) who required a hemodialysis vascular access.

Eligibility Criteria Summary: The study population consisted of male and female patients from Canada, Australia, and New Zealand who had chronic kidney disease (CKD), required a hemodialysis vascular access, and were at least 18 years of age.

Key inclusion criteria included the following:

  • . Established, non-reversible kidney failure requiring hemodialysis.
  • Patients deemed eligible for a native arteriovenous fistula.
  • Target artery diameter and target vein diameter both ≥ 2.0 mm.
  • Estimated life expectancy > 1 year.
  • . Subject was free of clinically significant conditions or illness within 30 days prior to the AV fistula that may compromise the procedure.

Key exclusion criteria included the following:

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  • Subjects who are eligible for a distal forearm fistula were excluded from the study. . Exception: If a distal forearm fistula had failed or distal forearm fistula was not the most optimum choice the subject was considered eligible to enroll.
  • . Known central venous stenosis or central vein narrowing > 50% based on imaging on the same side as the planned AVF creation.
  • . Upper extremity venous occlusion(s) and/or vessel abnormality(ies) on the same side as the planned AVF creation that precludes endovascular AVF creation by everlinQ endoAV System as deemed by the interventionalists' clinical judgment.
  • At the time of procedure distance between target artery and vein will not allow magnets . to align vessels sufficiently to create the fistula.
  • Prior upper arm surgically created access or functioning surgical access in the planned ● treatment arm.
  • Subjects with Body Mass Index (BMI) >35 who, in an expert cannulator's opinion, are ● not appropriate candidates for cannulation.
  • "Planned" concomitant major surgical procedure within 6 months of enrollment or previous major surgery within 30 days of enrollment.
  • . Immunosuppression, defined as use of immunosuppressive medications used to treat an active condition.
  • . New York Heart Association (NYHA) class III or IV heart failure.

Demographics: The total Intent-to-Treat (ITT) population consisted of 60 subjects. Data about the patient demographics and baseline comorbidities are provided in the tables below.

CharacteristicSummary
Gender
Male65.0% (39/60)
Female35.0% (21/60)
Age (years)59.9 ± 13.6 (60)61.0 [28.0, 85.0]
BMI27.9 ± 6.1 (60)27.1 [16.1 ,44.1]
BMI > 2563.3% (38/60)
Target Dialysis Weight (kg)80.9 ± 21.9 (60)78.7 [43.0, 138.9]
Race
Caucasian60.0% (36/60)
Asian31.7% (19/60)
Native Hawaiian/Pacific Islander1.7% (1/60)
Other6.7% (4/60)
Smoker (current or previous)33.3% (20/60)
Previous AVF (prior to study)31.7% (19/60)
Same arm as used for endoAVF creation73.7% (14/19)
Contralateral arm as used for endoAVF creation26.3% (5/19)
Pre-dialysis56.7% (34/60)
Data displayed as Mean±SD (N);Median [Range] or % (n/N).

Table 6: NEAT Study Subject Demographics

Table 7: NEAT Study Baseline Comorbidities

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Medical Condition/ComorbiditySummary% (n/N)
Primary Diagnosis Causing ESRD:
Diabetes50.0% (30/60)
Glomerular based disease13.3% (8/60)
Hypertension15.0% (9/60)
Interstitial nephritis1.7% (1/60)
Polycystic kidney disease6.7% (4/60)
Other11.7% (7/60)
Unknown1.7% (1/60)
Comorbidities:
Chronic Obstructive Pulmonary Disease (COPD)3.3% (2/60)
Cerebrovascular Disease (CVA/TIA)15.0% (9/60)
Congestive heart failure (NYHA I or II)11.7% (7/60)
Coronary artery disease (CAD)21.7% (13/60)
Diabetes65.0% (39/60)
Hypertension91.7% (55/60)
Hyperlipidemia48.3% (29/60)
Malignancy18.3% (11/60)
Prior peritoneal dialysis30.0% (18/60)
Prior renal transplant13.3% (8/60)

Accountability: A total of 183 subjects were screened for participation in the study. Sixteen (16) patients declined to participate and 84 patients failed initial screening. Three (3) additional patients failed final enrollment criteria (distance between target artery and vein too great at time of procedure) and were excluded at the time of index procedure. Most subjects who were excluded from the study did not meet the target vessel criteria of ≥ 2mm. In total, 80 subjects were enrolled in the study; 60 subjects were included in the study cohort and 20 subjects comprised a roll-in cohort.

Figure 3 below depicts the subject disposition in the NEAT Study. The figure shows the number of subjects who were evaluated or exited the study at each time point. Among the 60 study cohort subjects, 3 subjects (5%) died during the study and 8 (13.3%) withdrew for other reasons. A total of 11 subjects (18.3%) exited the study before the 12-month follow-up time point, and 4 additional subjects (6.7%) were not yet eligible for their 12-month evaluation at the final NEAT study report was submitted.

In total, 45/60 subjects (75%) were evaluated at 12 months. Those 45 subjects included 24 predialysis subjects (24/34 = 70.6% of pre-dialysis subjects) and 21 dialysis subjects (21/26 = 80.8% of dialysis subjects).

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Image /page/12/Figure/0 description: This image is a flowchart that shows the progression of subjects through a study. The study started with 183 subjects assessed for eligibility, and 80 were enrolled. Of the 183, 103 were excluded because they did not meet the inclusion criteria or declined participation. The 80 enrolled subjects were divided into two groups: 20 roll-in subjects and 60 study cohort subjects, and the flowchart shows the number of subjects who completed each follow-up visit, as well as the number of subjects who exited the study at each time point.

Figure 3: NEAT Study Subject Disposition Through End of Study

Primary Endpoints

    1. Safety: The safety endpoint was the percentage of patients who experienced one or more serious study device related adverse events during the first 3 months following AVF creation as adjudicated by an independent Clinical Events Committee (CEC). There was no formal hypothesis test associated with the safety endpoint. Analysis of the safety endpoint was performed on the study cohort subjects.

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The following definitions were used for the safety analyses:

  • Adverse event (AE): any untoward medical occurrence, unintended disease or injury, or . untoward clinical signs (including abnormal laboratory findings) in subjects, users or other persons, whether or not related to the investigational medical device.
  • Serious adverse event (SAE): A serious adverse event was defined as an adverse event that:
    • a) Led to death,
    • b) Led to serious deterioration in the health of the subject, that either resulted in
      • i. a life-threatening illness or injury, or
      • a permanent impairment of a body structure or a body function, or ii.
      • iii. in-patient or prolonged hospitalization, or
      • medical or surgical intervention to prevent life-threatening illness or injury or iv. permanent impairment to a body structure or a body function,
    • c) led to foetal distress, foetal death or a congenital abnormality or birth defect

NOTE: Planned hospitalization for a pre-existing condition, or a procedure required by the Study Protocol, without serious deterioration in health, was not considered an SAE.

    1. Effectiveness: The primary endpoint of the study was the percentage of patients with fistula maturation/usability at 3 months post-procedure, defined as endoAVF that is free of stenosis or thrombosis, with brachial artery flow of at least 500 ml/min and at least 4 mm vein diameter (as measured by duplex ultrasound) OR patient was dialyzed using 2 needles.
      Note: stenosis and thrombosis were defined as flow limiting complications that led to fistula closure at any time during the first 3 months post index procedure. Dialysis using 2 needles were assessed at any time during the first 3 months post index procedure.

This composite endpoint was chosen based on the most common three reasons for AVF failure to mature or lack of AVF usability: 1) thrombosis, 2) stenosis and 3) inadequate flow or diameter of the vein leading to abandoned AVF.

The primary effectiveness endpoint was tested for all 60 study cohort subjects ("Enrolled" population). Subjects in whom an endoAVF was attempted (i.e. RF energy was applied) but not created were included in the analysis as failures. If a patient had missing endpoint data, due to reasons not related to the endoAVF, procedure, or device, they were not included in the primary analysis.

The formal hypothesis tested for the primary endpoint was the 3-months proportion of patients with fistula maturation/usability greater than a historically derived performance goal:

Ho: π ≤ 57.5% vs. Ha: π > 57.5%,

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where T is the proportion of patients with fistula maturation/usability and 57.5% is the historically derived performance goal (PG). The PG was derived based on surgical AVF failure rates reported in clinical literature.

The number and percentage of patients with fistula maturation/usability within 3 months were summarized. A 90% exact confidence interval (CI) was calculated. The lower bound of the confidence interval was compared to the performance goal of 57.5% to determine success.

Secondary Endpoints

Secondary endpoints were summarized using descriptive statistics. There were no formal hypotheses associated with these endpoints and these analyses were not statistically powered. Analyses for each endpoint were performed on the study cohort subjects unless otherwise noted.

  • Procedural success: The successful endoAVF creation rate as assessed via fistulogram . immediately post-procedure or duplex ultrasound, or via presence of thrill/bruit.
  • . Time to Fistula Maturation: the number of days between the date of AVF creation and the date of endoAVF maturation (based on primary efficacy endpoint definition of maturation).
  • Duration of Central Venous Catheter (CVC) Exposure: The rate of CVC use at 1, 2, 3, 6 and 12 months follow-up. The analysis was performed for pre-dialysis and on dialysis subjects.
  • . endoAVF-related Interventions Rate: The intervention rate for endoAVF (defined as any intervention required to maintain or re-establish patency; may be also referred as "reintervention" rate) was calculated at 3, 6 and 12 months post index procedure.
  • Primary Patency: The primary patency rate was determined via Kaplan-Meier methods and . based on the time of endoAVF creation until any intervention designed to maintain or reestablish patency or endoAVF abandonment.
  • . Secondary Patency: The secondary patency rate was determined via Kaplan-Meier methods and based on the time of endoAVF creation until access abandonment.
  • . Additional analyses were summarized using descriptive statistics:
    • Rate of serious procedure-related AEs at 3 and 6 months. o
    • o Rate of serious device-related AEs at 6 months.
    • Rate of device and/or procedure-related infections at 6 months. o
    • Arterial flow rates and diameters as measured via DUS at 3, 6 and 12 months post o index procedure.
    • o Subject satisfaction and quality of life parameters via Vascular Access questionnaire.
    • The percentage of subjects dialyzed using endoAVF (2 needles) for 2/3 of their o dialysis sessions over a 4-week period.

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Results: The principal safety and effectiveness results from patients in the study are provided below. The analyses were performed on all 60 study cohort subjects (excluding roll-in subjects) unless otherwise noted.

Primary Safety Endpoint: At 3 months post index procedure, only one subject experienced one serious device related event (pseudoaneurysm), resulting in an observed percentage of 1.67% (1/60) with a two-sided 95% exact binomial confidence interval of 0.04% - 8.94%.

Primary Effectiveness Endpoint: The primary effectiveness endpoint results are shown in the table below. The primary endpoint was met with a 90-day maturation success rate of 52/57 (91.2%).

SubjectSuccess% (n/N)Exact 90%ConfidenceIntervalHypothesisDecisionConclusion
Subject with endoAVF that isfree of stenosis or thrombosis1,with brachial artery flow of atleast 500 ml/min and at least 4mm vein diameter OR subjectwas dialyzed using 2 needles1As adjudicated by the CEC.91.2%(52/57)(82.4%,96.5%)Ho: ps $ \u2264 $ 57.5%HA: ps > 57.5%RejectHoPerformanceGoal Met

Table 8: Primary Effectiveness Endpoint Results - 90-Day Maturation Success Rate

The primary effectiveness analysis did not include 3 subjects who either died prior to the 90-dav evaluation, unrelated to the device or procedure (1 subject) or experienced a procedural complication that led to endoAVF sacrifice (2 subjects).

If all 60 study cohort subjects were included in the primary endpoint analysis, the primary endpoint result was 52/60 = 86.7%. The primary endpoint was still met (90% CI: 77.2-93.2%).

Secondary Endpoints: A summary of the secondary endpoint analyses are provided below. All analyses presented below are based on the ITT population unless otherwise noted.

  • Procedural Success: Procedural success was achieved in 59/60 subjects (98.3%) per the definition above.
  • . Time to Fistula Maturation: The mean time to maturation based on the endpoint criteria was 14.8 days. Additional details are provided in the table below.

Table 9: Time to Fistula Maturation

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Maturation TimeMean ± SD (N)Median [Range]
Days to endoAVF maturation based on DUS14.8 ± 26.0 (52)5.0 [1.0, 97.0]
Days to endoAVF maturation based on physical exam65.0 ± 44.3 (45)58.0 [26.0, 213.0]
  • . Duration of Central Venous Catheter (CVC) Exposure: CVC exposure was evaluated for both pre-dialysis subjects and subjects who were on dialysis. Table 10 below shows the number of subjects who had a CVC in place at each timepoint. In sum, the total NEAT study CVC exposure at 12 months was 14/60 subjects (23.3%), calculated by adding 4/35 CVC only + 0/35 CVC and endoAVF subjects from the pre-dialysis subset, in addition to 6/25 CVC-only + 4/25 CVC and endoAVF subjects from the post-dialysis subset.
Pre-Dialysis Subjects
1-Month (0-45 Days)
CVC only3/35 (8.6%)
endoAVF only0/35 (0.0%)
CVC + endoAVF0/35 (0.0%)
Other0/35 (0.0%)
3-Month (46-135 Days)
CVC only3/35 (8.6%)
endoAVF only8/35 (22.9%)
CVC + endoAVF2/35 (5.7%)
Other0/35 (0.0%)
6-Month (136-270 Days)
CVC only3/35 (8.6%)
endoAVF only8/35 (22.9%)
CVC + endoAVF4/35 (11.4%)
Other1/35 (2.9%)
12-Month (271-390 Days)
CVC only4/35 (11.4%)
endoAVF only10/35 (28.6%)
CVC + endoAVF0/35 (0.0%)
Other1/35 (2.9%)
Post-Dialysis Subjects
1-Month (0-45 Days)
CVC only24/25 (96.0%)
endoAVF only0/25 (0.0%)
CVC + endoAVF0/25 (0.0%)
Other1/25 (4.0%)
3-Month (46-135 Days)
CVC only9/25 (36.0%)
endoAVF only1/25 (4.0%)
CVC + endoAVF13/25 (52.0%)
Other1/25 (4.0%)
6-Month (136-270 Days)
CVC only4/25 (16.0%)
endoAVF only6/25 (24.0%)

Table 10: Duration of CVC Exposure

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Other4/25 (16.0%)
12-Month (271-390 Days)
CVC only6/25 (24.0%)
endoAVF only11/25 (44.0%)
CVC + endoAVF4/25 (16.0%)
Other4/25 (16.0%)
  • endoAVF-related Interventions Rate: Table 11 below shows the number and types of . adjunctive procedures that were performed at the same time as the endoAVF index procedure. In total, 56/60 subjects (93.3%) required the implantation of at least one coil in their brachial vein at the time of the index procedure to redirect blood flow to the superficial veins and support maturation of the target cannulation area. The mean number of coils used per subject who received them was 1.6, with a range of 1.0-3.0 coils.
    Table 12 shows the number of subjects who required at least one reintervention after the index procedure to assist maturation of the endoAVF or to maintain a mature endoAVF. The total number and types of reinterventions are also tabulated.
Adjunctive Procedure# of Subjects (%)
Therapeutic embolization56 (93.3%)
Arterial closure device use41 (68.3%)
PTA0 (0.0%)
Stent0 (0.0%)
Other*6 (10.0%)
Total Subjects with > 1 Procedure58/60 (96.7%)

Table 11: Adjunctive Procedures Performed at Index Procedure

  • Other procedures include thrombolysis (1), thrombectomy (2), new surgical AVF (1), open surgical repair for an intraoperative complication (6).

Adjunctive procedures are tabulated by the procedure (i.e. one subject may have more than one adjunctive procedure), except for the last row which tabulates the data at the subject level.

ReinterventionIndication0-90 Days0-180 Days0-365 Days
Coil EmbolizationMaturation Assistance225
AngioplastyMaturation Assistance112
TranspositionFacilitate Cannulation035
Surgical Fistula or GraftNew Access Needed002
EndoAVF LigationAdverse Event333
Thrombin Injection for PseudoaneurysmAdverse Event222
Surgical Procedure for ComplicationAdverse Event111
Total Reinterventions-91220
Total Subjects with ≥ 1 Reintervention-7/60 (11.7%)10/60 (16.7%)17/60 (28.3%)

Table 12: endoAVF-related Reinterventions in NEAT Study

  • Primary Patency: The following primary patency rates were reported: .
    • O Primary patency, 6 months: 81.1%

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  • Primary patency. 12 months: 73.4% o
  • o Assisted primary patency, 6 months: 84.8%
  • Assisted primary patency, 12 months: 77.2% O
  • Secondary Patency: The following secondary patency rates were reported: .
    • 0 Secondary patency, 6 months: 86.4%
    • Secondary patency, 12 months: 78.9% o

Additional Analyses

Rate of Serious Device- and Procedure-Related AEs

A total of eight (8) serious adverse events (SAEs) in five (5) subjects were adjudicated as procedure and/or device-related. All eight (8) SAEs were adjudicated as procedure-related, and one of the eight (1/8) SAEs (pseudoaneurysm near endoAVF) was adjudicated as related to both the device and the procedure. Seven of the eight (7/8) SAEs occurred within 24 hours of the index procedure. One (1) SAE (steal syndrome) occurred on Day 8 post index procedure, representing the maximum number of days post-index procedure for onset of a serious procedure-related event. A summary of SAEs related to the study procedure and/or device has been provided in Table 13 below.

All SAEs were able to be resolved through intervention or resolved on their own. There were no instances of permanent impairment associated with the device. No new serious procedure and/or device related events were reported beyond 3 months.

0-3 Months3-6 Months> 6 MonthsOverall
EventsiTotalEventsSubjectsExperienced% (n/N)TotalEventsSubjectsExperienced% (n/Nii)TotalEventsSubjectsExperienced% (n/Niii)TotalEventsSubjectsExperienced% (n/N)
Overall88.3% (5/60)00.0% (0/57)00.0% (0/55)88.3% (5/60)
Closure device embolization23.3% (2/60)00.0% (0/57)00.0% (0/55)23.3% (2/60)
Dissection of brachial artery11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Pseudoaneurysm near endoAVFiv11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Pseudoaneurysm, access site11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Steal syndrome11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Thrombosis brachial artery, not leading to fistulaclosure23.3% (2/60)00.0% (0/57)00.0% (0/55)23.3% (2/60)

Table 13: NEAT Study SAEs Related to Study Procedure and/or Device (CEC-Adiudicated)

4 Based on the number of subjects still in the study at 3 Month follow-up (i.e. subjects who exited the study after 3 Month follow-up window opened) " Based on the number of subjects still in the study at 6 Month Follow-up (i.e. subjects who exited the study after 6 Month follow-up window opened) 1VThis event is also related to the study device.

A total of 28 adverse events (AEs) in 22 subjects were adjudicated as non-serious and procedure and/or device-related. Of these AEs. all were adjudicated as procedure-related (28/28) and three were adjudicated as related to both the device and the procedure (3/28). Twenty-six of the related AEs (26/28) occurred within 3 months of the index procedure. A summary of the non-serious AEs is provided in Table 14 below.

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All but two procedure-related AE occurred within 3 months post-index procedure resulting in 3month procedure-related AE rate of 33.3% (20/60) and overall rate of 36.7% (22/60) through 12 months.

0-3 Months3-6 Months> 6 MonthsOverall
EventsiTotalEventsSubjectsExperienced% (n/N)TotalEventsSubjectsExperienced% (n/N)TotalEventsSubjectsExperienced% (n/N)TotalEventsSubjectsExperienced% (n/N)
Overall2633.3% (20/60)23.5% (2/57)00.0% (0/55)2836.7% (22/60)
Bruising610.0% (6/60)00.0% (0/57)00.0% (0/55)610.0% (6/60)
Hematoma46.7% (4/60)00.0% (0/57)00.0% (0/55)46.7% (4/60)
Numbness, tingling and/or coolness in the fistulaextremity35.0% (3/60)00.0% (0/57)00.0% (0/55)35.0% (3/60)
Pain23.3% (2/60)00.0% (0/57)00.0% (0/55)23.3% (2/60)
Perforation, related to guidewire11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Pseudoaneurysm near endoAVF23.3% (2/60)00.0% (0/57)00.0% (0/55)23.3% (2/60)
Pseudoaneurysm, access site23.3% (2/60)00.0% (0/57)00.0% (0/55)23.3% (2/60)
Spasm and clot11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Steal11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Swelling, irritation or pain23.3% (2/60)11.8% (1/57)00.0% (0/55)35.0% (3/60)
Thrombosis Brachial artery, Not leading to fistulaclosure11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Thrombosis post proc of endoAVF leading tofistula closure00.0% (0/60)11.8% (1/57)00.0% (0/55)11.7% (1/60)
Thrombosis, intra-procedural leading to fistulaclosure11.7% (1/60)00.0% (0/57)00.0% (0/55)11.7% (1/60)
Table 14: NEAT Study Non-Serious Procedure-Related Adverse Events by Type and Timing
(CEC-Adjudicated)

¹As adjudicated by the Clinical Events Committee

Based on the number of subjects still in the study at 3 Month follow-up (i.e. subjects who extred the study after 3 Month follow-up window opened)

" Based on the number of subjects still in the study at 6 Month Follow-up (i.e. subjects who exited the study after 6 Month follow-up window opened)

Summary of Occlusions and Thromboses

Table 15 below provides a summary of the number of thromboses and occlusions that occurred during the study. The data are presented as acute (defined as 0-42 days to represent the data reported through the 6-week visit) and total events reported through the end of the study's 12month visit. There was 1 acute thrombosis of the endoAVF treated unsuccessfully with thrombolysis, and the endoAVF was eventually abandoned. There were 4 additional (non-acute) thromboses of the endoAVF all leading to endoAVF abandonment. In total, 5/60 (8.3%) subjects experienced thrombosis of the endoAVF at some point during the study. 3/60 (5.0%) subjects experienced thrombosis of the brachial artery during the study. All 3 of these events were acute and were treated (1 thrombolysis, 2 thrombectomy) and did not lead to endoAVF abandonment. 1/60 (1.7%) subjects experienced occlusion of the endoAVF during the study. This event was non-acute and led to endoAVF abandonment. There were no occlusions of the brachial artery during the study.

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All 4 acute thrombosis events listed in Table 15 (1 endoAVF thrombosis and 3 brachial artery thromboses) occurred at the time of the endoAVF index procedure and all were treated via thrombolysis or thrombectomy.

The events were either treated with thrombectomy/thrombolysis or no treatment was provided. 6/9 of the endoAVFs that experienced an occlusion or thrombosis were abandoned, for a total endoAVF abandonment rate of 10.0% at 12 months.

AcuteTotalTreatment(s)Outcome(s)
NAbandonedNAbandoned
Thrombosis - endoAVF1/60(1.7%)1/15/60(8.3%)5/51 Thrombolysis4 No Treatment2/5 subjects entered studypre-dialysis and exited studypre-dialysis3/5 subjects entered study on-dialysis and exited study onCVC
Thrombosis - Brachial Artery*3/60(5.0%)0/33/60(5.0%)0/32 Thrombectomy1 Thrombolysis2/3 subjects entered studypre-dialysis and 1 subjectexited study on CVC and 1subject exited study early pre-dialysis1/3 subjects entered study on-dialysis and exited study onendoAVF and achievedfunctional cannulationsuccess
Occlusion - endoAVF0/60(0.0%)-1/60(1.7%)1/11 No Treatment1/1 subject entered study pre-dialysis and exited study earlypre-dialysis
Occlusion - Brachial Artery0/60(0.0%)-0/60(0.0%)---
Total - endoAVF1/60(1.7%)1/16/60(10.0%)6/6--
Total - All4/60(6.7%)1/49/60(15.0%)6/9
* - The brachial artery thrombosis events occurred during the index procedure.

Table 15: NEAT Study Thromboses and Occlusions

Rate of Device and/or Procedure-Related Infections

There were no device- or-procedure related infections observed in the study. There were two subjects (2/60 = 3.3%) who experienced an infection related to a CVC.

Arterial Flow Rates and Vein Diameters

Table 16 below shows the arterial flow rates through the brachial artery as measured by DUS, expressed as mL/min. The highest mean arterial flow rate was observed at 6 weeks (928.17 mL/min). Figure 4 shows the average brachial artery flow rates over time. Table 17 shows the inner diameters by vessel and study visit, expressed in millimeters (mm).

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Study visitFlow Rate (peak)Flow Rate (mean)
Baseline123.40 ± 100.45 (57)102.10 [8.20,620.00]81.48 ± 61.67 (56)58.60 [8.29,300.00]
1-7 Days1188.04 ± 768.76 (57)1105.00 [14.35,4029.50]P-value: <.0001785.38 ± 474.35 (59)743.50 [7.46,2259.50]P-value: <.0001
1 Month1358.03 ± 753.33 (55)1290.00 [25.00,3026.00]P-value: <.0001881.25 ± 507.74 (54)838.00 [25.00,2713.50]P-value: <.0001
6 Weeks1391.72 ± 1017.27 (9)923.00 [563.00,3770.00]P-value: 0.0060928.17 ± 519.75 (9)822.50 [330.50,2081.00]P-value: 0.0017
3 Months1521.06 ± 875.51 (48)1328.50 [22.00,4408.50]P-value: <.0001917.57 ± 657.02 (48)827.50 [23.00,4148.00]P-value: <.0001
6 Months1540.45 ± 1075.16 (47)1229.50 [260.00,5571.00]P-value: <.0001893.19 ± 634.68 (47)754.50 [132.00,3695.00]P-value: <.0001
12 Months1480.35 ± 883.58 (31)1289.00 [178.00,3369.00]P-value: <.0001851.39 ± 521.69 (32)837.50 [80.65,2807.50]P-value: <.0001
Data summarized as Mean±SD (N); Median [Range]; P-value for change from baseline

Table 16: Brachial Artery (Medial) Flow Rates by Study Visit

Image /page/21/Figure/2 description: The image is a line graph showing flow in ml/min on the y-axis and months after endoAVF creation on the x-axis. The flow starts at approximately 80 ml/min at month 0, then increases to approximately 880 ml/min at month 1. The flow peaks at approximately 920 ml/min at month 3, then decreases to approximately 850 ml/min at month 12.

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Figure 4: Average Brachial Artery Flow Rate by Month

VesselBaseline1-7 Days1 Month6 Weeks3 Months6 Months12 Months
Median cubitalvein at elbow4.19 ± 1.48 (60)3.90 [1.20,8.50]5.20 ± 1.54 (57)5.00 [2.90,9.30]P-value: <.00015.25 ± 1.89 (54)4.85 [1.60,10.60]P-value: 0.00015.11 ± 1.61 (9)5.80 [2.40,7.00]P-value: 0.28275.89 ± 1.94 (48)5.90 [2.20,12.60]P-value: <.00016.09 ± 1.89 (47)6.00 [2.80,12.90]P-value: <.00016.93 ± 2.47 (32)6.10 [4.00,15.20]P-value: <.0001
Cephalic vein at2" proximal ofelbow3.34 ± 1.18 (53)3.20 [1.20,6.10]4.31 ± 1.15 (52)4.40 [1.30,6.50]P-value: <.00014.80 ± 1.43 (47)5.10 [1.60,8.30]P-value: <.00015.47 ± 1.38 (7)5.20 [4.00,8.10]P-value: 0.06524.92 ± 1.51 (40)5.10 [1.70,7.80]P-value: <.00015.26 ± 1.59 (41)5.30 [2.10,8.60]P-value: <.00015.57 ± 1.98 (27)5.40 [1.40,9.30]P-value: <.0001
Cephalic vein at2" distal of elbow3.53 ± 1.35 (57)3.40 [1.20,6.70]4.44 ± 1.34 (56)4.60 [1.40,6.70]P-value: <.00014.98 ± 1.69 (50)5.20 [1.30,9.20]P-value: <.00015.47 ± 1.83 (9)5.30 [1.60,7.70]P-value: 0.00445.13 ± 1.57 (44)5.25 [1.60,9.30]P-value: <.00015.74 ± 1.62 (43)5.70 [2.90,9.60]P-value: <.00016.15 ± 2.54 (31)6.10 [1.60,11.60]P-value: <.0001
Cephalic vein(mid)3.15 ± 1.10 (56)3.00 [1.10,5.60]4.30 ± 1.18 (54)4.40 [1.30,7.00]P-value: <.00014.90 ± 1.47 (49)5.20 [2.40,8.80]P-value: <.00015.51 ± 1.14 (8)5.30 [3.80,7.00]P-value: 0.00055.15 ± 1.63 (42)5.50 [2.00,9.10]P-value: <.00015.41 ± 1.57 (44)5.45 [2.50,8.60]P-value: <.00016.12 ± 2.58 (30)5.70 [1.90,10.60]P-value: <.0001
Basilic vein(medial)4.17 ± 1.40 (60)4.00 [1.60,8.00]5.37 ± 1.32 (59)5.40 [2.20,8.90]P-value: <.00015.86 ± 1.48 (54)5.80 [2.20,9.00]P-value: <.00016.31 ± 1.57 (9)6.00 [3.90,8.30]P-value: 0.00365.99 ± 1.57 (47)5.90 [3.10,10.50]P-value: <.00015.84 ± 1.50 (47)6.00 [3.10,9.60]P-value: <.00016.29 ± 1.41 (32)6.55 [3.60,8.80]P-value: <.0001
Data summarized as Mean=SD (N); Median [Range]; P-value for change from baseline

Table 17: Vessel Inner Diameters by Study Visit

Dialysis Using 2-Needle Cannulation

The following analyses are based on 52 subjects with a usable endoAVF (30 pre-dialysis subjects and 22 on dialysis subjects) at the end of the NEAT Study. A "usable" endoAVF was defined as an endoAVF that met the primary effectiveness endpoint success criteria. In total, 31/60 (52%) of the NEAT Study subjects initiated 2-needle dialysis with the endoAVF during the study.

Two-Needle Dialysis Analysis of Pre-Dialysis Subjects:

There were 30 subjects who entered the study as pre-dialysis subjects and had a usable endoAVF at the end of the study (per primary endpoint definition):

  • 16/30 (53.3%) subjects needed dialysis during the course of the study: .
    • 14/16 successfully utilized 2-needle dialysis:
      • 12/14 subjects met the criteria for functional fistula cannulation success 트 defined as "cannulating their endoAVF at 2/3 of their dialysis sessions over a continuous 4 week period with 2-needle cannulation."
      • 1 subject's endoAVF was successfully created and determined to be mature. ■ However, due to the subject's fear of needles, self-cannulation was continued via CVC.
      • . 1 subject had 2 successful cannulations of endoAVF but expired shortly thereafter due to causes unrelated to the study; and therefore, did not have an opportunity to complete a 4-week functional cannulation study requirement.
    • 1/16 had their endoAVF abandoned prior to the need for dialysis due to steal o syndrome leading to fistula ligation.

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  • 1/16 subject was not able to initiate dialysis with endoAVF despite having a mature o fistula 28 days post index procedure since the veins were too deep. Instead of undergoing vein superficialization a permanent CVC was placed. The subject was exited from the study without completing 12 months follow-up. Note this subject was utilizing peritoneal dialysis prior to entering into the study and was exited from the study since the subject went back to peritoneal dialysis.
  • . 14/30 (46.7%) subjects exited the study without the need for dialysis and therefore, endoAVF cannulation.

Two-Needle Dialysis Analysis of On-Dialysis Subjects:

There were 22 subjects who entered the study on dialysis and had a usable endoAVF at the end of the study (per primary endpoint definition):

  • 21/22 on dialysis subjects needed dialysis during the course of the study:
    • o 17/21 subjects successfully initiated 2-needle cannulation:
      • 8 subjects started 2-needle cannulation during month 3 post index procedure; ■
      • . 5 subjects started 2-needle cannulation during month 4 post index procedure;
      • . 3 subjects started 2-needle cannulation during month 6 post index procedure (all three subjects received vein superficialization/transposition):
      • . 1 subject started 2-needle cannulation during month 7 post index procedure. This subject had 1-needle cannulation of the endoAVF beginning during month 4 post index procedure.
      • o 2/21 subjects had fistula abandoned prior to cannulation start
  • 2/21 subjects started cannulation of endoAVF with one needle in endoAVF and one needle ● CVC1/22 subjects received a kidney transplant on the 2nd week post index procedure

Out of 17 on-dialysis subjects who initiated dialysis utilizing 2-needle cannulation:

  • 1/17 subject moved away (to a rural location) shortly after the endoAVF index procedure and ● started receiving healthcare through a non-study health authority. Subject came back to the study site for a 3-month follow up visit during which successful 2-needle cannulation via endoAVF was conducted.
  • . 16/17 subjects met the functional cannulation criteria.

Supportive Clinical Data Set: Global Analysis

Objective: The objective of the Global Analysis is to report and analyze data from multiple clinical studies and the commercial experience of the everlinQ® endoAVF system, individually by study and in the aggregate with pooled data. Aggregate effectiveness data is presented for all subjects; aggregate safety data is presented for the 6Fr cases alone. The Global Analysis was intended to supplement the NEAT Study data, including data to support a training program and labeling modifications.

Design:

Prospective Study Data

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The FLEX, NEAT, EU PMCF and EASE studies were each prospectively planned and executed single-arm studies. Each study obtained the required institutional ethics approvals and all subjects provided informed consent prior to treatment. Data were collected via Case Report Forms and were independently monitored. Inclusion criteria required subjects to need vascular access for long-term hemodialysis with target vein diameter ≥ 2 mm, target artery diameter ≥ 2 mm, and < 2 mm between target artery and vein. Relevant safety events were submitted for independent CEC adjudication. All procedural and post-procedural adverse events ("AEs") and secondary procedures were collected. Procedure success and patency effectiveness data were collected during the follow-up period: 6-month follow-up for FLEX and EASE and 12-month follow-up for NEAT and EU-PMCF.

Commercial Data

The Commercial data source was collected and reported by treating physicians from open-label commercial use of the 6Fr everlinQ® endoAVF System. The physician-reported data utilized a form generated by TVA based on the guidance of in-country regulatory counsel to specifically conform to applicable privacy regulations. The form was designed to specifically exclude any information that could be deemed to be personal data. AEs were submitted for CEC adjudication.

Patient Populations: A total of 236 subjects were available for analysis through the August 2017 cutoff date. Among these, 157 (66.5%) were in the four clinical studies and 79 (33.5%) were from the COMM study population.

Image /page/24/Figure/4 description: The image shows a diagram of different populations and their relationships. The diagram includes five initial populations: NEAT (N=60), FLEX (N=33), EU-PMCF (N=32), EASE (N=32), and COMM (N=79). These populations are then connected to three analysis populations: Pooled Safety Analysis Population (N=125), Pooled Effectiveness Analysis Population (N=157), and Non-Pooled Population (N=111), with lines indicating the flow of data for effectiveness and safety.

Figure 5: Safety and Effectiveness Data Available by Data Source

Analysis Endpoints:

Safety Endpoints

The safety endpoints are defined as the proportion of subjects with the following:

    1. Serious adverse events (SAEs)
    • . SAEs defined as adverse events that a. led to death,

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  • b. led to serious deterioration in the health of the subject, that either resulted in 1) a life threatening injury, or 2) a permanent impairment of a body structure or a body function, or 3) in-patient or prolonged hospitalization, or 4) medical or surgical intervention to prevent lifethreatening illness or injury or permanent impairment to a body structure or a body function, or
  • c. led to foetal distress, foetal death or a congenital abnormality or birth defect
    1. Significant events
    • Significant Events included device or procedure-related adverse events that either . could be limb-threatening if not promptly identified or treated, or required additional therapy to reestablish patency of the endoAVF) access circuit. irrespective of whether they met the criteria for an SAE.
    1. Device-related SAEs
    1. Procedure-related SAEs
    1. Brachial closure device-related SAEs
    1. Embolization coil-related SAEs

Effectiveness Endpoints

The effectiveness endpoints of the Global Analysis were the following:

    1. Procedure Success: The proportion of subjects who achieved successful endoAVF creation as confirmed by intraprocedural angiography/fistulogram or duplex ultrasound verification performed post-procedure. This definition corresponds to the term "Technical Success" commonly used in other studies.
    1. Time to Cannulation: The interval of time from the index procedure to successful 2needle cannulation of the endoAVF.
  • Cannulation Success: The proportion of subjects who achieved a successful cannulation 3. of the endoAVF with 2-needles for dialysis. A subject may be called a 'cannulation success' with the first successful 2-needle cannulation of the endoAVF.
    1. Primary Patency: The interval from the time of access placement until any intervention designed to maintain or reestablish patency, access thrombosis, access abandonment, or the time of measurement of patency (Society for Vascular Surgery Reporting Standards definition).
    1. Modified Primary Patency: Identical to Primary Patency except that loss was also triggered by reinterventions not directly related to the access circuit; namely coiling or vessel ligation of venous outflow tributaries to encourage flow into the superficial, more easily accessible veins of the upper arm.
  • Assisted Primary Patency: The interval from access placement to thrombosis or 6. abandonment; not triggered by access circuit interventions performed in the absence of occlusion.
    1. Secondary Patency: The interval from the time of access placement until access abandonment, lost to thrombosis, or the time of patency measurement including intervening manipulations (surgical or endovascular interventions) designed to reestablish functionality in thrombosed access (SVS Reporting Standards definition).

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    1. Functional Patency: The interval of time from the first 2-needle dialysis utilizing the access until access abandonment (SVS Reporting Standards definition).
    1. Functional Cannulation: Successful 2-needle access of the endoAVF access circuit with performance of more than 2/3rds of dialysis sessions of at least 120 minutes in duration over a continuous 28-day period. This measure was defined to more aptly measure whether an endoAVF resulted in a working access site for a subject, and is more pertinent to a subject, as opposed to Successful Cannulation, which is limited to completing a single successful 2-needle cannulation.

Eligibility Criteria Summary: The table below shows all of the criteria that were used to enroll subjects in the clinical studies. The "yes/no" answers indicate whether each criterion was evaluated for subject eligibility for the study in question. In eligibility criteria for the studies were similar among the data sources. Inclusion criteria required subjects to need vascular access for long-term hemodialysis with target vein diameter ≥ 2 mm, target artery diameter ≥ 2 mm, and ≤ 2 mm between target artery and vein.

FLEXNEATEU-PMCFEASE
GeographyPYCA, AUDE, GBPY
Size of System6Fr6Fr6Fr4Fr
Inclusion Criteria
Eligible for AVFYesYesYesYes
AgeYesYesYesYes
Kidney failureYesYesYesYes
Target AVF distanceYesYesNoNo
Target vein diameterYesYesYesYes
Target artery diameterYesYesYesYes
Life ExpectancyYesYesYesYes
Exclusion Criteria
Informed Consent RequiredYesYesYesYes
Significant baseline conditionsYesYesYesYes
Central vein stenosis > 50%YesYesYesYes
Hypercoagulable stateYesYesYesYes
Planned/prior procedure < 30 daysYesYesYesYes
Target vessel abnormalityYesYesYesYes
PregnancyYesYesYesYes
Known bleeding diathesisYesYesYesYes
ImmunosuppressionYesYesYesYes
Documented history of drug abuseYesYesYesYes
Body mass indexYesYesNoNo
Contrast/Sedation/AnesthesiaNoYesYesYes
PY- Paraguay, CA- Canada, AU- Australia, DE- Germany, GB- United Kingdom,
AVF- Arteriovenous fistula

Table 18: Comparison of Eligibility Criteria Across Data Sources

Data Quality Characteristics: Adverse events were assessed by an Independent Medical Monitor and an Independent Clinical Events Committee (CEC). Each event was classified with respect to:

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    1. Relationship to the study device
    1. Relationship to the procedure
    1. Relationship to coil embolization, if used
    1. Relationship to a brachial artery closure device, if used
    1. Whether the event was an Unanticipated Adverse Device Effect
    1. Whether the event met the definition of a Significant Event

The determination of a Significant Event was made by the Medical Monitor as follows:

  1. Yes, event was related to the study device or index procedure and could be limb-threatening if not promptly identified or treated

  2. Yes, event was related to the study device or index procedure and additional therapy was required to re-establish an occluded AV access

  3. No, neither of the above.

All procedural safety data and relevant post-procedure events were adjudicated by an independent CEC. The CEC Charter describes the event definitions, the adjudication process, and the CEC output data. The CEC consisted of three independent physicians with expertise in vascular surgery, interventional nephrology, and/or interventional radiology.

Study Quality Characteristics are shown in the table below:

FLEXNEATEU-PMCFEASE
GeographiesPYCA, AUDE, GBPY
Size of System6Fr6Fr6Fr4Fr
Adverse Event Source CollectionYesYesYesYes
Statistical Analysis PlanNoYesYesNo
Monitoring PlanYesYesYesYes
Interim MonitoringYesYesYesYes
Data Management PlanNoYesYesYes
Database Validation Plan/ReportNoYesYesNo
Data - Review for Completeness/AccuracyYesYesYesYes
Data - Query Generation/ResolutionYesYesYesYes
Core Lab (Duplex Ultrasound)NoYesYesNo
Clinical Event CommitteeYesYesYesYes
Data Safety Monitoring BoardNoYesNoNo
PY- Paraguay, CA- Canada, AU- Australia, DE- Germany, GB- United Kingdom

Table 19: Comparison of Quality Characteristics Across Studies

Accountability: The protocol-specified follow-up duration was 12 months in the NEAT and EU-PMCF studies and 6 months in FLEX and EASE. Subjects were withdrawn when they exited a study due to abandonment of the endoAVF, successful renal transplantation, or if the subject withdrew consent voluntarily.

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Of the 123 eligible subjects in the Pooled population 109 (88.6%) completed the 6 month followup visit. Of the 53 eligible subjects with pre-planned 12 month visits, 49 (92.5%) completed the 12 month visit.

Table 20: Study Accountability

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Follow-Up Interval1NEAT(N=60)FLEX(N=33)EU-PMCF4(N=32)EASE(N=32)Pooled2(N=157)
Follow-Up Duration12 Months6 Months12 Months6 MonthsNA
Postoperative (0-10 Days):
Eligible Subjects60/60 (100.0%)33/33 (100.0%)32/32 (100.0%)32/32 (100.0%)157/157(100.0%)
Death30/60 (0.0%)1/33 (3.0%)0/32 (0.0%)0/32 (0.0%)1/157 (0.6%)
Withdrawal31/60 (1.7%)0/33 (0.0%)5/32 (15.6%)1/32 (3.1%)7/157 (4.5%)
Visit Within Interval58/60 (96.7%)32/33 (97.0%)25/32 (78.1%)31/32 (96.9%)146/157 (93.0%)
30-Days (11 - 45 Days)
Eligible Subjects59/60 (98.3%)32/33 (97.0%)26/32 (81.3%)31/32 (96.9%)148/157 (94.3%)
Death31/59 (1.7%)2/32 (6.3%)0/26 (0.0%)1/31 (3.2%)4/148 (2.5%)
Withdrawal30/59 (0.0%)0/32 (0.0%)2/26 (7.7%)2/31 (6.5%)4/148 (2.5%)
Visit Within Interval57/59 (96.6%)30/32 (93.8%)22/26 (84.6%)24/31 (77.4%)133/148 (84.7%)
3-Months (46 - 135 Days)
Eligible Subjects58/60 (96.7%)30/33 (90.9%)24/32 (75.0%)26/32 (81.3%)138/157 (87.9%)
Death31/58 (1.7%)1/30 (3.3%)3/24 (12.5%)3/26 (11.5%)8/138 (5.8%)
Withdrawal32/58 (3.4%)0/30 (0.0%)3/24 (12.5%)2/26 (7.7%)7/138 (5.1%)
Visit Within Interval55/58 (94.8%)28/30 (93.3%)18/24 (75.0%)13/26 (50.0%)114/138 (82.6%)
6-Months (136 - 270 Days)
Eligible Subjects55/60 (91.7%)28/33 (84.8%)18/32 (56.3%)22/32 (68.8%)123/157 (78.3%)
Death30/55 (0.0%)0/28 (0.0%)0/18 (0.0%)1/22 (4.5%)1/123 (0.8%)
Withdrawal32/55 (3.6%)0/28 (0.0%)0/18 (0.0%)0/22 (0.0%)2/123 (1.6%)
Visit Within Interval53/55 (96.4%)23/28 (82.1%)11/18 (61.1%)22/22 (100.0%)109/123 (88.6%)
12-Months (271 - 390 Days)
Eligible Subjects53/60 (88.3%)NANA6NA53/60 (88.3%)
Death31/53 (1.9%)NANANA1/53 (1.9%)
Withdrawal33/53 (5.7%)NANANA3/53 (5.7%)
Visit Within Interval49/53 (92.5%)NANANA49/53 (92.5%)
1-The Follow-Up Intervals in this table are constructed to be contiguous and standardized between the studiesevaluated. They do not correspond to prespecified windows in each of the individual study protocols (follow-upwindows were specified in the NEAT study protocol alone), nor do they correspond to the windows used tostandardize follow-up for the Global Analysis.
2-Pooled studies include all data sources except COMM (commercial cases).

3-Withdrawn subjects include those subjects who exited the study due to lack of procedure success, endo.VF abandoned, transplant, or withdrew consent.

4-NEAT, FLEX, and EASE are completed studies. EU-PMCF is ongoing, with active enrollment and follow-up.

5- No EU-PMCF subjects had 12-month interval (beginning at day 271) data reported at the time of the data snap.

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Demographics: Demographics for the Pooled population and each individual study population is provided in the table below. Males (65%) were more common than females (35%). The mean age was 57 in the pooled data set. There was a predominance of Caucasian subjects in the European/Canadian studies (NEAT and EU-PMCF). The FLEX and EASE studies were uniformly comprised of subjects of Hispanic ethnicity because the studies were conducted in Paraguay. A small number of Asian and Indian subjects were enrolled. No Black subjects were enrolled in any of the studies. No demographic data or baseline characteristics were collected for the commercial cases.

CharacteristicNEAT(N=60)FLEX(N=33)EU-PMCF(N=32)EASE(N=32)Pooled(N=157)COMM(N=79)
Gender:
Male39/60(65.0%)20/33 (60.6%)21/32 (65.6%)31/32 (96.9%)111/157(70.7%)NA
Female21/60(35.0%)13/33 (39.4%)11/32 (34.4%)1/32 (3.1%)46/157(29.3%)NA
Age:
Mean ± SD59.9 ± 13.651.0 ± 11.463.5 ± 12.750.9 ± 12.957.0 ± 13.8NA
Race:
Caucasian36/60(60.0%)NA27/32 (84.4%)0/32 (0.0%)63/124(50.8%)NA
Black0/60 (0.0%)NA0/32 (0.0%)0/32 (0.0%)0/124 (0.0%)NA
Asian4/60 (6.7%)NA4/32 (12.5%)0/32 (0.0%)8/124 (6.5%)NA
Indian15/60(25.0%)NA1/32 (3.1%)NA16/124(12.9%)NA
Ethnicity:
NotHispanic/Latino58/60(96.7%)0/33 (0.0%)32/32(100.0%)0/32 (0.0%)90/157(57.3%)NA
Hispanic orLatino2/60 (1.7%)33/33(100.0%)0/32 (0.0%)32/32(100.0%)67/157(42.7%)NA
Height (cm):
Mean ± SD169.5 ± 11.7165.0 ± 8.3165.8 ± 10.6170.4 ± 9.6168.0 ± 10.6NA
Weight (kg):
Mean ± SD80.9 ± 21.965.8 ± 10.381.7 ± 18.575.6 ± 13.076.8 ± 18.5NA
BMI:
Mean ± SD27.9 ± 6.124.2 ± 3.929.8 ± 6.825.9 ± 3.127.1 ± 5.7NA
Systolic BP:
Mean ± SD144.5 ± 22.5NA137.7 ± 20.3163.5 ± 26.0149.7 ± 25.9NA
Table 21: Summary of Study Demographics
-----------------------------------------------

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Diastolic BP:
Mean ± SD83.4 ± 12.5NA72.5 ± 9.299.8 ± 18.885.8 ± 19.083.4 ± 12.5
Target Vein Diameter (mm):
Mean ± SD2.5 ± 0.5NA3.1±0.82.7±0.82.7±0.7NA
Target Artery Diameter (mm):
Mean ± SD3.8 ± 0.8NA3.7±0.63.0±0.73.6±0.8NA
The denominator for each data point varies due to exclusion of subjects with missing data.NA means data not collected

Results:

Procedural Characteristics

The endoAVF was created on the right side in one-third of subjects and on the left side in twothirds of subjects. The target vein diameter as determined by pre-procedure duplex ultrasonography averaged 2.7 ± 0.7 mm. The target artery diameter, also determined on the preprocedure duplex ultrasound, averaged 3.6 ± 0.8 mm.

The endoAVF was created between the ulnar artery and vein in all studies except EASE. where radio-radial endoAVF were created in 62.5% of the subjects and ulnar-ulnar endoAVFs were performed in the remaining 37.5%. The site of arterial access was, by and large, dictated by the size of the system. The 6Fr systems used in all studies except EASE mandated brachial artery and brachial vein access. The 4Fr system used in EASE facilitated access from the radial (59.4%) and ulnar (12.5%) arteries in addition to the brachial artery (28.1%). Venous access was brachial for all subjects except those in EASE. Closure of the arterial access site was with manual compression in 63.7% of subjects, while a brachial access closure device was used in 36.3% of the pooled population.

Adjunctive Procedures

Adjunctive procedures performed at the index procedure included planned coiling of outflow veins and the use of a brachial closure device. Unplanned procedures included balloon angioplasty or stenting of stenotic vessels. The frequency of these procedures appears in Table 22 below.

The most common adjunctive procedure was therapeutic coil embolization which occurred during the index procedure in 123/157 (78.3%) of the Pooled Effectiveness Population.

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Adjunctive ProceduresNEATFLEXEU-PMCFEASEPooled StudiesCOMM
Therapeutic Embolization5617271911959
Closure Device41NA224511
PTA000000
Stent000000
Other*612091
Subjects with ≥1 Procedure58/60 (96.7%)18/33 (54.5%)27/32 (84.4%)20/32 (62.5%)123/157 (78.3%)60/79 (75.9%)
The Pooled Studies in this table include the NEAT, FLEX, EU-PMCF, and EASE studies.
Adjunctive procedures are tabulated by the procedure (i.e. one subject may have more than one adjunctive procedure), except for thelast row which tabulated the data at the subject level.
*Other procedures include thrombolysis (1) thrombectomy (2), new surgical AVF (1), open surgical repair for an intraoperativecomplication (6)

Table 22: Adjunctive Procedures at the Time of Index Procedure

Independent Medical Monitor classified data.

Safety Endpoints

The Global Analysis of the everlinQ® System data is summarized in Table 23 below. For each outcome, the data represents the number of subjects experiencing an event divided by the number of subjects in the study. The Pooled Safety Population included subjects treated in the FLEX, EU-PMCF and NEAT studies (6Fr system) (N=125), but did not include subjects in the EASE study (4Fr system) or in the Commercial (COMM) cohort. All safety events were adjudicated by the CEC.

Table 23 below provides safety outcomes for the pooled 6Fr data (FLEX, EU-PMCF, NEAT) and 4Fr data (EASE). In the Pooled Safety population 15/125 (12.0%) subjects reported an unrelated SAE as adjudicated by the CEC. In total, 15/125 (12.0%) subjects reported an SAE that was related to the device and/or procedure. 4/125 (3.2%) subjects reported a device-related SAE, and 15/125 (12.0%) reported a procedure-related SAE.

Closure device-related SAEs occurred in 4.8% of the population (6/125). There were no coilrelated SAEs (0/125). There were 8 deaths included as SAEs in the Pooled Safety Population and all were unrelated to the study procedure or device (6.4%, 8/125). Commercial data from outside the US did not indicate any new or different types of risks.

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NEATFLEXEU-PMCFEASEPooled*COMM
(N=60)(N=33)(N=32)(N=32)(Safety=125)(N=79)
Safety Endpoints
SAE-unrelated9/60(15.0%)4/33(12.1%)1/32(3.1%)6/32(18.7%)15/125(12.0%)0/79 (0%)
SAE-related5/60(8.3%)4/33(12.1%)6/32(18.7%)1/32(3.1%)15/125(12.0%)3/79 (3.8%)
Device-Related SAE1/60(1.7%)1/33(3.0%)2/32(6.3%)0/32(0.0%)4/125(3.2%)1/79(1.3%)
Procedure-Related SAE5/60(8.3%)4/33(12.1%)6/32(18.8%)1/32(3.1%)15/125(12.0%)3/79(3.8%)
Closure Device-RelatedSAE4/60(6.7%)0/33(0.0%)2/32(6.3%)0/32(0.0%)6/125(4.8%)0/79(0.0%)
Coil-Related SAE0/60(0.0%)0/33(0.0%)0/32(0.0%)0/32(0.0%)0/125(0.0%)0/79(0.0%)

Table 23: Safety Endpoint Results - Global Analysis

This summary table is intended to provide standalone results for the most important safety study endpoints.

The Pooled Safety Population includes NEAT, FLEX, and EU-PMCF.

The 6- and 12-month windows are defined as 180 and 360 days, respectively. The data in this table revesent events through the end of the respective windows: i.e. 210 days for 6 months and 390 days for 12 months

The safety endpoints are tabulated on a per-subject basis and represent the number of subjects who experienced at least one event of the specified category of

SAE - Serious Adverse Event as adjudicated by the CEC, reported at any time duri

NA- Not avolicable. Indicates that the data point is beyond the length of follow-up for a study or that the number of evaluable subjects is zero at that time t

Significant Events included device or procedure-related adverse events that either a) could be limb-threatening if not promptly identified or treated, or b) reauir dditional therany to reestablish patency of the endoAVF access circuit. irrespective of whether they met the

Data is site-reported, with independent Medical Monitor classifications and CEC-adjudicated data

*For all safety endpoints, pooled studies include NEAT, FLEX, and reflect all data from each study.

The 6- and 12-month timepoints were calculated at the end of the follow-up windows, through 210 and 390 days, respectively.

Safety Events After Training

After completion of the NEAT Study, a training program was implemented to instruct physicians on the proper use of the device, recommended techniques, potential complications, and other information. The training includes diagrams, videos, training models, and proctored cases. The training also includes instruction on how to achieve hemostasis at the brachial artery access site using manual compression instead of using vascular closure devices.

Among the 20 subjects evaluated in the EU-PMCF study and commercial cases after implementation of the training program, all subjects achieved hemostasis after the procedure with manual compression of the brachial artery access site, and no subjects experienced serious adverse events as shown in Table 24 below. Although this demonstrates a numerical reduction in

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the rate of serious adverse events. the data was collected in a limited number of subjects and no conclusions can be drawn regarding whether or not this is a statistically significant difference.

Training StatusStatisticsNEAT(N=60)FLEX(N=33)EU-PMCF(N=32)COMM(N=78) *
Procedural (<72 hours)
Pre-Trainingn/N (%)5/60 (8.3%)2/33 (6.1%)5/21(23.8%)3/69(4.4%)
Post-Trainingn/N (%)NANA0/11 (0.0%)0/9 (0.0%)
Procedural (>72 hours, <- 30 days)
Pre-Trainingn/N (%)2/60 (3.3%)2/33 (6.06%)2/21 (9.52%)0/69 (0.0%)
Post-Trainingn/N (%)NANA0/11 (0.0%)0/9 (0.0%)
Follow-Up (>30 days)
Pre-Trainingn/N (%)10/60 (16.6%)4/33(12.1%)1/21(4.8%)0/69 (0.0%)
Post-Trainingn/N (%)NANA0/11 (0.0%)0/9 (0.0%)
Any Timepoint
Pre-Trainingn/N (%)15/60 (25.0%)8/33(24.24%)7/21(33.3%)3/69 (4.4%)
Post-Trainingn/N (%)NANA0/11 (0.0%)0/9 (0.0%)
* Procedure date unavailable for 1 COMM subjectCEC-adjudicated data

Table 24: SAEs by Training Status (CEC-Adjudicated)

Effectiveness Endpoints

A summary of the Effectiveness outcomes is tabulated in the main summary table (Table 25) below. The Pooled Effectiveness Population comprised subjects treated as part of the FLEX. EU-PMCF, NEAT, and EASE studies (N=157). Subjects treated commercially were not included in this population.

Procedural success, defined as the successful creation of an endoAVF with blood flow confirmed intraoperatively by fistulography or by duplex ultrasound postoperatively, was achieved in 96.8% (152/157) of the Pooled Effectiveness Population Success (2-needle access and hemodialysis through the fistula) was achieved in 82.4% of subjects through the 6 month window and in 92.4% of subjects through the 12 month window after the index procedure.

The median time to successful cannulation was 2.1 months after a subject went on dialysis (or after the index procedure in those that were on dialysis at enrollment). The Kaplan-Meier estimate for Functional Cannulation (All Subjects), defined in the table below, was 42.4% at 6 months and 58.9% at 12 months. For patients already on dialysis at the time of enrollment, Functional Cannulation was 56.1% and 78.4% at 6 and 12 months, respectively. The reported Kaplan-Meier estimate of Primary Patency was 82.7% and 74.8% at 6 and 12 months, respectively. Similar results were observed in the commercial cases, where the corresponding data was available.

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NEAT(N=60)FLEX(N=33)EU-PMCF(N=32)EASE(N=32)Pooled*(Effectiveness=157)COMM(N=45)
Effectiveness Endpoints:
Procedural Success59/60(98.3%)32/33(97.0%)29/32(90.6%)32/32(100.0%)152/157(96.8%)44/45(97.8%)
Time to Cannulation (Months)
Observations312511218818
Median [IQR]3.1 [2.7,5.6]2.1 [1.9,2.4]2.4 [1.4,3.4]1.3 [1.1,1.6]2.1 [1.6,3.2]1.7 [0.4,2.9]
Mean ± SD4.1 ± 2.32.2 ± 0.83.0 ± 1.91.4 ± 0.52.8 ± 1.92.3 ± 2.3
(Min, Max)(1.4, 10.7)(1.1, 4.6)(1.2, 7.2)(1.0, 3.0)(1.0, 10.7)(0.3, 7.8)
CannulationSuccess, 6-Month70.6%(±7.4%)100.0%(±0.0%)71.2%(±13.3%)90.4%(±6.4%)82.4%(±4.0%)94.3%(±5.5%)
CannulationSuccess, 12-Month86.1%(±6.6%)NA100.0%(±0.0%)NA92.4%(±3.6%)100.0%(±0.0%)
FunctionalCannulation, 6-Month36.3%(±6.7%)88.6%(±7.0%)63.2%(±13.6%)85.8%(±7.5%)42.4%(±6.1%)NA
FunctionalCannulation, 12-Month53.1%(±7.4%)NA100.0%(±0.0%)NA58.9%(±6.6%)NA
FunctionalCannulation,Dialysis Subset, 6-Month†50.4%(±8.2%)94.5%(±5.1%)71.1%(±13.3%)85.8%(±7.5%)56.1%(±7.1%)NA
FunctionalCannulation,Dialysis Subset, 12-Month†74.2%(±7.0%)NANANA78.4%(±6.7%)NA
Primary Patency, 6-Month81.1%(±5.1%)96.4%(±3.5%)78.9%(±7.7%)83.3%(±6.8%)82.7%(±3.5%)71.3%(±7.4%)
Primary Patency.12-Month73.4%(±5.9%)N/A78.9%(±7.7%)N/A74.8%(±4.9%)63.5%(±8.4%)
Mod PrimaryPatency, 6-Month76.5%(±5.5%)53.6%(±9.4%)68.4%(±8.8%)83.3%(±6.8%)70.5%(±4.0%)71.3%(±7.4%)
Mod PrimaryPatency, 12-Month61.1%(±8.1%)N/A68.4%(±8.8%)N/A56.3%(±7.1%)63.5%(±8.4%)
Assist Prim Patency,6-Month84.8%(±4.7%)96.4%(±3.5%)82.1%(±7.3%)86.8%(±6.2%)85.8%(±3.2%)71.3%(±7.4%)
Assist Prim Patency,12-Month77.2%(±5.6%)N/A82.1%(±7.3%)N/A78.2%(±4.7%)63.5%(±8.4%)
Secondary Patency.6-Month86.4%(±4.5%)96.4%(±3.5%)82.1%(±7.3%)86.8%(±6.2%)86.5%(±3.1%)70.4%(±7.5%)
Table 25: Effectiveness Endpoint Results
------------------------------------------

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Secondary Patency,12-Month78.9%(±5.4%)N/A82.1%(±7.3%)N/A79.0%(±4.6%)62.8%(±8.4%)
Functional Patency,6-Month96.3%(±3.6%)100.0%(±0.0%)100.0%(±0.0%)100.0%(±0.0%)98.1%(±1.8%)95.0%(±4.9%)
Functional Patency,12-Month96.3%(±3.6%)N/A100.0%(±0.0%)N/A98.1%(±1.8%)82.3%(±9.3%)

This summary table is intended to provide standalone results for the most important efficacy study endooints.

The Pooled Effectiveness Population includes those studies plus EASE. The exception is Functional Cannulation, where the pooled dataset is limited to NEAT and EU-PMCF since more extensive cannulation data was available in those studies.

The 6- and 12-month windows are defined as 180 and 360 days + 30 days, respectively. The data in this table represent events through the end of the respective windows; i.e. 210 days for 6 months and 390 days for 12 months.

NA- Not applicable. Indicates that the data point is beyond the length of follow-up for a study or that the number of evaluable subjects is zero at that time point.

Procedural Success was defined as successful endo.4VF creation confirmed via intraprocedural fistulography or by duplex ultrasound performed post-procedure.

Time to Cannulation is the time between the index procedure to the first successful endoAVF cannulation. Cannulation Success was defined as successful 2-needle cannulation and dialysis through the endoAVF.

Functional Cannulation is defined as 2-needle access of the endoAVF access circuit with performance of ≥ 2/3rds of > 120-minute dialysis sessions through the endoAVF access circuit over a continuous 28-day period. Functional Cannulation is expressed as the Kaplan-Meier estimate (Standard Error).

Patency definitions are from the Society of Vascular Surgery Reporting Standards document; Sidawy et al. Recommended standards for reports dealing with arteriovenous hemodialysis accesses, J Vasc Surg 2002;35:603-10. Primary patency is the interval of time of access placement until any intervention designed to maintain or re-establish patency, access thrombosis, access abandomment, or the time of measurement of patency. Assisted is the interval from access placement to thrombosis or abandonment; not triggered by access circuit interventions performed in the absence of occlusion. Secondary patency is the of access placement until access abandonment, lost to thrombosis, or the time of patency measurement including intervening manipulations (surgical or endovascular interventions) designed to re-establish functionality in thrombosed access. Functional patency is the interval of time from the first 2-needle dialysis utilizing the access abandonment.

Patency rates are expressed as Kaplan-Meier estimates (Standard Error,

Data is site-reported, with independent Medical Monitor classifications and CEC-adjudicated data

  • For all effectiveness endpoints except Functional Cannulation, pooled studies include NEAT, FLEX, EU-PMCF, and EASE. The pooled studies for Functional Cannulation excluded FLEX and EASE, since the extent of available cannulation data was less than for the NEAT and EU-PMCF studies.

f Functional Cannulation, specified in the dialysis subset defined as the cohort of subjects who were enrolled on dialysis or eventually went on dialysis during follow-up. The data include the NEAT and EU-PMCF studies alone.

The 6- and 12-month timepoints were calculated at the end of the follow-up windows, through 210 and 390 days, respectively.

Patency Results

As shown in Table 25 above, the 6-month primary patency rates among the EU-PMCF (78.9%) and EASE (83.3%) studies were numerically similar to the 6-month primary patency rate in the NEAT study (81.1%). Among the entire pooled effectiveness population, the 6-month primary patency rate was 82.7%.

The figures below show patency rates for the pooled effectiveness population expressed as Kaplan-Meier estimates with shaded regions showing the 95% confidence interval. The 12

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month primary patency rate for the pooled effectiveness population was 74.8%, although only 29 subjects were evaluable at this 12 months as shown by the corresponding life table.

Image /page/37/Figure/1 description: The image shows a survival probability graph with days on the x-axis and survival probability on the y-axis. The graph displays a curve that starts near 1.0 and gradually decreases over time, with a shaded area representing the 95% equal precision band. A table below the graph provides data on the number at risk, censored, failures, success rate, Greenwood SE, and 95% CI for different time intervals in days, ranging from day 0 to 361-390. For example, at day 0, the success rate is 98.1%, while at days 361-390, the success rate is 74.8%.

Figure 6: Primary Patency, Pooled Effectiveness Population

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Image /page/38/Figure/0 description: The image shows a survival probability graph with days on the x-axis and survival probability on the y-axis. The graph includes a blue line representing the survival probability over time, along with a shaded blue area indicating the 95% equal precision band. A table below the graph provides detailed data for different time intervals, including the number at risk, censored, failures, success rate, Greenwood SE, and 95% CI. For example, at day 0, there were 157 at risk, 4 censored, 2 failures, and a success rate of 98.7%.

Figure 7: Assisted Primary Patency, Pooled Effectiveness Population

Functional Cannulation

Functional Cannulation is defined as successful 2-needle cannulations with at least 2 hours of hemodialysis through the access circuit, for two-thirds or more of the dialysis sessions in any continuous 28-day period. The time to Functional Cannulation is the duration from the index procedure to the start of the 28-day period.

Table 26 below shows the proportion of subjects in each category who had achieved functional cannulation at each timepoint. Additionally, the table shows the number of subjects who were evaluable in each category (N), as well as the median (months), mean ± SD (months), and range

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of months subjects required to reach the 28-day period when they achieved Functional Cannulation success. The data come from the NEAT and EU-PMCF studies, as these studies used detailed cannulation logs.

MeasureOn dialysis at enrollmentPre-dialysis at enrollmentwho eventually went ondialysisOn dialysis at enrollmentor pre-dialysis atenrollment who eventuallywent on dialysis
Functional Cannulation, 6-Month*59.4% ( $\pm$ 9.3%)52.5% ( $\pm$ 10.8%)56.1% ( $\pm$ 7.1%)
Functional Cannulation, 12-Month*73.9% ( $\pm$ 9.1%)85.1% ( $\pm$ 9.1%)78.4% ( $\pm$ 6.6%)
N402666
Median [IQR]0.7 [0.0,3.5]3.5 [1.9,7.4]3.4 [2.1,7.2]
Mean $\pm$ SD2.1 $\pm$ 2.65.0 $\pm$ 3.64.7 $\pm$ 3.7
Range (min, max)(0.0, 9.5)(0.3, 12.1)(0.0, 12.4)
The 6- and 12-Month windows end at 210 and 390 days, respectively.

Table 26: Functional Cannulation, Subjects Requiring Dialysis

Table 27 below shows the number of subjects who were evaluable for functional cannulation success from each data source: i.e., the number of subjects who initiated hemodialysis during each study. It also shows the percentage of subjects from each study who were on hemodialysis and achieved functional cannulation success at 6 months and 12 months, as well as the time to achieve functional cannulation success broken out by subjects who were on dialysis at enrollment and subjects who were pre-dialysis at the beginning of the study and eventually required hemodialysis.

Among the Pooled functional cannulation - which includes only subjects from the NEAT and EU-PMCF studies because only these studies contained detailed cannulation logs the functional cannulation success was 56.1% at 6 months and 78.4% at 12 months. Among these subjects, the average time to achieve functional cannulation success was 2.1 months for subjects who were on dialysis at enrollment and 5.0 months for subjects who were pre-dialysis at the time of study enrollment.

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MetricNEATFLEXEU-PMCFEASEPooled
Total N6033323292
Exited studypredialysis1729026
Totalincluded inanalysis4331233266
FunctionalCannulationSuccess6-Month+50.4%CI[34.3% - 66.5%]94.5%CI[84.5% - 100%]71.1%CI[45.1%-97.1%]85.8%CI[71.1%-100%]56.1%CI[42.2%-69.9%]
FunctionalCannulationSuccess12-Month+74.2%[58.7%-89.6%]NANANA78.4%CI[65.3%-91.4%]
Time toCannulation(months)Dialysis 3.9 ± 1.5Predialysis 4.2 ± 3.0Dialysis 2.2 ± 0.8Predialysis NADialysis 3.1 ± 1.4Predialysis 2.9 ±2.5Dialysis 1.4 ± 0.5Predialysis NADialysis 2.1 ± 2.6Predialysis 5.0 ±3.6
* Excludes predialysis patients that never were on to dialysis through study exitPooled includes NEAT and EU-PMCF only as these studies contained detailed cannulation logs.+ The 6- and 12-month windows end at 210 and 390 days, respectively

Table 27: Functional Cannulation Success* by Data Source

Conclusions: The NEAT Study and the Global Analysis demonstrated that there is a reasonable assurance of safety and effectiveness that the everlinQ® endoAVF System creates an arteriovenous fistula that can mature as a method of vascular access for hemodialysis. In the NEAT Study, a fistula was successfully created in 59/60 (98.3%) subjects and 52/60 (86.7%) met the primary endpoint success criteria for fistula maturation at 90 days. The rate of SAEs related to the device and/or procedure through 12 months was 8 SAEs in 5/60 subjects (8.3%), and the primary safety endpoint was met. Although 2 of the SAEs in the NEAT Study were related to vascular closure device embolization, safety data collected from the EU-PMCF and commercial cases after the implementation of a training program showed that all subjects (20/20) achieved hemostasis by manual compression of the brachial artery instead of using vascular closure devices, and no subjects (0/20 = 0%) experienced any SAEs after the implementation of the training program, as summarized in Table 24 above. Among NEAT Study subjects who went on hemodialysis during the study, the functional cannulation endpoint was met by 50.4% of subjects at 6 months and by 74.2% of subjects at 12 months. In the NEAT Study, the reported Kaplan-Meier estimate for primary patency was 81.1% at 6 months and 73.4% at 12 months. The reported Kaplan-Meier estimate for assisted primary patency at 12 months was 77.2%. In the NEAT Study, 56/60 subjects (93.3%) required the implantation of at least one embolization coil in their brachial vein at the time of the index procedure, with an average of 1.6 coils. After the index procedure, 17/60 subjects (28.3%) required at least one reintervention, with a total of 20 reinterventions among those 17 subjects.

Pediatric Extrapolation

In this De Novo request, existing clinical data were not leveraged to support the use of the device in a pediatric patient population.

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POSTMARKET EVALUATION

A postmarket evaluation will be conducted to collect data on the safety and effectiveness of the everlinO® endoAVF System in U.S. patients. This is a postmarket, prospective. multi-center study of U.S. patients with chronic kidney disease who need hemodialysis and are candidates for the creation of an arteriovenous fistula with the everlinO® endoAVF System. Safety and effectiveness data will be collected and compared to the pivotal study data that supported this De Novo application.

LABELING

The everlinQ® endoAVF System labeling consists of Instructions for Use and packaging labels. The Instructions for Use include the indications for use; a description of the device, contraindications, warnings, precautions; a list of commercially available electrosurgical devices that are compatible with the device; a detailed summary of the clinical data collected in support of the device: a list of potential adverse events; a shelf life; the expertise needed for the safe use of the device; and instructions for the safe use of the device. The labeling satisfies the requirements of 21 CFR 801.109.

Please see the Limitations section above for important contraindications, warnings and precautions presented in the device labeling.

RISKS TO HEALTH

The table below identifies the risks to health that may be associated with use of a percutaneous catheter for creation of an arteriovenous fistula for hemodialysis access and the measures necessary to mitigate these risks.

Identified Risks to HealthMitigation Measures
Unintended vascular or tissue injuryNon-clinical performance testingAnimal testingClinical performance testingLabeling
Adverse hemodynamic effectsNon-clinical performance testingAnimal testingClinical performance testingLabeling
Failure to create a durable fistula that is usablefor hemodialysisAnimal testingClinical performance testing
Use of the device adversely impacts futurevascular access sitesClinical performance testingLabeling
Adverse tissue reactionBiocompatibility evaluationLabeling
InfectionSterilization validation

Table 28: Identified Risks to Health and Mitigation Measures

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Shelf life testingLabeling
Electrical malfunction or interference leadingto electrical shock, device failure, orinappropriate activationNon-clinical performance testingElectrical safety testingElectromagnetic compatibility (EMC) testing
Software malfunction leading to device failureor inappropriate activationSoftware verification, validation, and hazardanalysis

SPECIAL CONTROLS:

In combination with the general controls of the FD&C Act, the percutaneous catheter for creation of an arteriovenous fistula for hemodialysis access is subject to the following special controls:

    1. Clinical performance testing must evaluate:
    • The ability to safely deliver, deploy, and remove the device; a.
    • b. The ability of the device to create an arteriovenous fistula;
    • c. The ability of the arteriovenous fistula to attain a blood flow rate and diameter suitable for hemodialysis:
    • d. The ability of the fistula to be used for vascular access for hemodialysis;
    • e. The patency of the fistula; and
    • f. The rates and types of all adverse events.
    1. Animal testing must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be assessed:
    • a. Delivery, deployment, and retrieval of the device:
    • b. Compatibility with other devices labeled for use with the device:
    • Patency of the fistula: C.
    • d. Characterization of blood flow at the time of the fistula creation procedure and at chronic follow-up; and
    • Gross pathology and histopathology assessing vascular injury and downstream e. embolization.
    1. Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
    • Simulated-use testing in a clinically relevant bench anatomic model to assess the a. delivery, deployment, activation, and retrieval of the device:
    • b. Tensile strengths of joints and components;
    • c. Accurate positioning and alignment of the device to achieve fistula creation: and
    • d. Characterization and verification of all dimensions.
    1. Electrical performance, electrical safety, and electromagnetic compatibility (EMC) testing must be performed for devices with electrical components.

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    1. Software verification, validation, and hazard analysis must be performed for devices that use software.
    1. All patient-contacting components of the device must be demonstrated to be biocompatible.
    1. Performance data must demonstrate the sterility of the device components intended to be provided sterile.
    1. Performance data must support the shelf life of the device by demonstrating continued sterility, package integrity, and device functionality over the identified shelf life.
    1. Labeling for the device must include:
    • a. Instructions for use:
    • b. Identification of system components and compatible devices;
    • c. Expertise needed for the safe use of the device;
    • d. A detailed summary of the clinical testing conducted and the patient population studied: and
    • e. A shelf life and storage conditions.

BENEFIT/RISK DETERMINATION

The risks of the device are based on nonclinical laboratory and/or animal studies as well as data collected in the clinical studies described above. Types of harmful events include access site complications, pseudoaneurysm, thrombosis, closure device embolization, brachial artery dissection, hematoma, bruising, steal, swelling and pain. Among the NEAT study population described in the clinical data section above, the rate of serious device- and/or procedure-related harmful events was 5/60 (8.3%) and the rate of non-serious device- and/or procedure-related harmful events was 22/60 (36.7%). There were no deaths adjudicated as related to the device or procedure. A total of 9 occlusion and/or thrombosis events were observed in 9 subjects (15.0%); for 4 of these 9 subjects (44.4%) the occlusion event was acute (occurred within 0-42 days of the index procedure). A total of 6 endoAVFs (6/60 = 10%) were abandoned due to thrombosis or occlusion of the endoAVF at 12 months. The endoAVF procedure requires adjunctive procedures at the time of the index procedure, as 56/60 subjects (93.3%) in the NEAT study required the implantation of an average of 1.6 embolization coils in a brachial vein to redirect blood flow to the superficial veins and support maturation of the target cannulation area.

The probable benefits of the device are also based on nonclinical laboratory and/or animal studies as well as data collected in clinical studies as described above. In the NEAT Study, there was a high rate of procedural success as 59/60 subjects (98.3%) had an endoAVF successfully created. The 90-day maturation success rate, defined as the rate of subjects with an endoAVF that was free of stenosis or thrombosis with brachial artery flow of at least 500 mL/min and at least 4mm vein diameter OR subject was dialyzed using 2 needles, was 52/60 (86.7%). Out of the subjects who required hemodialysis during the NEAT study. 70.6% achieved cannulation success at 6 months and 86.1% achieved cannulation success at 12 months. Among those subjects who required hemodialysis during the study, functional cannulation success was

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achieved in 50.4% of the subjects at 6 months and in 74.2% of the subjects at 12 months. Primary patency was achieved in 81.1% of subjects at 6 months and 73.4% of subjects at 12 months.

Additional factors to be considered in determining probable risks and benefits for the everlin(® endoAVF System include: Physician training may reduce the rate of access site complications, and a physician training program will be used in the post-market study. The Global Analysis data and initial physician training data suggest that hemostasis of the brachial artery access site can be achieved with manual compression instead of vascular closure devices. The device requires embolization coils to be implanted in the deep veins at the index procedure to assist fistula maturation, so any adjunctive procedures should be planned for each patient prior to the procedure. The device was not studied with any Black subjects, but this subgroup will be evaluated in a U.S. post-market study. All serious device- and/or procedure-related complications observed in the NEAT Study were reversible through intervention or were selfresolving. There were no device- or procedure-related infections observed in the NEAT Study.

Patient Perspectives

This submission included patient perspective information from a subset of patients treated in the NEAT Study. However, due to the limitations of the data, it was not considered in the benefit/risk analysis of the device.

Benefit/Risk Conclusion

In conclusion, given the available information above, the data support that for the creation of an arteriovenous fistula in patients with chronic kidney disease who need hemodialysis, the probable benefits outweigh the probable risks for the everlinO® endoAVF System. The device provides benefits and the risks can be mitigated by the use of general controls and the identified special controls.

CONCLUSION

The De Novo request for the everlinQ® endoAVF System is granted and the device is classified under the following:

Product Code:PQK
Device Type:Percutaneous catheter for creation of an arteriovenous fistula for hemodialysis access
Class:II
Regulation:21 CFR 870.1252

§ 870.1252 Percutaneous catheter for creation of an arteriovenous fistula for hemodialysis access.

(a)
Identification. This device is a single use percutaneous catheter system that creates an arteriovenous fistula in the arm of patients with chronic kidney disease who need hemodialysis.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Clinical performance testing must evaluate:
(i) The ability to safely deliver, deploy, and remove the device;
(ii) The ability of the device to create an arteriovenous fistula;
(iii) The ability of the arteriovenous fistula to attain a blood flow rate and diameter suitable for hemodialysis;
(iv) The ability of the fistula to be used for vascular access for hemodialysis;
(v) The patency of the fistula; and
(vi) The rates and types of all adverse events.
(2) Animal testing must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be assessed:
(i) Delivery, deployment, and retrieval of the device;
(ii) Compatibility with other devices labeled for use with the device;
(iii) Patency of the fistula;
(iv) Characterization of blood flow at the time of the fistula creation procedure and at chronic followup; and
(v) Gross pathology and histopathology assessing vascular injury and downstream embolization.
(3) Non-clinical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. The following performance characteristics must be tested:
(i) Simulated-use testing in a clinically relevant bench anatomic model to assess the delivery, deployment, activation, and retrieval of the device;
(ii) Tensile strengths of joints and components;
(iii) Accurate positioning and alignment of the device to achieve fistula creation; and
(iv) Characterization and verification of all dimensions.
(4) Electrical performance, electrical safety, and electromagnetic compatibility (EMC) testing must be performed for devices with electrical components.
(5) Software verification, validation, and hazard analysis must be performed for devices that use software.
(6) All patient-contacting components of the device must be demonstrated to be biocompatible.
(7) Performance data must demonstrate the sterility of the device components intended to be provided sterile.
(8) Performance data must support the shelf life of the device by demonstrating continued sterility, package integrity, and device functionality over the identified shelf life.
(9) Labeling for the device must include:
(i) Instructions for use;
(ii) Identification of system components and compatible devices;
(iii) Expertise needed for the safe use of the device;
(iv) A detailed summary of the clinical testing conducted and the patient population studied; and
(v) A shelf life and storage conditions.