FDA 510(k) Search - By Innolitics (SaMD and AI Experts)

The GEM® Premier 3000 is a portable system for use by health care professionals to rapidly analyze whole blood samples that was originally cleared for the U.S. market by K992834, with glucose and lactate parameters added by K010520.

Intelligent Quality Management (iQM") is being introduced on the GEM® Premier 3000 as an active quality process control program designed to provide continuous monitoring of the analytical process with real-time, automatic error detection, automatic correction of the system and automatic documentation of all corrective actions, replacing the use of traditional external quality controls.

As part of this program, GEM® CVP (Calibration Validation Product) is intended for the external verification of the iQM" cartridge calibration after initial warm-up to ensure its integrity. The reported values for the four levels of GEM® CVP (two levels for pH, blood gases, electrolytes and metabolites; two levels for hematocrit) must meet specifications before the iQM" cartridge can be used for patient sample measurements. Once the cartridge calibration is verified, the internal iOM "program monitors the status of the system during the cartridge use life.

To ensure that a total quality management system is adhered to, laboratories should follow local, state and federal regulatory guidelines. As with any analytical device or computer software, there is always the potential for software failure. However, IL conducts rigorous testing and extensive software validation prior to releasing a software revision. If the user encounters a rare software error code, it should be reported to your local IL Technical Support Representative.

Device Description

AI/ML Overview

Here's a breakdown of the acceptance criteria and the studies performed for the GEM® Premier 3000 with iQM™ and GEM® CVP, based on the provided document:

Acceptance Criteria and Device Performance

The document does not explicitly present a table of acceptance criteria in the sense of predefined thresholds for performance metrics. Instead, it presents the results of performance studies (precision and method comparison) that indicate the device's capabilities and statistical similarity to a reference instrument.

For the GEM® CVP Precision study, the reported performance is the Day-to-Day %CV (or SD) and Total %CV (or SD) for various parameters across different CVP levels. The acceptance is implicitly assumed if these values are considered acceptable for clinical use, or comparable to existing methods.

For the GEM® Premier 3000 with iQM™ Method Comparison study, the reported performance includes the slope, intercept, and correlation coefficient (r) when compared to a reference instrument (IL Synthesis). The acceptance is stated as being "statistically similar to the reference instrument."

Table of Reported Performance Data (Excerpted from the document):

GEM® CVP Precision Study Results:

Parameter	Mean	Day-to-Day %CV (or SD)	Total %CV (or SD)
GEM® CVP Level 1
pH	7.200	0.005 (SD)	0.007 (SD)
pCO2 (mmHg)	70.8	1.39	1.63
pO2 (mmHg)	54.5	4.97	5.16
Na+ (mmol/L)	129.3	0.46	0.55
K+ (mmol/L)	2.90	0.25	0.70
Ca++ (mmol/L)	1.493	0.95	1.26
Glucose (mg/dL)	46.1	2.23	2.99
Lactate (mmol/L)	0.93	4.73	4.87
GEM® CVP Level 2
pH	7.640	0.002 (SD)	0.003 (SD)
pCO2 (mmHg)	29.9	1.78	1.91
pO2 (mmHg)	148.2	1.33	1.93
Na+ (mmol/L)	158.7	0.44	0.56
K+ (mmol/L)	6.46	0.75	0.98
Ca++ (mmol/L)	0.486	1.15	2.06
Glucose (mg/dL)	192.8	1.67	1.78
Lactate (mmol/L)	5.54	1.85	2.19
GEM® CVP Level 3
Hematocrit (%)	23.4	2.14	2.11
GEM® CVP Level 4
Hematocrit (%)	43.8	1.21	1.23

GEM® Premier 3000 with iQM™ Method Comparison Study Results:

Analyte	N	Slope	Intercept	r	Sample Range
pH	281	1.0802	-0.5810	0.9917	7.129-7.559
pCO2 (mmHg)	282	1.0674	-2.3800	0.9839	25.3-87.5
pO2 (mmHg)	282	0.9715	6.9900	0.9988	26-489
Na+ (mmol/L)	271	0.9801	2.9300	0.9584	119-148
K+ (mmol/L)	271	0.9743	-0.0600	0.9871	3.2-7.4
Ca++ (mmol/L)	271	0.9196	0.1270	0.9590	0.82-1.40
Glucose (mg/dL)	283	1.0111	8.8700	0.9860	66-389
Lactate (mmol/L)	280	0.9323	0.1730	0.9958	0.49-16.67
Hct (%)	284	0.9983	-0.7999	0.9600	17-56

Study Information:

1. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

GEM® CVP Precision Study:
- Test Set Size: 15 replicates for each of 4 CVP levels on each of 9 different GEM® Premier 3000 instruments (N=135 total measurements per CVP level/parameter combination).
- Data Provenance: Not explicitly stated, but implied to be from internal lab studies. It's likely a controlled, prospective study.
GEM® Premier 3000 with iQM™ Method Comparison Study:
- Test Set Size (N): Varies per analyte, ranging from 271 to 284 samples (e.g., 281 for pH, 282 for pCO2, 271 for Na+, etc.).
- Data Provenance: "arterial, venous, heart bypass and liver transplant blood samples from hospital patients." This indicates human patient samples. The country of origin is not specified, but the submission is for the U.S. market, so it typically implies U.S. data or data relevant to its approval. It's a retrospective analysis of prospectively collected patient samples, as they were analyzed on both the test device and a reference instrument.
iQM™ (Intelligent Quality Management) Evaluation - Evaluation of Cartridge Malfunction Detection:
- Test Set Size: Data from 79 GEM® Premier 3000 cartridges that demonstrated a QC failure.
- Data Provenance: Not explicitly stated, but implies real-world usage data where QC failures occurred. This would be considered retrospective analysis of field data.
Field Evaluation: External QC vs. iQM™:
- Test Set Size: 304 blood samples.
- Data Provenance: During an external field evaluation at a U.S. hospital. This is prospective real-world data collection.

2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

The document describes device performance validation against instrument measurements and quality control materials. It does not involve human expert interpretation of results to establish ground truth in the way a medical imaging study might.
GEM® CVP Precision: Ground truth is the actual concentration of the assayed quality control materials.
GEM® Premier 3000 with iQM™ Method Comparison: Ground truth is established by the IL Synthesis reference instrument. No human experts are mentioned for establishing ground truth directly for this comparison.
iQM™ (Intelligent Quality Management) Evaluation: Ground truth for a malfunction detection study would be the confirmed presence or absence of a malfunction in the cartridge. This was determined by analysis of "system parameters" and the nature of the QC failures. "No identifiable cartridge malfunction" and "All system parameters were within specifications" implies instrument-derived ground truth.
Field Evaluation: Ground truth for analyte failures came from the observation of "transient drift failures," "Benzalkonium exposure," and "Thiopental Sodium exposure."

3. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Adjudication methods like 2+1 or 3+1 are typically used when human interpretation (e.g., by experts) is involved to resolve discrepancies in ground truth establishment. Since these studies primarily involve comparing instrument readings or detecting malfunctions based on predefined parameters, no such adjudication method is mentioned or appears applicable.

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

No MRMC comparative effectiveness study was done. This device is an analytical instrument and an associated quality control program, not a diagnostic aid that assists human readers in interpreting images or complex data as in AI applications. The focus is on automated measurement accuracy and malfunction detection.

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

Yes, the performance of the GEM® Premier 3000 with iQM™ and GEM® CVP is evaluated entirely in a standalone manner. The iQM™ system itself is an "active quality process control program designed to provide continuous monitoring of the analytical process with real-time, automatic error detection, automatic correction of the system and automatic documentation of all corrective actions, replacing the use of traditional external quality controls." Its evaluation, therefore, is its performance as a standalone automated system. The studies assess its precision, agreement with a reference instrument, and its ability to detect malfunctions automatically.

6. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

GEM® CVP Precision: Assayed values of the quality control materials.
GEM® Premier 3000 with iQM™ Method Comparison: Readings from a reference analytical instrument (IL Synthesis).
iQM™ (Intelligent Quality Management) Evaluation - Evaluation of Cartridge Malfunction Detection: Instrument-based parameters and previous QC failure data. The conclusion that "no identifiable cartridge malfunction" existed for the unflagged failures suggests thorough investigation of instrument internal states.
Field Evaluation: Identified causes of analytical interference (Benzalkonium exposure, Thiopental Sodium exposure) and comparison to a reference instrument (IL Synthesis) and a GEM® 3000 without iQM.

7. The sample size for the training set

The document does not explicitly state the sample size for a "training set." This type of device relies on established analytical principles and algorithms. While the iQM™ system uses "Failure Pattern Recognition (FPR) checks," it's not described as a system that undergoes machine learning training in the contemporary sense. The "training" in this context would likely refer to internal development and validation data, not a distinct "training set" as in typical AI/ML development. The "79 GEM® Premier 3000 cartridges that demonstrated a QC failure" were part of an evaluation to test the FPR checks, not necessarily to train them.

8. How the ground truth for the training set was established

As a conventional analytical instrument and its QC system, there isn't a "training set" with ground truth established in the same way as an AI/ML model for image recognition or diagnosis. The underlying principles for analysis and quality control are based on established chemistry, physics, and engineering. The "ground truth" for the device's operational parameters would have been established through extensive engineering, chemical assays, and calibration procedures during the device's development.

Summary

Regulation Number and Section

§ 862.1345 Glucose test system.

(a)
Identification. A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.(b)
Classification. Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.