K Number
K070462
Device Name
XPERT MRSA
Manufacturer
Date Cleared
2007-04-17

(60 days)

Product Code
Regulation Number
866.1640
Reference & Predicate Devices
N/A
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Cepheid® Xpert MRSA Assay performed on the GeneXpert® Dx System (Xpert MRSA) is a qualitative in vitro diagnostic test designed for rapid detection of methicillinresistant Staphylococcus aureus (MRSA) from nasal swabs in patients at risk for nasal colonization. The test utilizes automated real-time polymerase chain reaction (PCR) to detect MRSA DNA. The Xpert MRSA Assay is intended to aid in the prevention and control of MRSA infections in healthcare settings. The Xpert MRSA Assay is not intended to diagnose MRSA nor to guide or monitor treatment for MRSA infections. Concomitant cultures are necessary only to recover organisms for epidemiological typing or for further susceptibility testing.

Device Description

The Cepheid Xpert methicillin-resistant Staphylococcus aureus (MRSA) Assay is a rapid, automated DNA test for detecting MRSA directly from nasal swab specimens of patients in a healthcare setting. The Xpert MRSA performs real-time, multiplex polymerase chain reaction (PCR) for detection of DNA after an initial manual sample elution step. In this platform, additional sample preparation, amplification, and real-time detection are all fully automated and completely integrated. The system includes a GeneXpert® System, which consists of an instrument, personal computer, and disposable fluidic cartridges that are designed to complete sample preparation and real-time PCR for detection of MRSA in about 75 minutes. Each instrument contains 2-4 randomly accessible modules that are each capable of performing separate sample preparation and real-time PCR tests. Each module contains a syringe drive for dispensing fluids, an ultrasonic horn for lysing cells or spores, and a proprietary I-CORE® thermocycler for performing real-time PCR and detection.

The Xpert MRSA Assay includes reagents for the detection of the target MRSA. The primers and probes in the Xpert MRSA Assay detect the presence of the staphylococcal cassette chromosome (SCC) inserted into the SA chromosomal attB site.

The test includes a sample processing control (SPC) to control for adequate processing of the target bacteria and to monitor the presence of inhibitor(s) in the PCR assay. The Probe Check Control (PCC) verifies reagent rehydration, PCR tube filling in the cartridge, probe integrity, and dye stability.

AI/ML Overview

Here's a breakdown of the acceptance criteria and study details for the Cepheid Xpert MRSA Assay, based on the provided 510(k) summary:

Acceptance Criteria and Reported Device Performance

The acceptance criteria are implied by the comparison to the reference culture method and the predicate device. The primary performance metrics are Sensitivity and Specificity.

Acceptance Criterion (Implicit)Reported Device Performance (Xpert MRSA Assay vs. Reference Culture)
Sensitivity comparable to or better than predicate (IDI-MRSA™)86.3% (95% CI: 80.9-90.6%)
Specificity comparable to or better than predicate (IDI-MRSA™)94.9% (95% CI: 93.2-96.3%)

Note: The predicate device (IDI-MRSA™ Assay) had a reported sensitivity of 83.3% and specificity of 94.4% in the same Cepheid Clinical study using the same reference method. Its package insert (using a different enriched culture method) reported 92.5% sensitivity and 96.4% specificity. The Xpert MRSA Assay met the implicit criterion of performing as well as or better than the predicate in the comparative study.


Study Details

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

    • Test Set Sample Size: 1077 eligible subjects (patients).
    • Data Provenance: A multi-center prospective investigation study at seven institutions. The document does not explicitly state the country of origin, but given the submission is to the FDA, it is highly likely the study was conducted within the United States.
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • The ground truth was established by a centralized laboratory culture testing, which is a laboratory method, not directly dependent on expert interpretation in the same way as, for example, a medical imaging study. The document does not specify the number of laboratory personnel or their specific qualifications, but it implies standard microbiological laboratory practices were followed.
  3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • None in the context of human reader adjudication. The ground truth was established by laboratory culture methods (enriched culture method, and for secondary comparison, direct culture method). Presumptive positive colonies from culture methods were confirmed with a tube coagulase test and Gram stain, which are standard laboratory confirmation procedures.
  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, this was not an MRMC comparative effectiveness study involving human readers with and without AI assistance. This study evaluated an automated diagnostic assay (Xpert MRSA) against a reference culture method and a predicate device (IDI-MRSA™). It assesses the performance of the device itself, not an AI assisting human readers.
  5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    • Yes, this was essentially a standalone performance study. The Xpert MRSA Assay is an "automated DNA test" where "additional sample preparation, amplification, and real-time detection are all fully automated and completely integrated." The reported performance characteristics (Sensitivity, Specificity, PPV, NPV) are for the assay's output directly compared to the reference standard. While laboratory personnel operate the system, the diagnostic result itself is generated by the instrument/algorithm without human interpretative input beyond loading the sample and reading the final result.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The primary ground truth used was the enriched culture method performed at a centralized laboratory, which is considered the "most sensitive culture method" for detecting MRSA from nasal swabs. A secondary comparison was made against a "direct culture method." This is a laboratory-based gold standard.
  7. The sample size for the training set:

    • The document describes a clinical study for validation, not explicitly a separate training set. For analytical sensitivity (Limit of Detection), a study was performed with MRSA cells at seven concentrations (0, 5, 10, 20, 40, 60, and 80 CFU/swab) to determine the LoD. This is an analytical experiment, not a clinical training set in the sense of machine learning algorithms. The commercial assay itself is not described as involving a machine learning model that requires a distinct "training set" of clinical data for its development in the way an AI diagnostic often does.
  8. How the ground truth for the training set was established:

    • This question is less applicable as the device is a nucleic acid amplification test (NAAT) and not a machine learning-based AI device that typically requires a large "training set" of labeled clinical data. The analytical sensitivity (LoD) was established using controlled dilutions of MRSA type II cells to define the assay's detection limit, not a clinical ground truth for a training set.

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K070462

5.0 510(k) Summary

As required by 21 CFR Section 807.92(c).

APR 17 2007
Submitted by:Cepheid904 Caribbean DriveSunnyvale, CA 90489Phone number: (408) 400-8230Fax number: (408) 541-6439
Contact:Russel K. Enns, Ph.D.
Date of Preparation:February 16, 2007
Device:
Trade name:Xpert MRSA
Common name:Methicillin-resistant Staphylococcus aureus (MRSA) Assay
Type of Test:Nucleic Acid Amplification Test, DNA, Methicillin-resistant Staphylococcus aureus (MRSA), qualitative
Classification name:Antimicrobial susceptibility test powder
Regulation number:866.1640
Procode:NQX
ClassificationAdvisory Committee:Microbiology
Panel:83
Predicate Device.IDI-MRSATM Assay [510(k) nos K033415/K042357]

Device Description:

The Cepheid Xpert methicillin-resistant Staphylococcus aureus (MRSA) Assay is a rapid, automated DNA test for detecting MRSA directly from nasal swab specimens of patients in a healthcare setting. The Xpert MRSA performs real-time, multiplex polymerase chain reaction (PCR) for detection of DNA after an initial manual sample elution step. In this platform, additional sample preparation, amplification, and real-time detection are all fully automated and completely integrated. The system includes a GeneXpert® System, which consists of an instrument, personal computer, and disposable fluidic cartridges that are designed to complete sample preparation and real-time PCR for detection of MRSA in about 75 minutes. Each instrument contains 2-4 randomly accessible modules that are each capable of performing separate sample preparation and real-time PCR tests. Each module contains a syringe drive for dispensing fluids, an ultrasonic horn for lysing cells or spores, and a proprietary I-CORE® thermocycler for performing real-time PCR and detection.

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The Xpert MRSA Assay includes reagents for the detection of the target MRSA. The primers and probes in the Xpert MRSA Assay detect the presence of the staphylococcal cassette chromosome (SCC) inserted into the SA chromosomal attB site.

The test includes a sample processing control (SPC) to control for adequate processing of the target bacteria and to monitor the presence of inhibitor(s) in the PCR assay. The Probe Check Control (PCC) verifies reagent rehydration, PCR tube filling in the cartridge, probe integrity, and dye stability.

Device Intended Use:

The Cepheid® Xpert MRSA Assay performed on the GeneXpert® Dx System (Xpert MRSA) is a qualitative in vitro diagnostic test designed for rapid detection of methicillinresistant Staphylococcus aureus (MRSA) from nasal swabs in patients at risk for nasal colonization. The test utilizes automated real-time polymerase chain reaction (PCR) to detect MRSA DNA. The Xpert MRSA Assay is intended to aid in the prevention and control of MRSA infections in healthcare settings. The Xpert MRSA Assay is not intended to diagnose MRSA nor to guide or monitor treatment for MRSA infections. Concomitant cultures are necessary only to recover organisms for epidemiological typing or for further susceptibility testing.

Substantial Equivalence:

The Xpert MRSA Assay is substantially equivalent to the BD Infectio Diagnostic Inc. IDI-MRSA™ Assay (K033415). Both assays detect MRSA; both assays determine the presence of MRSA through real-time PCR amplification and fluorogenic target-specific hybridization detection.

The Xpert MRSA Assay is automated using the Cepheid GeneXpert Dx System instrument. The IDI-MRSA™ Assay is semi-automated using the Cepheid SmartCvcler® System instrument. Both instruments emplov the same principle I-CORE® design for controlling the real-time PCR amplification and fluorogenic targetspecific hybridization detection.

A multi-center study was conducted on 1077 patients. The samples were evaluated with the Xpert MRSA Assay and the IDI-MRSA™ Assay. Broth culture was also performed. The test results showed the two assays to be substantially equivalent.

Table 5-1 shows the similarities and differences between the Xpert MRSA Assay and the IDI-MRSA™ Assay.

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Table 5-1

Similarities and Differences Between the Xpert MRSA Assay and the IDI-MRSA™ Assay

Similarities
ItemDevicePredicate
Intended UseRapid detection MRSASame
Specimen TypeDirect from nasal swabsSame
Indication for UseIdentification of MRSA colonizationSame
TechnologicalPrinciplesNucleic acid amplification (DNA);real-time PCRSame
InstrumentationReal-time PCR (thermal cycling anddetection), I-CORE®Same
Differences
ItemDevicePredicate
InstrumentationCepheid GeneXpert® Dx SystemCepheid SmartCycler® System
FluidicsSelf-contained and automated afterswab elution and two single-dosereagent additions.Multiple manual steps includingpipetting, fluid transfers, vortexing,centrifugation, and sample heating.
LysisSonication (automated single-usecartridge)Glass Beads (manual)
ProbesTaqMan® ProbesMolecular beacons
DNA TargetSequenceSimilar, but differentSequence incorporating the insertionsite ( attBssc ) of StaphylococcalCassette Chromosome mec (SCC mec ).Similar, but differentSequence near the insertion site ofStaphylococcal CassetteChromosome mec (SCC mec ).
Internal ControlsSample processing control (SPC) andprobe check control (PCC).Internal Control (IC)
Time to result75 minutes total60 to 75 minutes total
UsersOperators with no clinical labexperience to experienced clinicallaboratory technologists.CLIA high complexity laboratorytechnologists

Xpert MRSA 510(k) Notification February 16, 2007

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Differences
ItemDevicePredicate
PerformanceCharacteristics asdetermined in theCepheid ClinicalStudy incomparison to thereference culturemethod asrequested per thepre-IDE.Sensitivity: 86.3 %Specificity: 94.9 %Sensitivity: 83.3 %Specificity: 94.4 %*As determined in the CepheidClinical study using the samesubjects and the same referenceenriched culture method (selectivechromogenic agar plates) as testedwith the Xpert MRSA Assay.Sensitivity: 92.5%Specificity: 96.4%**IDI-MRSA™ package insert(using a different enriched culturemethod)

Non-Clinical Studies:

Analytical Specificity

Cultures from 51 American Type Culture Collection (ATCC) and Network on Antimicrobial Resistance in Staphylococcus aureus (NARSA) strains representing species phylogenetically related to S. aureus and members of the nasal commensal flora, 32 strains of methicillin-sensitive coagulase negative staphylococci, and 12 strains of methicillin-resistant coagulase negative staphylococci were tested. Three replicates of each isolate were tested at ≥ 1 x 10° CFU/swab. None of these isolates were detected by the assay. Under the conditions of this test, the specificity was 100%,

Analytical Sensitivity

The analytical sensitivity or limit of detection (LoD), of the Xpert MRSA was determined using type II cells of MRSA evaluated at seven concentrations. Under the conditions of this study and using a Ct (cycle threshold) cutoff of 36, these results indicate that the LoD point estimate is 79 CFU/swab with a 95% confidence interval ranging from 70 CFU/swab to 94 CFU/swab. The estimate and confidence levels were determined using logistic regression with data (number of positives per number of tests at each level) taken at seven levels (0, 5, 10, 20, 40, 60 and 80 CFU/swab). The confidence intervals were determined using maximum likelihood estimates on the logistic model parameters using the large sample variance-covariance matrix. Results from the studies performed indicated that the Xpert MRSA Assay will produce a positive result 95% of the time with 95% confidence for a swab containing 80 CFU.

Interfering Substances

Potentially interfering substances evaluated include blood, mucus, and nasal sprays used to relieve decongestion, nasal dryness, or irritation. The presence of these substances did not significantly inhibit PCR and did not give invalid or erroneous results.

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In the investigational study for the Xpert MRSA Assay, potential interfering substances (blood, mucus or both) were reported on 45 of 1077 (4.2 %) nasal swab specimens. Of the 31 specimens that gave an equivocal result on initial testing, three specimens had mucus and one specimen had blood on the swab. Three of the four specimens gave a result on retesting while one that contained mucus remained indeterminate.

Clinical Study

Performance characteristics of the Xpert MRSA Assay were determined in a multi-site prospective investigation study at seven institutions by comparing the MRSA Assay on the GeneXpert® System (Xpert MRSA Assay) with a second FDA-cleared nucleic acid amplification test (NAAT), and enriched culture, the most sensitive culture method. Subjects included individuals and medical staff at risk for nasal colonization. Each subject was enrolled in the study only one time. Subjects who had received systemic or topical-nasal antibiotics in the period 48 hours to one week prior to study enrollment, under 2 years of age, had contraindication to nasal swab collection were excluded from the study. Only those subjects meeting the inclusion criteria were enrolled.

Nasal swabs were collected from each subject. One swab was tested by the Xpert MRSA Assay and another swab by the 2nd FDA-cleared NAAT test. The two types of NAAT tests were performed at each participating institution and an additional swab was sent to a centralized laboratory for culture testing.

At the centralized laboratory, the swab was directly streaked onto a selective chromogenic agar plate with cefoxitin and the plate was incubated for 24-48 hours at 35+2°C. The swab was transferred to trypticase soy broth (TSB) with 6.5% sodium chloride and incubated for 18-24 hours at 35+2°C. If the direct streak was negative at 24 hours, the enriched TSB was streaked onto another chromogenic agar plate with cefoxitin and incubated for 24-48 hours at 35±2℃. Confirmation of presumptive positives colonies from either culture method was performed with a tube coagulase test and Gram stain.

Assay performance of the Xpert MRSA Assay and the 2nd FDA-cleared NAAT test were calculated relative to the central laboratory culture results (reference culture).

Overall Results

A total of 1077 eligible subjects (one specimen per patient) were tested for MRSA by Xpert MRSA Assay, and a 2nd FDA-cleared NAAT test, and culture. 1-74 subjects were determined eligible for inclusion in the analysis. The Xpert MRSA Assay identified 86.3% of the specimens positive for MRSA and 94.9% of the specimens negative for MRSA relative to the reference culture method. For the subjects tested, the positive predictive value was 80.5% and the negative predictive value was 96.6%.

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Culture
+-
+18244226Sensitivity: 86.3%
Xpert MRSA29819848Specificity: 94.9%
2118631074*PPV1: 80.5%
NPV2: 96.6%

Table 5-2A Xpert MRSA Assay Compared to Reference Culture Method

1 Positive predictive value

2 Negative predictive value

When compared to the direct culture method (swabs directly streaked on selective chromogenic agar plates with cefoxitin without TSB enrichment and incubated for 24-48 hours at 35±2℃), Xpert MRSA Assay identified 94.3% of the specimens positive for MRSA and 93.2% of the specimens negative for MRSA; the positive predictive value was 73.0% and the negative predictive value was 98.8%.

Table 5-2B Xpert MRSA Assay Compared to Direct Culture Method

Direct Culture
+-
Xpert MRSA+16561226Sensitivity:94.3%
-10838848Specificity:93.2%
1758991074PPV1:73.0%
NPV2:98.8%

1 Positive predictive value

2 Negative predictive value

Tables 5-3A to 5-3C show the performance of Xpert MRSA Assay at each clinical site compared to the reference culture and direct culture methods.

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Table 5-3A Performance of Xpert MRSA Assay by Site Compared to Reference Culture Method

SiteMRSAprevalence¹Sensitivity (n²) (95% CI)Specificity (n³) (95% CI)No. ofindeterminateresults
120.2% (78/387)87.2% (n=78) (77.7-93.7%)93.9% (n=309) (90.6-96.3%)10
25.2% (3/58)100.0% (n=3) (29.2-100.0%)98.2% (n=55) (90.3-100.0%)3
344.4% (12/27)91.7%(n=12) (61.5-99.8%)100.0%(n=15) (78.2-100.0%)3
412.3% (20/162)80.0% (n=20) (56.3-94.3%)97.2% (n=142) (92.9-99.2%)10
520.5% (46/224)89.1% (n=46) (76.4-96.4%)94.9% (n=178) (90.6-97.7%)1
622.3% (42/188)81.0% (n=42) (65.9-91.4%)93.2% (n=146) (87.8-96.7%)6
735.7% (10/28)90.0% (n=10) (55.5-99.8%)94.4% (n=18) (72.7-99.9%)2
Total19.6%(211/1074)86.3%(n=211) (80.9-90.6%)94.9%(n=863) (93.2-96.3%)32

Determined from results by reference culture method

2Number of positive determined by reference culture method

3Number of negative determined by reference culture method

Table 5-3B

Performance of Xpert MRSA Assay by Site - Comparison between Reference and Direct Culture Method: Sensitivity (95% CI)

Xpert MRSA Sensitivity (95% CI)
SiteReference CultureDirect Culture
187.2% (77.7-93.7%)95.4% (87.1-99.0%)
2100% (29.2-100.0%)100.0% (29.2-100.0%)
391.7% (61.5-99.8%)91.7% (61.5-99.8%)
480.0% (56.3-94.3%)81.3% (54.4-96.0%)
589.1% (76.4-96.4%)94.9% (82.7-99.4%)
681.0% (65.9-91.4%)97.1% (84.7-99.9%)
790.0% (55.5-99.8%)100.0% (54.1-100.0%)
Total86.3% (80.9-90.6%)94.3% (89.7-97.2%)

Xpert MRSA 510(k) Notification February 16, 2007

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SiteXpert MRSA Specificity (95% CI)
Reference CultureDirect Culture
193.9% (90.6-96.3%)92.2% (88.8-94.9%)
298.2% (90.3-100.0%)98.2% (90.3-100.0%)
3100.0% (78.2-100.0%)100.0% (78.2-100.0%)
497.2% (92.9-99.2%)95.2% (90.4-98.1%)
594.9% (90.6-97.7%)93.0% (88.3-96.2%)
693.2% (87.8-96.7%)92.9% (87.6-96.4%)
794.4% (72.7-99.9%)81.8% (59.7-94.8%)
Total94.9% (93.2-96.3%)93.2% (91.4-94.8%)
Table 5-3C Performance of Xpert MRSA Assay by Site - Comparison between
Reference and Direct Culture Method: Specificity (95% CI)

Performances of Xpert MRSA Assay, the 2nd FDA-cleared NAAT and direct culture method from individual sites relative to the reference culture method are presented in Tables 5-4A, 5-4B, and 5-4C.

Table 5-4A Performance of Xpert MRSA Assay, Direct Culture Method and 2nd FDA-cleared NAAT Test with Specimens Positive for MRSA by Reference Culture Method

SiteXpert MRSASensitivity (95% CI)2nd NAATDirect Culture1
187.2% (77.7-93.7%)80.8% (70.3-88.8%)83.3% (73.2-90.8%)
2100.0% (29.2-100.0%)100.0% (29.2-100.0%)100.0% (29.2-100.0%)
391.7% (61.5.-99.8%)83.3% (51.6-97.9%)100.0% (73.5-100.0%)
480.0% (56.3-94.3%)78.9% (54.4-93.9%)80.0% (56.3-94.3%)
589.1% (76.4-96.4%)89.1% (76.4-96.4%)84.8% (71.1-93.7%)
681.0% (65.9-91.4%)78.6%(63.2-89.7%)81.0% (65.9-91.4%)
790.0% (55.5-99.7%)100.0% (69.2-100.0%)60.0% (26.2-87.8%)
Total86.3% (80.9-90.6%)83.3% (77.6-88.1%)82.9% (77.2-87.8%)

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Table 5-4B

Specificity (95% CI)
SiteXpert MRSA2nd NAATDirect Culture1
193.9% (90.6-96.3%)92.2% (88.7-95.0%)100.0% (98.8-100.0%)
298.2% (90.3-100.0%)98.2% (90.3-100.0%)100.0% (93.6-100.0%)
3100.0% (78.2.-100.0%)100.0% (79.4-100.0%)100.0% (79.4-100.0%)
497.2% (92.9-99.2%)97.9% (93.9-99.6%)100.0% (97.5-100.0%)
594.9% (90.6-97.7%)93.8% (89.2-96.9%)100.0% (97.9-100.0%)
693.2% (87.8-96.7%)94.5% (89.5-97.6%)100.0% (97.5-100.0%)
794.4% (72.7-99.9%)94.4% (72.7-99.9%)100.0% (81.5-100.0%)
Total94.9% (93.2-96.3%)94.4% (92.7-95.9%)100.0% (99.6-100.0%)

Performance of Xpert MRSA Assay, Direct Culture Method and 2nd FDA-cleared NAAT Test with Specimens Negative for MRSA by Reference Culture Method

'Swabs directly streaked on selective chromogenic agar plates with cefoxitin and incubated for 24-48 hours at 35+2°C.

Reproducibility

A panel of specimens with varying concentrations of MRSA and MSSE (methicillin sensitive Staphylococcus epidermidis) (negative) were tested in triplicate on 10 different days at each of the three sites (4 specimens x 3 times /day x 10 days x 3 sites). One lot of Xpert MRSA Assay kit was used at each of the 3 testing sites. Xpert MRSA Assays were performed according to the Xpert MRSA Assay package insert procedure. Table 5-5 shows the reproducibility of the assay.

Table 5-5: Summary of Reproducibility Results
Specimen IDMRSA inCFU/swabMSSECFU/swabSite 1Site 2Site 3TotalAgreement% TotalAgreement
Negative02.6 x 10630/3030/3030/31A90/9198.9%
Weak positive1172.6 x 10630/3030/3027/29A87/8997.8%
Positive8002.6 x 10630/3030/3030/3090/90100.0%
Strongpositive2.6 x 1042.6 x 10630/3030/3030/3090/90100.0%
TotalAgreement120/120120/120117/120357/36099.2%
% Agreement100.0%100.0%97.5%

A Xpert MRSA Assay was inadvertently performed on one additional negative specimen and one less weak positive specimen.

Conclusions

The results of the nonclinical analytical and clinical performance studies summarized above demonstrate that the device is as safe, as effective, and performs as well or better than the predicate device.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/9/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle-like symbol with three curved lines representing the body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged in a circular fashion around the symbol.

Public Health Service

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

APR 1 7 2007

Russel K. Enns, Ph.D. Senior Vice Preseident Regulatory, Clinical & Government Affairs, and Quality Systems Cepheid® 904 Caribbean Drive Sunnyvale, CA 94089

  • Re: K070462
    Trade/Device Name: Xpert MRSA Regulation Number: 21 CFR 866.1640 Regulation Name: Antimicrobial Susceptibility Test Powder Regulatory Class: Class II Product Code: NQX Dated: February 16, 2007 Received: February 16, 2007

Dear Dr. Enns:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA), You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Parts 801 and 809); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820).

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This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific information about the application of labeling requirements to your device, or questions on the promotion and advertising of your device, please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (240)276-0450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.

Sincerely yours.

Sally, artin

Sally A. Hojvat, M.Sc., Ph.D. Director Division of Microbiology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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4.0 Indications for Use Statement

510(k) Number (if known): k () 70462

Device Name: Xpert MRSA

Indications for Use: The Cepheid Xpert MRSA Assay performed on the GeneXpert® Dx System (Xpert MRSA) is a qualitative in vitro diagnostic test designed for rapid detection of methicillin-resistant Staphylococcus aureus (MRSA) from nasal swabs in patients at risk for nasal colonization. The test utilizes automated real-time polymerase chain reaction (PCR) to detect MRSA DNA. The Xpert MRSA Assay is intended to aid in the prevention and control of MRSA infections in healthcare settings. The Xpert MRSA Assay is not intended to diagnose MRSA nor to guide or monitor treatment for MRSA infections. Concomitant cultures are necessary only to recover organisms for epidemiological typing or for further susceptibility testing.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Freddie. Poole
Division Sign-Off

Office of In Vitro Diagnostic Device Evaluation and Safety

Xpert MRSA 510(k) Notification February 16, 2007

510(k) K070465

Volume I Page 22

§ 866.1640 Antimicrobial susceptibility test powder.

(a)
Identification. An antimicrobial susceptibility test powder is a device that consists of an antimicrobial drug powder packaged in vials in specified amounts and intended for use in clinical laboratories for determining in vitro susceptibility of bacterial pathogens to these therapeutic agents. Test results are used to determine the antimicrobial agent of choice in the treatment of bacterial diseases.(b)
Classification. Class II (performance standards).