(108 days)
The SentiCare PillStation is intended for medical purposes to provide alerts to patients and healthcare providers for pre-determined medication dosing schedules. The device incorporates wireless communication and electronic imaging.
The SentiCare PillStation includes an electronic pillbox for home use (the PillStation), and server software for communicating and programming the PillStation (PillStation Manager Software). The SentiCare PillStation is designed to assist individuals with medication organization, self administration, and adherence. Specifically, the PillStation is designed to aid individuals in medication organization and reconciliation: identify incomplete or inappropriate removal of medications with corrective feedback; teach and coach about medications and daily medical procedures; provide alerts of dose times; and ensure timely relills of all medications self-administration. The SentiCare PillStation is a daily assist device with many features to alert users and caregivers of pre-determined scheduled medication times: easy to use pill tray, pill bins highlighted by light-up indicators, pill alarms, and LCD serven messaging. Through PillStation's built in scanning system, high quality, static digital images are sent from the PillStation to PillStation Manager software. Remote monitors, are other alled "Call Center Advisors", monitor and verify PillStation's medication contents with PillStation users' prescriptions in order to keep track of medication aterts and verify that the user and/or caregiver has loaded their prescribed medications into the PillStation pill tray. This monitoring is accomplished through the PillStation Manager software. The SentiCare PillStation is a novel approach to medication organization and may be of great assistance to those individuals and caregivers who look to improve upon their own medication organization, adherence, and self administration.
The SentiCare PillStation is a daily activity assist device (medication reminder). The 510(k) summary states that "Applicable tests were carried out as part of the software design process, where the key functions of the SentiCare PillStation (including both the PillStation and the PillStation Manager software) were verified and/or validated. The results of the testing met specifications, and established the device as safe and effective for its intended use, which is comparable to other predicate devices."
However, specific acceptance criteria and detailed study results beyond this general statement are not provided in the 510(k) document. The document primarily focuses on demonstrating substantial equivalence to predicate devices based on intended use and technological characteristics, particularly highlighting the unique feature of imaging the pill tray contents.
Therefore, many of the requested details about acceptance criteria, specific performance metrics, sample sizes, expert involvement, and ground truth establishment are not available in the provided text.
Here is what can be extracted and what information is missing:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| (Not explicitly stated in the provided text, but implied as meeting specifications for key functions) | "The results of the testing met specifications, and established the device as safe and effective for its intended use, which is comparable to other predicate devices." |
| (Specific quantitative criteria for medication organization, reconciliation, identification of incomplete/inappropriate removal, corrective feedback, teaching/coaching, alerts, timely refills, and accurate imaging/upload of contents are not provided) | The device is designed to aid in these areas, and testing validated its key functions. The capability to image pill tray contents and upload to a central server was a key functionality tested. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample size: Not specified.
- Data provenance: Not specified (e.g., country of origin, retrospective or prospective).
3. 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)
- Not specified. The document indicates that "Remote monitors, are other alled 'Call Center Advisors', monitor and verify PillStation's medication contents with PillStation users' prescriptions." These 'Call Center Advisors' might be considered the "experts" in the context of the device's function, but their number and specific qualifications are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not specified. The text mentions "Remote monitors... monitor and verify PillStation's medication contents," which implies a form of verification, but no specific adjudication method (like 2+1) is described.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No MRMC comparative effectiveness study is mentioned. The device's primary function is to assist users and caregivers, with "Call Center Advisors" monitoring. The document does not describe a study comparing human performance with and without AI assistance for tasks like image recognition, as the device itself does not perform image recognition.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- The device's core functionality involves imaging and uploading data, which is then monitored by human "Call Center Advisors." The 510(k) explicitly states: "the SentiCare PillStation does not perform image recognition or prohibit access to medications stored in the device." Therefore, a standalone algorithm-only performance study for image recognition would not be applicable, as that is not a function the device performs autonomously. The "standalone" testing described is of the system's "key functions" meeting specifications.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- The ground truth for verifying medication contents appears to be the user's prescriptions, as verified by "Call Center Advisors." The document states they "monitor and verify PillStation's medication contents with PillStation users' prescriptions."
8. The sample size for the training set
- Not applicable/Not specified. This is not a machine learning device that requires a distinct "training set" in the conventional sense. The testing described is performance validation of software and hardware functions.
9. How the ground truth for the training set was established
- Not applicable/Not specified, as there is no mention of a training set for a machine learning model.
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K103009
JAN 28 2011
510(k) Summary
| Submitted by | SentiCare, Inc. |
|---|---|
| Address: | 132 Turnpike Road, Suite 130Southborough, MA 01772 |
| Telephone: | 508-875-2401 |
| Facsimile: | 508-875-2404 |
| Contact Name: | Yogendra Jain, Chief Technical Officer / Co-founder |
| Date Submitted: | January 18, 2011 |
| Trade Name: | SentiCare PillStation |
| Common Name: | Medication reminder |
Product Code / Regulation: 21 C.F.R. 890.5050, Daily Activity Assist Device (Medication Reminder), product code NXQ, class I
Description: The SentiCare PillStation includes an electronic pillbox for home use (the PillStation), and server software for communicating and programming the PillStation (PillStation Manager Software). The SentiCare PillStation is designed to assist individuals with medication organization, self administration, and adherence. Specifically, the PillStation is designed to aid individuals in medication organization and reconciliation: identify incomplete or inappropriate removal of medications with corrective feedback; teach and coach about medications and daily medical procedures; provide alerts of dose times; and ensure timely relills of all medications self-administration. The SentiCare PillStation is a daily assist device with many features to alert users and caregivers of pre-determined scheduled medication times: easy to use pill tray, pill bins highlighted by light-up indicators, pill alarms, and LCD serven messaging. Through PillStation's built in scanning system, high quality, static digital images are sent from the PillStation to PillStation Manager software. Remote monitors, are other alled "Call Center Advisors", monitor and verify PillStation's medication contents with PillStation users' prescriptions in order to keep track of medication aterts and verify that the user and/or caregiver has loaded their prescribed medications into the PillStation pill tray. This monitoring is accomplished through the PillStation Manager software. The SentiCare PillStation is a novel approach to medication organization and may be of great assistance to those individuals and caregivers who look to improve upon their own medication organization, adherence, and self administration.
- Intended Use: The SentiCare PillStation is intended for medical purposes to provide alerts to patients and healtheare providers for pre-determined medication dosing schedules. The device incorporates wireless communication and electronic imaging.
- The SentiCare PillStation is similar in intended use and Substantial Equivalence: technological characteristics to predicate devices reviewed as
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medication reminders (Daily Activity Assist Devices), including the Vocel Pill Phone (K060298), and the e-piller 4 Alarm Vibrating Pill Box (510(k) exempt).
The capability of the SentiCare PillStation to image the contents of the pill tray and upload the information through the Internet 10 a central server was determined by the FDA to introduce a different fundamental technology requiring the submission of a 510(k). Despite the introduction of this technology into the device, the SentiCare PillStation does not perform image recognition or prohibit access to medications stored in the device. Apart from the additional capability to scan the contents of the pill tray, the SentiCare PillStation is otherwise similar with respect to indications for use and physical characteristics to predicate devices in terms of $10(k) substantial equivalency.
Applicable tests were carried out as part of the software design process, where the key functions of the SentiCare PillStation (including both the PillStation and the PillStation Manager software) were verified and/or validated. The results of the testing met specifications, and established the device as safe and effective for its intended use, which is comparable to other predicate devices.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle or bird-like symbol with three curved lines representing its wings or feathers. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
SentiCare, Incorporated C/O Mr. Seth A. Mailhot Nixon Peabody LLP 401 9th Street NW, Suite 900 Washington, District of Columbia 20004
JAN 2 8 25th
Re: K103009
Trade/Device Name: SentiCare PillStation Regulation Number: 21 CFR 890.5050 Regulation Name: Daily Activity Assist Device Regulatory Class: I Product Code: NXQ Dated: January 18, 2011 Received: January 19, 2011
Dear Mr. Mailhot:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equival nt five 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. Please note: CDRH, not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register. and the control control of the control of
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Page 2- Mr. Mailhot
Enclosure
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 Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 33) -542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ur.v 115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go no http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/ default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Jam 2. Kasia
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
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Indications for Use
510(k) Number (if known): ________________
Device Name: SentiCare PillStation
Intended Use:
The SentiCare PillStation is intended for medical purposes to provide alerts to patients and healthcare providers for pre-determined medication dosing schedules. The device incorporates wireless communication and electronic imaging.
Prescription Use __ X (Part 21 CFR 801 Subpart D)
WE STATE AND WANT OF COLLECT AND A LA COLLECT COLLECTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULTION CONSULT
AND/OR
Over-The-Counter Use __ X (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Rich C. Chapman 1/26/16
Page 1 of 1
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: K103009
§ 890.5050 Daily activity assist device.
(a)
Identification. A daily activity assist device is a modified adaptor or utensil (e.g., a dressing, grooming, recreational activity, transfer, eating, or homemaking aid) that is intended for medical purposes to assist a patient to perform a specific function.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 890.9. If the device is not labeled or otherwise represented as sterile, the device is also exempt from the current good manufacturing practice requirements of the quality system regulation in part 820 of this chapter, with the exception of § 820.180, regarding general requirements concerning records and § 820.198, regarding complaint files.