The Reveal LINQ Model LNQ11 Insertable Cardiac Monitors (ICM) is designed to automatically record the occurrence of arrhythmias in a patient. Arrhythmia may be classified as atrial tachyarrhythmia/atrial fibrillation (AT/AF), bradyarrhythmia, pause, or (fast) ventricular tachyarrhythmia. The Reveal LINO ICM provides storage of ECG and Marker Channel during patient-activated and automatically-detected (auto-activated) events. Auto activation may help to detect abnormal heart rhythms in patients who may not activate/trigger the ICM.

The Reveal LINQ ICM Model LNQ11 is a small, leadless device that is typically implanted under the skin, in the chest. Two electrodes on the body of the device continuously monitor the patient's subcutaneous ECG.

AI/ML Overview

The provided text describes a 510(k) premarket notification for the Medtronic Reveal LINQ Insertable Cardiac Monitor (Model LNQ11). The submission details minor firmware changes to enhance atrial and ventricular arrhythmia detection algorithms. The primary purpose of this document is to demonstrate substantial equivalence to a predicate device.

Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:

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

The document broadly states that "The results of the above testing met the specified acceptance criteria and did not raise new safety or performance issues." However, specific quantitative acceptance criteria and corresponding reported device performance metrics are NOT provided in a table format, or explicitly stated otherwise. The text refers to meeting "established performance criteria" and adhering to the ANSI/AAMI EC57:1998 standard for testing cardiac rhythm algorithms, but the actual performance numbers against defined thresholds are not given for direct comparison.

It only mentions the addition of "three rules to reduce false positive detections":

Atrial Algorithms Adaptive P-sense rule
Dual Sense Brady rejection rule
Dual Sense Asystole rejection rule

This indicates an improvement aim, but the metrics of that improvement (e.g., how much false positives were reduced, or what the new sensitivity/specificity values are) are not detailed.

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

The document mentions "Firmware regression testing, design verification, system verification, and system design validation testing." It specifically states that "The validation for the changes to enhance the atrial and ventricular algorithms of the Reveal LINQ ICM firmware was based on the ANSI/AAMI EC57:1998 standard for Testing and Reporting Performance Results of Cardiac Rhythm and ST Segment Measurement Algorithms."

The specific sample sizes (number of patients or ECG recordings) used for the test set for these validations are NOT explicitly stated.

Data provenance (country of origin, retrospective/prospective) is NOT provided. The ANSI/AAMI EC57:1998 standard generally uses standardized ECG databases or collected patient recordings, but the origin of the data used in this specific study is not specified in the provided text.

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

This information is NOT consistently present in the provided text. The document describes a device that automatically detects arrhythmias, and its validation against a standard (ANSI/AAMI EC57:1998). This standard often involves the use of meticulously annotated ECG datasets where ground truth is established by clinical experts. However, the exact number and qualifications of experts involved in establishing the ground truth for the specific test set used by Medtronic for this submission are not detailed.

4. Adjudication method for the test set:

The adjudication method is NOT explicitly stated. If ground truth was established by experts, an adjudication process (e.g., 2+1 majority voting, consensus) would typically be employed, but the document does not describe it.

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 involving human readers is described. The device is an "Insertable Cardiac Monitor" that automatically detects arrhythmias. The study focuses on the device's algorithmic performance against established standards, not on human interpretation or improvement with AI assistance.

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

Yes, a standalone (algorithm only) performance assessment was done. The entire focus of the "Summary of Testing" section is on the performance of the modified firmware (algorithm) in detecting arrhythmias automatically. This includes "Firmware regression testing," "Firmware design verification," and "System level testing" which "ensured that the proposed modifications did not impact the existing system level design inputs" and "confirmed through a combination of test and analysis that the stakeholder needs and intended use continued to be met." The validation was explicitly "based on the ANSI/AAMI EC57:1998 standard for Testing and Reporting Performance Results of Cardiac Rhythm and ST Segment Measurement Algorithms," which is a standard for standalone algorithm performance.

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

While not explicitly stated for this specific study, the ANSI/AAMI EC57:1998 standard typically relies on expert-annotated ECG recordings where ground truth for cardiac rhythm events (e.g., AT/AF, bradyarrhythmia, pause, ventricular tachyarrhythmia) is established. Given the nature of cardiac arrhythmia detection, the ground truth would be based on the precise identification and classification of ECG events.

8. The sample size for the training set:

The sample size for the training set is NOT provided. The submission focuses on changes to existing algorithms and their validation, not on the details of the initial algorithm development and training data.

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

This information is NOT provided. Similar to the training set size, the document does not describe how the ground truth for the training data (if any re-training was performed, or for the original algorithm development) was established.

Summary

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

February 23, 2017

Medtronic, Inc. Syed Mohiuddin Principal Regulatory Affairs Specialist 8200 Coral Sea Street NE Mounds View, Minnesota 55112

Re: K162855

Trade/Device Name: Reveal LINO Insertable Cardiac Monitor (Model LNO11) Regulation Number: 21 CFR 870.1025 Regulation Name: Arrhythmia Detector and Alarm (Including ST-Segment Measurement And Alarm) Regulatory Class: Class II Product Code: DSI Dated: January 20, 2017 Received: January 23, 2017

Dear Syed Mohiuddin:

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. Please note: CDRH does 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.

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely.

Mude Jellim
for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K162855

Device Name

Reveal LINQ Insertable Cardiac Monitor (Model LNQ11)

Indications for Use (Describe)

The Reveal LINQ ICM is an insertable automatically-activated monitoring system that records subcutaneous ECG and is indicated in the following cases:

· Patients with clinical syndromes or situations at increased risk of cardiac arrhythmias

· Patients who experience transient symptoms such as dizziness, palpitation, syncope, and chest pain that may suggest a cardiac arrhythmia

The device has not been tested specifically for pediatric use.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)	☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

[As required by 21 CFR 807.92]
Date Prepared:	October 11, 2016
Submitter:	Medtronic, Inc.Medtronic Cardiac Rhythm Heart Failure8200 Coral Sea Street N.E.Mounds View, MN 55112Establishment Registration Number: 2182208
Contact Person:	Syed Sumran MohiuddinPrincipal Regulatory Affairs SpecialistMedtronic Cardiac Rhythm Heart FailurePhone: 763.526.2380Fax: 651.367.0603Email: syed.s.mohiuddin@medtronic.com
Alternate Contact:	Ryan CalabreseDirector Regulatory AffairsMedtronic Cardiac Rhythm Heart FailurePhone: 763.526.3515Fax: 651.367.0603Email: ryan.s.calabrese@medtronic.com
General Information

Trade Name:	Reveal LINQTM Insertable Cardiac Monitor"*O qf gn'NP S 33+
Common Name:	Insertable Cardiac Monitor
Regulation Number:	CFR 870.1025
Product Code:	DSI
Classification:	Class II
Classification Panel:	Cardiovascular
Special Controls:	Class II Special Controls Guidance Document: Arrhythmia Detector andAlarm
Predicate Devices:	Reveal LINQ Insertable Cardiac Monitor (Model LNQ11) K160809

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Device Description

Indications for Use

There are no changes to the Indications for Use as a result of this submission. The Indications for Use are provided below:

The Reveal LINQ ICM is an insertable automatically-activated and patient-activated monitoring system that records subcutaneous ECG and is indicated in the following cases:

patients with clinical syndromes or situations at increased risk of cardiac arrhythmias
o patients who experience transient symptoms such as dizziness, palpitation, syncope, and chest pain that may suggest a cardiac arrhythmia

The device has not been tested specifically for pediatric use.

Technological Characteristics

The Reyeal LINO ICM consists of three major subassemblies which include the hermetically enclosed battery, hermetically enclosed electronics module, and molded header assembly. The battery is a custom D-shaped cell based on LiCFx chemistry and supports a 12-month shelf life and 3-year usable capacity. The Electronics Module contains the hybrid comprised of a printed circuit board with surface mount components on one side and an over molded stack on the other side which contains analog, digital and memory IC's along with capacitor arrays. The molded Header Assembly contains a Titanium Nitride coated sensing electrode, an embedded miniature RF antenna, suture hole, and a mounting bracket.

The Reveal LINQ ICM will continue to use the same technology. It is designed to automatically record the occurrence of an arrhythmia in a patient, continuously senses the patient's subcutaneous ECG, and analyzes the timing of ventricular events to detect possible episodes of arrhythmia. The Reveal LINQ ICM has a small form factor, and uses Titanium, Parylene, Urethane, and Titanium Nitride coating on the sensing electrodes as body contacting materials.

When compared to the predicate device, the existing Reveal LINO ICM (cleared by FDA under K160809), the Reveal LINQ ICM with modified firmware (subject of this submission) has the same:

Intended use/indications for use ●
. Operating principle
Design features ●

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Device functionality ●
Biological safety
Packaging materials
o Shelf life

When compared to the predicate device, the existing Reveal LINO ICM (cleared by FDA under K160809), the Reveal LINQ ICM with modified firmware (the subject of this submission) differs as follows:

o The Reveal LINQ ICM with modified firmware includes minor changes to enhance its atrial and ventricular arrhythmia detection algorithms by adding three rules to reduce false positive detections listed below:
- Atrial Algorithms Adaptive P-sense rule O
- Dual Sense Brady rejection rule o
- Dual Sense Asystole rejection rule O
The Reveal LINQ ICM with modified firmware includes minor cumulative updates that ● are categorized as under:
- Minor diagnostic updates o
- Minor telemetry updates O
- LINQ RRT update integration O
- Minor bug fixes o

Substantial Equivalence

Technological differences between the subject and predicate devices have been evaluated through bench testing to provide evidence of safe and effective use. The Reveal LINO ICM with modified firmware is substantially equivalent to the predicate device, the existing Reveal LINQ ICM (cleared by FDA under K160809) based on comparisons of device functionality, technological characteristics, and indications for use.

Summary of Testing

Firmware regression testing, design verification, system verification, and system design validation testing were performed to demonstrate that the subject device – the Reveal LINO ICM with modified firmware, met established performance criteria to support equivalency to the referenced predicate device, the existing Reveal LINQ ICM (cleared by FDA under K160809).

. Firmware regression testing: This testing of unchanged firmware was performed to ensure that no unintended side effects were introduced.
Firmware design verification: This testing was made up of two parts: verification of the 0 individual design artifacts (firmware units) associated with the development and release of the firmware; and verification of the finished firmware product (implemented design) to confirm that it meets the associated input requirements.
System level testing: This testing was performed on the subject device the Reveal ● LINQ ICM with modified firmware, which included system verification testing and system validation testing. System design verification ensured that the proposed

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modifications did not impact the existing system level design inputs. System design validation confirmed through a combination of test and analysis that the stakeholder needs and intended use continued to be met by the subject device. The validation for the changes to enhance the atrial and ventricular algorithms of the Reveal LINQ ICM firmware was based on the ANSI/AAMI EC57:1998 standard for Testing and Reporting Performance Results of Cardiac Rhythm and ST Segment Measurement Algorithms.

The following standards and guidance documents were used for development and testing of the subject device:

StandardNumber	StandardOrganization	Standard Title
14971:2012	ISO	Medical Devices - Application of Risk Management to MedicalDevices
62304:2006	IEC EN	Medical device software - Software life-cycle processes
EC57:1998	AANSI/AAMI	Testing and Reporting Performance Results of Cardiac Rhythmand ST Segment Measurement Algorithms
Guidance	FDA	Class II Special Controls Guidance Document: ArrhythmiaDetector and Alarm
Guidance	FDA	Guidance for the Content of Premarket Submissions for SoftwareContained in Medical Devices

Conclusion

The results of the above testing met the specified acceptance criteria and did not raise new safety or performance issues. Therefore, the modifications made to the Reveal LINQ Model LNQ11 Insertable Cardiac Monitor described in this submission result in a device that is substantially equivalent to the predicate.

Regulation Number and Section

§ 870.1025 Arrhythmia detector and alarm (including ST-segment measurement and alarm).

(a)
Identification. The arrhythmia detector and alarm device monitors an electrocardiogram and is designed to produce a visible or audible signal or alarm when atrial or ventricular arrhythmia, such as premature contraction or ventricular fibrillation, occurs.(b)
Classification. Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Arrhythmia Detector and Alarm” will serve as the special control. See § 870.1 for the availability of this guidance document.