(56 days)
No reference devices were used in this submission.
Yes
The device description explicitly states that one of its modules uses "machine learning algorithms (ML) to provide an initial segmentation".
No
The device aids in creating and modifying contours for radiation treatment planning, but it does not directly administer therapy or provide a therapeutic effect itself. It is a software tool used in the planning stage, not the treatment stage.
No
The device is intended to assist in radiotherapy treatment planning by providing tools for contouring tumors and healthy structures, but it explicitly states that images reviewed using the software "should not be used for primary image interpretations." This indicates it's a planning and assistance tool, not a device for diagnosing medical conditions.
Yes
The device description explicitly states "Microsoft Radiomics App v1.0 is a software-only medical device". The description focuses solely on software functionalities and algorithms for image processing and contouring, with no mention of accompanying hardware components.
Based on the provided text, the Microsoft Radiomics App v1.0 is not an IVD (In Vitro Diagnostic) device.
Here's why:
- IVD devices are used to examine specimens derived from the human body. The Radiomics App works with medical images (CT and MR scans) of the patient's body, not with biological samples like blood, urine, or tissue.
- The intended use is for radiation treatment planning. The software assists in contouring organs and tumors on medical images to help radiation oncologists, dosimetrists, and physicists plan radiation therapy. This is a clinical application focused on treatment planning based on imaging data, not on diagnosing or monitoring a condition through the analysis of biological specimens.
- The device description focuses on image processing and segmentation. The core function is to process and delineate structures within medical images.
Therefore, the Microsoft Radiomics App v1.0 falls under the category of a medical image processing or analysis software device used for treatment planning, not an In Vitro Diagnostic device.
No
The input explicitly states "Control Plan Authorized (PCCP) and relevant text: Not Found", indicating that the letter does not mention FDA review or approval of a PCCP for this device.
Intended Use / Indications for Use
Microsoft Radiomics App v1.0 is a software-only medical device intended for use by trained radiation oncologists, dosimetrists and physicists to derive optimal organ and tumor contours for input to radiation treatment planning. Supported image modalities are Computed Tomography and Magnetic Resonance. Radiomics App assists in the following scenarios:
· Load, save and display of medical images and contours for treatment evaluation and treatment planning.
· Creation, transformation, and modification of contours for applications including, but not limited to: transferring contours to radiotherapy treatment planning systems, aiding adaptive therapy, and archiving contours for patient followup.
· Localization and definition of both solid tumors and healthy anatomical structures.
- · Fusion display of compatible images for treatment planning.
· Three-dimensional rendering of medical images and the segmented contours.
Images reviewed using the Radiomics App software should not be used for primary image interpretations. Radiomics App is not for use with digital mammography.
Product codes
LLZ
Device Description
Microsoft Radiomics App v1.0 is a software-only medical device intended for use by trained radiation oncologists, dosimetrists and medical physicists for radiation treatment planning.
Radiomics App stems from more than eight years of research in computerized medical image analysis, computer vision and machine learning. It applies well tested, state-of-the-art algorithms for the assisted delineation of anatomical structures of interest in three-dimensional, clinical radiological scans.
Radiomics App works on computed tomography (CT) and magnetic resonance (MR) scans, and is designed to contour/delineate both healthy anatomical structures as well as lesions such as solid tumors.
Radiomics App integrates into the clinical data network of radiation therapy treatment centers, receiving data from imaging devices such as CT and MR scanners. The purpose of the tool is to assist the expert user in producing segmentations (three-dimensional contours) of anatomical structures, for both solid tumors and healthy tissue structures. The following segmentation tools are provided:
- Assisted Contouring. This module allows for the manual, user-guided segmentation of . structures of interest in both CT and MR images.
- . Machine-learning based contouring. This module uses machine learning algorithms (ML) to provide an initial segmentation of certain structures of interest automatically. The user has the option to accept this initial segmentation or edit and refine it.
- . Contour refinement. This module allows the user to edit and improve segmentations created by either the machine learning or the assisted contouring algorithms.
These segmentations are then exported back into the clinical data network, and subsequently utilized in a radiotherapy treatment planning system to generate a treatment plan for a patient.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Yes
Input Imaging Modality
Computed Tomography and Magnetic Resonance
Anatomical Site
Not Found
Indicated Patient Age Range
Not Found
Intended User / Care Setting
trained radiation oncologists, dosimetrists and physicists
Description of the training set, sample size, data source, and annotation protocol
Not Found
Description of the test set, sample size, data source, and annotation protocol
Not Found
Summary of Performance Studies
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a moderate level of concern.
Verification Testing: Two different types of verification testing were conducted to verify the software requirements: Manual and Automated. All tests passed, demonstrating that the software performance is in accordance with the stated software requirements.
Validation Testing: Validation testing of the following functions of the Radiomics App demonstrated that the software meets user needs and intended uses and to support substantial equivalence:
- Measurements - Validation Test
- Volumetric Rendering - Validation Test
- Multi-Planar Reconstruction Validation Test ●
- Assisted Contouring Validation Test ●
- Automatic Contouring - Validation Test
Key Metrics
Not Found
Predicate Device(s)
Reference Device(s)
No reference devices were used in this submission.
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
0
December 27, 2017
Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
Microsoft Corp. % Donna-Bea Tillman, Ph.D. Senior Consultant Biologics Consulting Group, Inc. 1555 King Street. Suite 300 ALEXANDRIA VA 22314
Re: K173420
Trade/Device Name: Radiomics App v1.0 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: II Product Code: LLZ Dated: October 31, 2017 Received: November 1, 2017
Dear Dr. Tillman:
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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in 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.
1
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and
Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Michael D. O'Hara For
Robert Ochs, Ph.D. Director Division of Radiological Health Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known) K173420
Device Name Radiomics App v1.0
Indications for Use (Describe)
Microsoft Radiomics App v1.0 is a software-only medical device intended for use by trained radiation oncologists, dosimetrists and physicists to derive optimal organ and tumor contours for input to radiation treatment planning. Supported image modalities are Computed Tomography and Magnetic Resonance. Radiomics App assists in the following scenarios:
· Load, save and display of medical images and contours for treatment evaluation and treatment planning.
· Creation, transformation, and modification of contours for applications including, but not limited to: transferring contours to radiotherapy treatment planning systems, aiding adaptive therapy, and archiving contours for patient followup.
· Localization and definition of both solid tumors and healthy anatomical structures.
- · Fusion display of compatible images for treatment planning.
· Three-dimensional rendering of medical images and the segmented contours.
Images reviewed using the Radiomics App software should not be used for primary image interpretations. Radiomics App is not for use with digital mammography.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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3
510(K) SUMMARY
1. SUBMITTER
| Submitter: | Microsoft Corp
1 Microsoft Way
Redmond, WA 98052
Phone: 425-538-9419 |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Ivan Tarapov
Ivan.Tarapov@microsoft.com |
| Submission Correspondent: | Donna-Bea Tillman, Ph.D, MPA
Biologics Consulting Group, Inc.
1555 King Street, Suite 300
Alexandria, VA 22314
Phone: 410-531-6542
dtillman@biologicsconsulting.com |
| Date Prepared: | October 31, 2017 |
2. DEVICE
| Name of Device: | Radiomics App v1.0 |
|---|---|
| Common or Usual Name: | Radiological Image Processing System |
| Classification Name: | Picture Archiving and Communications System |
| 21 CFR 892.2050 | |
| Regulatory Class: | Class II |
| Product Code: | LLZ |
3. PREDICATE DEVICE
| Predicate Device Name: | MIM 5.2 (BRACHY) |
|---|---|
| Manufacturer: | MIM Software Inc. |
| 510(k) Number: | K103576 |
| Reference Devices: | No reference devices were used in this submission. |
DEVICE DESCRIPTION 4.
Microsoft Radiomics App v1.0 is a software-only medical device intended for use by trained radiation oncologists, dosimetrists and medical physicists for radiation treatment planning.
Radiomics App stems from more than eight years of research in computerized medical image analysis, computer vision and machine learning. It applies well tested, state-of-the-art algorithms for the assisted delineation of anatomical structures of interest in three-dimensional, clinical radiological scans.
Radiomics App works on computed tomography (CT) and magnetic resonance (MR) scans, and is designed to contour/delineate both healthy anatomical structures as well as lesions such as solid tumors.
4
Radiomics App integrates into the clinical data network of radiation therapy treatment centers, receiving data from imaging devices such as CT and MR scanners. The purpose of the tool is to assist the expert user in producing segmentations (three-dimensional contours) of anatomical structures, for both solid tumors and healthy tissue structures. The following segmentation tools are provided:
- Assisted Contouring. This module allows for the manual, user-guided segmentation of . structures of interest in both CT and MR images.
- . Machine-learning based contouring. This module uses machine learning algorithms (ML) to provide an initial segmentation of certain structures of interest automatically. The user has the option to accept this initial segmentation or edit and refine it.
- . Contour refinement. This module allows the user to edit and improve segmentations created by either the machine learning or the assisted contouring algorithms.
These segmentations are then exported back into the clinical data network, and subsequently utilized in a radiotherapy treatment planning system to generate a treatment plan for a patient.
ട്. INDICATION FOR USE
Microsoft Radiomics App v1.0 is a software-only medical device intended for use by trained radiation oncologists, dosimetrists and physicists to derive optimal organ and tumor contours for input to radiation treatment planning. Supported image modalities are Computed Tomography and Magnetic Resonance. Radiomics App assists in the following scenarios:
- Load, save and display of medical images and contours for treatment evaluation and treatment planning.
- . Creation, transformation, and modification of contours for applications including, but not limited to: transferring contours to radiotherapy treatment planning systems, aiding adaptive therapy, and archiving contours for patient follow-up.
- Localization and definition of both solid tumors and healthy anatomical structures.
- . Fusion display of compatible images for treatment planning.
- Three-dimensional rendering of medical images and the segmented contours.
Images reviewed using the Radiomics App software should not be used for primary image interpretations.
Radiomics App is not for use with digital mammography.
Comparison of Indications for Use
Both devices are only intended for use by trained medical professionals. As noted below, both devices are intended for use during radiation therapy planning. The subject device supports a subset of the image modalities supported by the predicate device. Both devices accept DICOM images generated elsewhere as inputs. Both devices provide the user with tools to contour medical images for use in radiation therapy planning and patient follow-up. Both devices can be used to localize and define normal tissues as well as solid tumors. Both devices support the fusion of different image modalities. Both devices provide three-dimensional image rendering. The subject device is not intended for primary image interpretation or for use with digital mammography. This is a subset of the indications of the predicate device.
5
The minor differences in indications of use between the subject Radiomics App and the predicate MIM software do not constitute a different intended use.
COMPARISON OF TECHNOLOGICAL CHARACTERISTICS 6. WITH THE PREDICATE DEVICE
| Proposed Device | Predicate Device | |
|---|---|---|
| 510(k) Number | TBD | K103576 |
| Applicant | Microsoft | MIM Software |
| Device Name | Radiomics App | MIM 5.2 |
| Classification | ||
| Regulation | 892.2050 - Picture Archiving and | |
| Communication System | 892.2050 – Picture Archiving and | |
| Communication System | ||
| Product Code | LLZ | LLZ |
| Indications for Use | Microsoft Radiomics Advanced | |
| Image Contouring v1.0 (Radiomics | ||
| App) is a software-only medical | ||
| device intended for use by trained | ||
| radiation oncologists, dosimetrists | ||
| and physicists to derive optimal organ | ||
| and tumor contours for input to | ||
| radiation treatment planning. | ||
| Supported image modalities are | ||
| Computed Tomography and Magnetic | ||
| Resonance. Radiomics App assists in | ||
| the following scenarios: | ||
| Load, save and display of medical | ||
| images and contours for treatment | ||
| evaluation and treatment planning. | ||
| Creation, transformation, and | ||
| modification of contours for | ||
| applications including, but not limited | ||
| to: transferring contours to | ||
| radiotherapy treatment planning | ||
| systems, aiding adaptive therapy, and | ||
| archiving contours for patient follow- | ||
| up. | ||
| Localization and definition of both | ||
| solid tumors and healthy anatomical | ||
| structures. | ||
| Fusion display of compatible images | ||
| for treatment planning. | ||
| Three-dimensional rendering of | ||
| medical images and the segmented | ||
| contours. | ||
| Images reviewed using the Radiomics | MIM 5.2 software is used by trained | |
| medical professionals as a tool to aid in | ||
| evaluation and information management | ||
| of digital medical images. The medical | ||
| image modalities include, but are not | ||
| limited to, CT, MRI, CR, DX, MG, US, | ||
| SPECT, PET and XA as supported by | ||
| ACRINEMA DICOM 3.0. MIM 5.2 | ||
| assists in the following indications | ||
| Receive, transmit, store, retrieve, display, | ||
| print, and process medical images and | ||
| DICOM objects. | ||
| Create, display and print reports from | ||
| medical images. | ||
| Registration, fusion display, and review | ||
| of medical images for diagnosis, | ||
| treatment evaluation, and treatment | ||
| planning. | ||
| Evaluation of cardiac left ventricular | ||
| function and perfusion, including left | ||
| ventricular end-diastolic volume, end- | ||
| systolic volume, and ejection fraction. | ||
| Localization and definition of objects | ||
| such as tumors and normal tissues in | ||
| medical images. | ||
| Creation, transformation, and | ||
| modification of contours for applications | ||
| including, but not limited to, quantitative | ||
| analysis, aiding adaptive therapy, | ||
| transferring contours to radiation therapy | ||
| treatment planning systems, and | ||
| archiving contours for patient follow-up. | ||
| Proposed Device | Predicate Device | |
| App software should not be used for | ||
| primary image interpretations. | ||
| Radiomics App is not for use with | ||
| digital mammography. | and management. | |
| Quantitative and statistical analysis of | ||
| PET/SPECT brain scans by comparing to | ||
| other registered PET/SPECT brain scans. | ||
| Planning and evaluation of permanent | ||
| implant brachytherapy procedures. | ||
| Lossy compressed mammographic | ||
| images and digitized film screen images | ||
| must not be reviewed for primary image | ||
| interpretations. Images that are printed to | ||
| film must be printed using a FDA- | ||
| approved printer for the diagnosis of | ||
| digital mammography images. | ||
| Mammographic images must be viewed | ||
| on a display system that has been cleared | ||
| by the FDA for the diagnosis of digital | ||
| mammography images. The software is | ||
| not to be used for mammography CAD. | ||
| Intended users | Healthcare providers | Healthcare providers |
| Contouring modes | Assisted and automatic | Assisted and automatic |
| Types of tissue | ||
| contoured | Tumors and normal tissues | Tumors and normal tissues |
| Measurements | 2D distance measurement, average | |
| tissue density within a region (for | ||
| CT), segmentation volume | 2D distance measurement, segmentation | |
| volume, average tissue density within a | ||
| region (for CT) | ||
| Image Fusion | Fuse only two 3D images, CT and | |
| MR | Fuse medical images from multiple | |
| modalities | ||
| 3D image | ||
| rendering | Yes | Yes |
| Cardiac | ||
| applications | No | Yes |
| Dose visualization | ||
| and manipulation | No | Yes |
| Image modalities | CT and MR | CT, MRI, CR, DX, MG, US, SPECT, |
| PET and XA | ||
| Platform | Stand-alone package which operates | |
| on Microsoft Windows operating | ||
| systems only. | Stand-alone package which operates on | |
| both Windows and Mac computer | ||
| systems. |
The table below provides a side-by-same comparison of the technological characteristics of the proposed Radiomics App and the predicate MIM Software.
6
7. PERFORMANCE DATA
The following performance data were provided in support of the substantial equivalence determination.
Biocompatibility
7
The subject device is a software-only device. There are no direct patient-contacting components of the subject device. Therefore, patient contact information is not needed for this device.
Electrical Safety and electromagnetic compatibility (EMC)
Not applicable. The subject device is a software-only device. It contains no electric components, generates no electrical emissions, and uses no electrical energy of any type.
Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a moderate level of concern.
Verification Testing
Two different types of verification testing were conducted to verify the software requirements: Manual and Automated. All tests passed, demonstrating that the software performance is in accordance with the stated software requirements.
Validation Testing
Validation testing of the following functions of the Radiomics App demonstrated that the software meets user needs and intended uses and to support substantial equivalence:
- Measurements - Validation Test
- Volumetric Rendering - Validation Test
- Multi-Planar Reconstruction Validation Test ●
- Assisted Contouring Validation Test ●
- Automatic Contouring - Validation Test
Animal Study
Not applicable. Animal studies are not necessary to establish the substantial equivalence of this device.
Clinical Study
Not applicable. Clinical studies are not necessary to establish the substantial equivalence of this device.
CONCLUSIONS 8.
The minor differences in indications of use between the subject Radiomics App and the predicate MIM software do not constitute a different intended use. The technological characteristics of the Radiomics App are similar to those of the MIM Software, with the biggest differences being that the Radiomics App offers a subset of the features provided by the MIM software. Results of software verification and validation testing demonstrate that the Radiomics App performs in accordance with specifications and that the performance is comparable to that of the predicate device. Therefore, the Radiomics App can be found to be substantially equivalent to the predicate MIM Software.