(521 days)
The Visby Medical Sexual Health Click Test is a single-use (disposable), fully-integrated, automated Polymerase Chain Reaction (PCR) in vitro diagnostic test intended for use in point of-care or clinical laboratory settings for the rapid detection and differentiation of DNA from Chlamydia trachomatis, Neisseria gonorrhoeae, and Trichomonas vaginalis in seff-collected female vaginal swab specimens using the Visby Medical Sexual Health Vaginal Specimen Collection Kit in a health care setting. The test results are to aid in the diagnosis of symptomatic infections with Chlamydia trachomatis, Neisseria gonorrhoeae, and Trichomonas vaginalis.
The test system includes the Visby Medical Sexual Health Click device, the Visby Medical power supply, the Visby Medical Vaginal Collection kit, and fixed-volume transfer pipettes. The device processes a vaginal swab sample by automatically performing all steps required to complete lysis, polymerase chain reaction, and amplicon detection.
The patient uses the Visby Medical Vaginal Collection Kit to self-collect a vaginal specimen with the provided flocked swab, and then the patient elutes the specimen into the Visby Medical Collection Media. The test operator transfers the collection media containing the patient specimen into the sample port of the device using the provided fixed-volume pipette where it rehydrates a lyophilized internal process control. The sample enters a lysis module, where the DNA of the sample and the internal process control are extracted using a combination of chemical lysis and high temperature. The extracted DNA enters a mixing chamber where it rehydrated lyophilized PCR reagents, followed by thermocycling to amplify target DNA. If present, the amplified pathogen target (CT, NG, and/or TV) and internal process control hybridize to specific probes located on a flow channel. Detection of the target-specific PCR product is accomplished via an enzyme-linked colorimetric assay using streptavidin bound horseradish peroxidase (HRP) and a colorimetric substrate that forms a purple precipitate. Test results can be expected in approximately 30 minutes: a green check mark will appear, and a purple color will appear in the "Control" spot, indicating a valid test. A purple spot adjacent to "Chlamydia," "Gonorrhoeae," and/or "Trichomonas" signifies the presence of amplified CT, NG, and/or TV DNA in the sample. Tests with invalid results due to an error (indicated by a red X status light) or failure to develop a purple spot in the "Control" spot, are retested with a new Visby device.
The Visby Medical Sexual Health Click Test is an automated Polymerase Chain Reaction (PCR) in vitro diagnostic test for the rapid detection and differentiation of DNA from Chlamydia trachomatis (CT), Neisseria gonorrhoeae (NG), and Trichomonas vaginalis (TV) in self-collected female vaginal swab specimens.
Here's an analysis of its acceptance criteria and the study that proves its performance:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly defined by the clinical performance observed in the study, aiming for high sensitivity and specificity. The reported device performance is based on the achieved Positive Percent Agreement (PPA) and Negative Percent Agreement (NPA) or Sensitivity and Specificity against a Composite Comparator Result (CCR) or Patient Infected Status (PIS).
| Target Organism | Performance Metric | Acceptance Criteria (Implicit) | Reported Device Performance (95% CI) |
|---|---|---|---|
| Chlamydia trachomatis (CT) | Overall PPA | High (e.g., >90%) | 97.4% (93.5-99.0%) |
| Overall NPA | High (e.g., >90%) | 97.8% (96.9-98.4%) | |
| Neisseria gonorrhoeae (NG) | Overall PPA | High (e.g., >90%) | 97.8% (88.4-99.6%) |
| Overall NPA | High (e.g., >90%) | 99.1% (98.5-99.4%) | |
| Trichomonas vaginalis (TV) | Overall Sensitivity | High (e.g., >90%) | 99.3% (96.0-99.9%) |
| Overall Specificity | High (e.g., >90%) | 96.7% (95.8-97.5%) |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size:
- CT: 1774 subjects
- NG: 1786 subjects
- TV: 1765 subjects
- Initially, 1899 subjects were enrolled, 1881 were eligible, and 1789 were included in the data analysis.
- Data Provenance: The study was conducted at 14 clinical sites geographically distributed across the United States. The study subjects were prospectively enrolled females.
3. Number of Experts Used to Establish Ground Truth and Their Qualifications
- The document does not specify the number of experts explicitly used to establish the ground truth.
- The ground truth was established by a Composite Comparator Result (CCR) for CT and NG, and a Patient Infected Status (PIS) algorithm for TV, which were comprised of three FDA-cleared NAAT assays.
- The qualifications of the individuals interpreting the results of these FDA-cleared NAAT assays are not explicitly stated, but it can be inferred that they would be trained laboratory personnel given the nature of NAAT testing.
4. Adjudication Method for the Test Set
- Adjudication Method: For all three organisms (CT, NG, TV), the ground truth (CCR/PIS) was determined as follows:
- A study participant was considered infected if a positive result was reported from two of the three FDA-cleared NAAT tests.
- If the test results of the first two NAATs were discordant (one positive, one negative), the CCR/PIS was determined by the third NAAT. This is often referred to as a "2 out of 3" or "tie-breaker" adjudication method.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No MRMC comparative effectiveness study was done in the context of human readers improving with or without AI assistance. This device is a fully-automated in vitro diagnostic test, and the clinical study evaluated the device's performance directly against a laboratory-based ground truth, not human reader performance.
- However, a reproducibility study was conducted with "untrained users" (non-laboratorians) in CLIA waived settings, to assess the device's performance when used by typical healthcare professionals in such environments. This indirectly assesses the device's usability and reliability in a real-world setting where "human readers" (the operators) process samples and interpret simple visual results (green check mark for valid, purple spots for positive). The study demonstrated robust reproducibility and that untrained users could perform and interpret results accurately, but it wasn't a comparative effectiveness study of human reader improvement.
6. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop Performance)
- Yes, the clinical performance described in section H is a standalone performance study (device only without human-in-the-loop performance influencing the result generation). The device processes a vaginal swab sample fully-integrated and automatically, performing lysis, PCR, and amplicon detection, and then provides a visual result (a green check mark for valid and purple spots for positive). The study evaluated how this automated device's results compared to the established ground truth.
- While human operators handled the samples and initiated the test, the test interpretation is designed to be straightforward and automatic (visual detection of colored spots), making the clinical performance metrics largely reflective of the algorithm's standalone capability to detect the presence of pathogens. The reproducibility study explicitly confirmed that "untrained users can perform the test and interpret the results accurately."
7. Type of Ground Truth Used
- The ground truth used was a Composite Comparator Result (CCR) for CT and NG, and a Patient Infected Status (PIS) algorithm for TV.
- This ground truth was derived from the results of three FDA-cleared NAAT (Nucleic Acid Amplification Test) assays. This is a common and robust method for establishing ground truth in molecular diagnostics, as NAATs are highly sensitive and specific.
8. Sample Size for the Training Set
- The document focuses on the validation of the device through non-clinical and clinical studies. It does not specify the sample size for a training set.
- As an in vitro diagnostic (IVD) device, its development likely involves extensive internal optimization and testing (which could be considered analogous to "training" in the context of AI/ML, though this device is PCR-based with colorimetric detection, not explicitly a machine learning algorithm) using characterized samples and analytical performance studies (Limit of Detection, Inclusivity, Cross-Reactivity, etc.). These analytical studies serve as a rigorous "training" and development phase, but specific "training set sizes" as might be reported for a machine learning model are not applicable or provided here.
9. How the Ground Truth for the Training Set Was Established
- Since a specific "training set" with established ground truth as in AI/ML model development is not explicitly mentioned or applicable to this type of PCR-based diagnostic, this question cannot be directly answered from the provided text.
- However, the analytical studies (LoD, Inclusivity, Cross-Reactivity, Competitive Interference, Interfering Substances, Reproducibility) described in section G involve using well-characterized organisms (known strains/serovars with specified concentrations) spiked into negative clinical vaginal sample matrix. The "ground truth" for these analytical samples is the known presence/absence and concentration of the spiked organisms. This rigorous analytical characterization serves to ensure the robust performance of the assay.
§ 866.3393 Device to detect nucleic acids from non-viral microorganism(s) causing sexually transmitted infections and associated resistance marker(s).
(a)
Identification. A device to detect nucleic acids from non-viral microorganism(s) causing sexually transmitted infections and associated resistance marker(s) is an in vitro diagnostic device intended for the detection and identification of nucleic acids from non-viral microorganism(s) and their associated resistance markers in clinical specimens collected from patients suspected of sexually transmitted infections. The device is intended to aid in the diagnosis of non-viral sexually transmitted infections in conjunction with other clinical and laboratory data. These devices do not provide confirmation of antibiotic susceptibility since mechanisms of resistance may exist that are not detected by the device.(b)
Classification. Class II (special controls). The special controls for this device are:(1) The intended use for the labeling required under § 809.10 of this chapter must include a detailed description of targets the device detects, the results provided to the user, the clinical indications appropriate for test use, and the specific population(s) for which the device is intended.
(2) Any sample collection device used must be FDA-cleared, -approved, or -classified as 510(k) exempt (standalone or as part of a test system) for the collection of specimen types claimed by this device; alternatively, the sample collection device must be cleared in a premarket submission as a part of this device.
(3) The labeling required under § 809.10(b) of this chapter must include:
(i) A detailed device description, including reagents, instruments, ancillary materials, all control elements, and a detailed explanation of the methodology, including all pre-analytical methods for processing of specimens;
(ii) Detailed discussion of the performance characteristics of the device for all claimed specimen types based on analytical studies, including Limit of Detection, inclusivity, cross-reactivity, interfering substances, competitive inhibition, carryover/cross contamination, specimen stability, within lab precision, and reproducibility, as appropriate;
(iii) Detailed descriptions of the test procedure, the interpretation of test results for clinical specimens, and acceptance criteria for any quality control testing;
(iv) Limiting statements indicating that:
(A) A negative test result does not preclude the possibility of infection;
(B) The test results should be interpreted in conjunction with other clinical and laboratory data available to the clinician;
(C) Reliable results are dependent on adequate specimen collection, transport, storage, and processing. Failure to observe proper procedures in any one of these steps can lead to incorrect results; and
(D) If appropriate (
e.g., recommended by the Centers for Disease Control and Prevention, by current well-accepted clinical guidelines, or by published peer reviewed research), that the clinical performance is inferior in a specific clinical subpopulation or for a specific claimed specimen type; and(v) If the device is intended to detect antimicrobial resistance markers, limiting statements, as appropriate, indicating that:
(A) Negative results for claimed resistance markers do not indicate susceptibility of detected microorganisms, as resistance markers not measured by the assay or other potential mechanisms of antibiotic resistance may be present;
(B) Detection of resistance markers cannot be definitively linked to specific microorganisms and the source of a detected resistance marker may be an organism not detected by the assay, including colonizing flora;
(C) Detection of antibiotic resistance markers may not correlate with phenotypic gene expression; and
(D) Therapeutic failure or success cannot be determined based on the assay results, since nucleic acid may persist following appropriate antimicrobial therapy.
(4) Design verification and validation must include:
(i) Detailed device description documentation, including methodology from obtaining sample to result, design of primer/probe sequences, rationale for target sequence selection, and computational path from collected raw data to reported result (
e.g., how collected raw signals are converted into a reported result).(ii) Detailed documentation of analytical studies, including, Limit of Detection, inclusivity, cross-reactivity, microbial interference, interfering substances, competitive inhibition, carryover/cross contamination, specimen stability, within lab precision, and reproducibility, as appropriate.
(iii) Detailed documentation and performance results from a clinical study that includes prospective (sequential) samples for each claimed specimen type and, when determined to be appropriate by FDA, additional characterized clinical samples. The study must be performed on a study population consistent with the intended use population and compare the device performance to results obtained from FDA accepted comparator methods. Documentation from the clinical studies must include the clinical study protocol (including a predefined statistical analysis plan) study report, testing results, and results of all statistical analyses.
(iv) A detailed description of the impact of any software, including software applications and hardware-based devices that incorporate software, on the device's functions.