(247 days)
The Dexcom G6 Continuous Glucose Monitoring System (Dexcom G6 System) is a real time, continuous glucose monitoring device indicated for the management of diabetes in persons age 2 years and older.
The Dexcom G6 System is intended to replace fingerstick blood glucose testing for diabetes treatment decisions. Interpretation of the Dexcom G6 System results should be based on the glucose trends and sequential readings over time. The Dexcom G6 System also aids in the detection of evisodes of hyperglycemia, facilitating both acute and long-term therapy adjustments.
The Dexcom G6 System is also intended to autonomously communicate with digitally connected devices, including automated insulin dosing (AID) systems. The Dexcom G6 System can be used alone or in conjunction with these digitally connected medical devices for the purpose of managing diabetes.
The Dexcom G6 Glucose Program Continuous Glucose Monitoring System Glucose Program System) is a real time, continuous glucose monitoring device indicated for the management of diabetes in persons age 2 years and older.
The Dexcom Glucose Program System is intended to replace fingerstick blood glucose testing for diabetes treatment decisions for persons with diabetes who are not at significant risk of severe hypoglycemia. Interpretation of the Dexcom Glucose Program System results should be based on the glucose trends and sequential sensor readings over time. The Dexcom Glucose Program System also aids in the detection of episodes of hyperglycemia, facilitating long-term therapy adjustments.
The Dexcom Glucose Program System is also intended to autonomously communicate with digitally connected devices. The Dexcom Glucose Program System can be used alone or in conjunction with these digitally connected devices or services for the purpose of managing diabetes.
The Dexcom G6 Continuous Glucose Monitoring (CGM) System consists of three main components: a sensor/applicator, a Bluetooth Low Energy (BLE) transmitter, and a BLE enabled display device (receiver and/or mobile app). The sensor is a small and flexible wire inserted by the applicator into subcutaneous tissue where it converts glucose into electrical current. The transmitter is connected to the sensor and is worn on the body. It samples the electrical current produced by the sensor and converts these measurements into estimated glucose values (EGV) using an onboard algorithm. The transmitter sends glucose data to the receiver and/or mobile app which displays the current glucose reading (updated every 5 minutes) and glucose trends. The receiver and/or mobile app alerts the user when glucose levels are outside of a target zone and when other important system conditions occur. The G6 sensor life has an expected wear time of up to 10 days. Though the Dexcom G6 CGM System is factory calibrated and does not require user calibration, users of the Dexcom G6 CGM System have the option to calibrate the device (e.g., in situations where users do not have to use the sensor code). When operating in factory calibration mode (using sensor code, the primary mode of G6 CGM System), the G6 algorithm does not require SMBG calibration and instead uses sensor glucose sensitivity estimates determined during manufacturing for EGV calculation. When operating in manual calibration mode (no sensor code), the G6 algorithm relies on daily SMBG calibrations and timematched sensor counts (matched pairs) to estimate calibration parameters for EGV calculation. When a SMBG calibration is entered into the system (in either mode), this information may be used by the system for estimating the glucose using the Bayesian Joint probability algorithm (JPA).
The proposed G6 CGM System is based on the same physical principles and fundamental design as the commercially available G6 CGM System (K191450), but it includes a modified algorithm (onboard algorithm) in the welded version of the G6 Transmitter (also named "Firefly" Transmitter in Dexcom's internal documents). The proposed algorithm is modified to improve data availability by modifications to modules that handle noise events and calibrations when applicable. Additionally, the algorithm has been modified to improve detectability of sensors approaching end of life. Except the modified transmitter firmware, there have been no changes to other components of the G6 CGM System (sensor/applicator, transmitter hardware, receiver, and mobile app) introduced by the modified algorithm.
The Dexcom G6 Glucose Program CGM System consists of three main components: the sensor/applicator delivery system, transmitter, and mobile application (app). The sensor is a small and flexible wire inserted into subcutaneous tissue where it converts glucose into electrical current. The transmitter is connected to the sensor and is worn on the body. It samples the electrical current produced by the sensor and converts these measurements into glucose readings using an onboard algorithm. The transmitter sends glucose data to the app. The app displays the current glucose reading (updated every 5 minutes) and glucose trends. The app alerts users of important system conditions, when it enters an error state, or when it requires the user to enter information. The app also supports connectivity to Dexcom Share and Follow. The G6 sensor life has an expected wear time of up to 10 days. Though the Dexcom G6 Glucose Program CGM System is factory calibrated and does not require user calibration, users have the option to calibrate the device when operating in factory calibration mode (using sensor code, the only mode of System). When a SMBG calibration is entered into the system, this information may be used by the system for estimating the glucose using the Bayesian Joint probability algorithm (JPA).
The proposed G6 Glucose Program CGM System is based on the same physical principles and fundamental design as the commercially available G6 Glucose Program CGM System, but it includes a modified algorithm (onboard algorithm) in the welded version of the G6 Transmitter (also named "Firefly" Transmitter in Dexcom's internal documents). The proposed algorithm is modified to improve data availability by modifications to modules that handle noise events and calibrations when applicable. Additionally, the algorithm has been modified to improve detectability of sensors approaching end of life. Except the modified transmitter firmware, the sensor/applicator, transmitter hardware, and mobile app remain unchanged.
This document is a 510(k) premarket notification for the Dexcom G6 Continuous Glucose Monitoring System and the Dexcom G6 Glucose Program Continuous Glucose Monitoring System. The notification aims to demonstrate the substantial equivalence of the modified device to its legally marketed predicate (K191450).
Key Takeaways:
- Device: Dexcom G6 Continuous Glucose Monitoring System and Dexcom G6 Glucose Program Continuous Glucose Monitoring System.
- Modification: Modified algorithm (onboard algorithm) in the transmitter to improve data availability by handling noise events and calibrations better, and to improve detectability of sensors approaching end of life. No changes to other components (sensor/applicator, transmitter hardware, receiver, mobile app).
- Purpose: To demonstrate substantial equivalence to the predicate (K191450) despite the algorithm modification.
While the document highlights the device's intended use and compares it to a predicate device, it does not explicitly provide a table of acceptance criteria and reported device performance with specific metrics (e.g., MARD, accuracy at different glucose ranges). It states that performance testing was done but does not detail the results. Similarly, it doesn't provide information on sample sizes, ground truth establishment methods, or multi-reader studies in the format requested.
Therefore, many of the requested details cannot be extracted directly from this document. The document primarily focuses on demonstrating substantial equivalence based on the intended use and the technological characteristics remaining largely the same, with the algorithm modification being verified and validated internally.
Based on the provided text, here's what can be answered, and what cannot:
1. A table of acceptance criteria and the reported device performance:
- Cannot be fully provided. The document states: "This testing demonstrated that the proposed systems performed according to their respective specifications, and the proposed systems have met their respective technological and performance criteria, which have not changed from the predicate device (K191450)."
- It also states regarding the algorithm modification: "The accuracy of the proposed G6 CGM System was demonstrated to meet the iCGM (21 CFR 862.1355) Special Controls requirements (Section 20, Performance Testing - Clinical)."
- However, the specific numerical acceptance criteria (e.g., a certain MARD %) and the actual reported device performance (e.g., the measured MARD) are not detailed in this summary.
2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Cannot be provided. The document mentions "Performance Testing - Clinical" but does not detail the sample size, data provenance, or whether the study was 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 applicable / Cannot be provided. This device is a Continuous Glucose Monitor (CGM). Its "ground truth" would typically refer to validated reference glucose measurements (e.g., YSI glucose analyzer, lab-derived plasma glucose). It does not involve human expert interpretation of images that would require multiple readers or their qualifications in the context of imaging.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable / Cannot be provided. As above, adjudication methods for expert interpretation are not relevant for a CGM's ground truth, which is based on objective glucose measurements.
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:
- Not applicable. This is a standalone device that measures glucose, not an AI-assisted diagnostic tool that human readers would use to interpret medical images.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Yes, implicitly. The core of the device is the algorithm that converts sensor data into estimated glucose values. The document mentions "The proposed algorithm is modified to improve data availability by modifications to modules that handle noise events and calibrations when applicable." The "accuracy of the proposed G6 CGM System" was demonstrated to meet requirements. This refers to the algorithm's performance in generating glucose estimations. The device is intended to "replace fingerstick blood glucose testing for diabetes treatment decisions," implying a standalone measurement accuracy.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Implicitly, reference glucose measurements. For a CGM, the ground truth is established by highly accurate laboratory-grade glucose measurements, typically from venous blood samples analyzed by a calibrated reference method (e.g., YSI glucose analyzer). While not explicitly stated, this is the standard for CGM validation.
8. The sample size for the training set:
- Cannot be provided. The document does not discuss the training set for the algorithm, only the performance testing of the final modified algorithm.
9. How the ground truth for the training set was established:
- Cannot be provided. As with point 8, the document does not detail the training process or the establishment of ground truth for the training data.
§ 862.1355 Integrated continuous glucose monitoring system.
(a)
Identification. An integrated continuous glucose monitoring system (iCGM) is intended to automatically measure glucose in bodily fluids continuously or frequently for a specified period of time. iCGM systems are designed to reliably and securely transmit glucose measurement data to digitally connected devices, including automated insulin dosing systems, and are intended to be used alone or in conjunction with these digitally connected medical devices for the purpose of managing a disease or condition related to glycemic control.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Design verification and validation must include the following:
(i) Robust clinical data demonstrating the accuracy of the device in the intended use population.
(ii) The clinical data must include a comparison between iCGM values and blood glucose values in specimens collected in parallel that are measured on an FDA-accepted laboratory-based glucose measurement method that is precise and accurate, and that is traceable to a higher order (
e.g., an internationally recognized reference material and/or method).(iii) The clinical data must be obtained from a clinical study designed to fully represent the performance of the device throughout the intended use population and throughout the measuring range of the device.
(iv) Clinical study results must demonstrate consistent analytical and clinical performance throughout the sensor wear period.
(v) Clinical study results in the adult population must meet the following performance requirements:
(A) For all iCGM measurements less than 70 milligrams/deciliter (mg/dL), the percentage of iCGM measurements within ±15 mg/dL of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 85 percent.
(B) For all iCGM measurements from 70 mg/dL to 180 mg/dL, the percentage of iCGM measurements within ±15 percent of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 70 percent.
(C) For all iCGM measurements greater than 180 mg/dL, the percentage of iCGM measurements within ±15 percent of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 80 percent.
(D) For all iCGM measurements less than 70 mg/dL, the percentage of iCGM measurements within ±40 mg/dL of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 98 percent.
(E) For all iCGM measurements from 70 mg/dL to 180 mg/dL, the percentage of iCGM measurements within ±40 percent of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 99 percent.
(F) For all iCGM measurements greater than180 mg/dL, the percentage of iCGM measurements within ±40 percent of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 99 percent.
(G) Throughout the device measuring range, the percentage of iCGM measurements within ±20 percent of the corresponding blood glucose value must be calculated, and the lower one-sided 95 percent confidence bound must exceed 87 percent.
(H) When iCGM values are less than 70 mg/dL, no corresponding blood glucose value shall read above 180 mg/dL.
(I) When iCGM values are greater than 180 mg/dL, no corresponding blood glucose value shall read less than 70 mg/dL.
(J) There shall be no more than 1 percent of iCGM measurements that indicate a positive glucose rate of change greater than 1 mg/dL per minute (/min) when the corresponding true negative glucose rate of change is less than −2 mg/dL/min as determined by the corresponding blood glucose measurements.
(K) There shall be no more than 1 percent of iCGM measurements that indicate a negative glucose rate of change less than −1 mg/dL/min when the corresponding true positive glucose rate of change is greater than 2 mg/dL/min as determined by the corresponding blood glucose measurements.
(vi) Data demonstrating similar accuracy and rate of change performance of the iCGM in the pediatric population as compared to that in the adult population, or alternatively a clinical and/or technical justification for why pediatric data are not needed, must be provided and determined by FDA to be acceptable and appropriate.
(vii) Data must demonstrate that throughout the claimed sensor life, the device does not allow clinically significant gaps in sensor data availability that would prevent any digitally connected devices from achieving their intended use.
(2) Design verification and validation must include a detailed strategy to ensure secure and reliable means of iCGM data transmission to provide real-time glucose readings at clinically meaningful time intervals to devices intended to receive the iCGM glucose data.
(3) Design verification and validation must include adequate controls established during manufacturing and at product release to ensure the released product meets the performance specifications as defined in paragraphs (b)(1) and (b)(2) of this section.
(4) The device must demonstrate clinically acceptable performance in the presence of clinically relevant levels of potential interfering substances that are reasonably present in the intended use population, including but not limited to endogenous substances and metabolites, foods, dietary supplements, and medications.
(5) The device must include appropriate measures to ensure that disposable sensors cannot be used beyond its claimed sensor wear period.
(6) Design verification and validation must include results obtained through a usability study that demonstrates that the intended user can use the device safely and obtain the expected glucose measurement accuracy.
(7) The labeling required under § 809.10(b) of this chapter must include a separate description of the following sensor performance data observed in the clinical study performed in conformance with paragraph (b)(1) of this section for each intended use population, in addition to separate sensor performance data for each different iCGM insertion or use sites (
e.g., abdomen, arm, buttock):(i) A description of the accuracy in the following blood glucose concentration ranges: less than 54 mg/dL, 54 mg/dL to less than 70 mg/dL, 70 to 180 mg/dL, greater than 180 to 250 mg/dL, and greater than 250 mg/dL.
(ii) A description of the accuracy of positive and negative rate of change data.
(iii) A description of the frequency and duration of gaps in sensor data.
(iv) A description of the true, false, missed, and correct alert rates and a description of the available glucose concentration alert settings, if applicable.
(v) A description of the observed duration of iCGM life for the device.