(63 days)
Not Found
Yes
The device description explicitly states that the software "uses artificial intelligence to emulate the expertise of sonographers."
No
The device is described as an accessory to diagnostic ultrasound systems intended to assist in image acquisition, not for therapeutic purposes.
No
The device is described as an "acquisition guidance system" intended to "assist medical professionals in the acquisition of cardiac ultrasound images." It helps obtain "anatomically correct images that represent standard 2D echocardiographic diagnostic views and orientations" and judges the "expected diagnostic quality" of an image. However, its stated purpose is to aid in image acquisition for compatible diagnostic ultrasound systems, not to perform diagnosis itself.
Yes
The device description explicitly states, "Caption Guidance is a software-only device."
Based on the provided information, the Caption Guidance software is not an In Vitro Diagnostic (IVD).
Here's why:
- IVDs analyze samples taken from the human body. The Caption Guidance software works with cardiac ultrasound images, which are generated by a medical device (the ultrasound system) and represent the internal structure of the body. It does not analyze biological samples like blood, urine, or tissue.
- The intended use is image acquisition assistance. The software's purpose is to help medical professionals acquire better quality cardiac ultrasound images. It is an accessory to a diagnostic ultrasound system, which is the device that performs the actual diagnostic imaging.
- The device description focuses on image guidance and acquisition features. The features described (Quality Meter, Prescriptive Guidance, Auto-Capture, Save Best Clip) are all related to improving the process of obtaining ultrasound images, not analyzing biological samples.
Therefore, the Caption Guidance software falls under the category of a medical device that assists in the acquisition of diagnostic images, rather than an In Vitro Diagnostic device.
Yes
This device is a Predetermined Change Control Plan (PCCP) authorized device because the "Predetermined Change Control Plan (PCCP) - All Relevant Information" section explicitly states its purpose is "to address the modification of a predetermined change control plan (PCCP) to outline anticipated modifications to the Caption Guidance software." This indicates that a PCCP is in place for this device.
Intended Use / Indications for Use
The Caption Guidance software is intended to assist medical professionals in the acquisition of cardiac ultrasound images. The Caption Guidance software is an accessory to compatible general purpose diagnostic ultrasound systems.
The Caption Guidance software is indicated for use in two-dimensional transthoracic echocardiography (2D-TTE) for adult patients, specifically in the acquisition of the following standard views: Parasternal Long-Axis (PLAX), Parasternal Short-Axis at the Aortic Valve (PSAX-AV), Parasternal Short-Axis at the Mitral Valve (PSAX-MV), Parasternal Short-Axis at the Papillary Muscle (PSAX-PM), Apical 4-Chamber (AP4), Apical 5-Chamber (AP5), Apical 2-Chamber (AP2), Apical 3-Chamber (AP3), Subcostal 4-Chamber (SubC4), and Subcostal Inferior Vena Cava (SC-IVC).
Product codes
QJU
Device Description
The Caption Guidance software is a radiological computer assisted acquisition guidance system that provides real-time user quidance during acquisition of echocardiography to assist the user in obtaining anatomically correct images that represent standard 2D echocardiographic diagnostic views and orientations. Caption Guidance is a software-only device that uses artificial intelligence to emulate the expertise of sonographers.
Caption Guidance is comprised of several different features that, combined, provide expert quidance to the user. These include:
- Quality Meter: The real-time feedback from the Quality Meter advises the user on the expected diagnostic quality of the resulting clip, such that the user can make decisions to further optimize the quality, for example by following the prescriptive guidance feature below.
- Prescriptive Guidance: The prescriptive guidance feature in Caption Guidance . provides direction to the user to emulate how a sonographer would manipulate the transducer to acquire the optimal view.
- Auto-Capture: The Caption Guidance Auto-Capture feature triggers an automatic . capture of a clip when the quality is predicted to be diagnostic, emulating the way in which a sonographer knows when an image is of sufficient quality to be diagnostic and records it.
- Save Best Clip: This feature continually assesses clip quality while the user is scanning . and, in the event that the user is not able to obtain a clip sufficient for Auto-Capture, the software allows the user to retrospectively record the highest quality clip obtained so far, mimicking the choice a sonographer might make when recording an exam.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Yes
Input Imaging Modality
Ultrasound
Anatomical Site
Cardiac
Indicated Patient Age Range
Adult
Intended User / Care Setting
Medical professionals
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 (study type, sample size, AUC, MRMC, standalone performance, key results)
Not Found
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
The purpose of the 510(k) submission is to address the modification of a predetermined change control plan (PCCP) to outline anticipated modifications to the Caption Guidance software and the methods that will be utilized to implement those modifications in a controlled manner while maintaining safety and efficacy. In accordance with the PCCP, all algorithm modifications will be trained, tuned, and locked prior to release of the software to the field. The PCCP does not include provisions for implementation of adaptive algorithms that will continuously learn in the field.
892.2100 Radiological acquisition and/or optimization guidance system.
892.2100 Radiological acquisition and/or optimization guidance system.
(a)
Identification. A radiological acquisition and/or optimization guidance system is a device that is intended to aid in the acquisition and/or optimization of images and/or diagnostic signals. The device interfaces with the acquisition system, analyzes its output, and provides guidance and/or feedback to the operator for improving image and/or signal quality.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Design verification and validation must include:
(i) A detailed, technical device description, including a detailed description of the impact of any software and hardware on the device's functions, the associated capabilities and limitations of each part, and the associated inputs and outputs.
(ii) A detailed, technical report on the non-clinical performance testing of the subject device in the intended use environments, using relevant consensus standards when applicable.
(iii) A detailed report on the clinical performance testing, obtained from either clinical testing, accepted virtual/physical systems designed to capture clinical variability, comparison to a closely-related device with established clinical performance, or other sources that are justified appropriately. The choice of the method must be justified given the risk of the device and the general acceptance of the test methods. The report must include the following:
(A) A thorough description of the testing protocol(s).
(B) A thorough, quantitative evaluation of the diagnostic utility and quality of images/data acquired, or optimized, using the device.
(C) A thorough, quantitative evaluation of the performance in a representative user population and patient population, under anticipated conditions and environments of use.
(D) A thorough discussion on the generalizability of the clinical performance testing results.
(E) A thorough discussion on use-related risk analysis/human factors data.
(iv) A detailed protocol that describes, in the event of a future change, the level of change in the device technical specifications or indications for use at which the change or changes could significantly affect the safety or effectiveness of the device and the risks posed by these changes. The assessment metrics, acceptance criteria, and analytical methods used for the performance testing of changes that are within the scope of the protocol must be included.
(v) Documentation of an appropriate training program, including instructions on how to acquire and process quality images and video clips, and a report on usability testing demonstrating the effectiveness of that training program on user performance, including acquiring and processing quality images.
(2) The labeling required under § 801.109(c) of this chapter must include:
(i) A detailed description of the device, including information on all required and/or compatible parts.
(ii) A detailed description of the patient population for which the device is indicated for use.
(iii) A detailed description of the intended user population, and the recommended user training.
(iv) Detailed instructions for use, including the information provided in the training program used to meet the requirements of paragraph (b)(1)(iv) of this section.
(v) A warning that the images and data acquired using the device are to be interpreted only by qualified medical professionals.
(vi) A detailed summary of the reports required under paragraphs (b)(1)(ii) and (iii) of this section.
(vii) A statement on upholding the As Low As Reasonably Achievable (ALARA) principle with a discussion on the associated device controls/options.
0
September 18, 2020
Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG" in blue, and then the word "ADMINISTRATION" in a smaller font size below that.
Caption Health % Sam Surette Head of RA/QA 2000 Sierra Point Pkwy., 8th Floor BRISBANE CA 94005
Re: K201992
Trade/Device Name: Caption Guidance Regulation Number: 21 CFR 892.2100 Regulation Name: Radiological acquisition and/or optimization guidance system Regulatory Class: Class II Product Code: QJU Dated: July 17, 2020 Received: July 17, 2020
Dear Sam Surette:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
1
https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known)
Device Name
Caption Guidance
Indications for Use (Describe)
The Caption Guidance software is intended to assist medical professionals in the acquisition of cardiac ultrasound images. The Caption Guidance software is an accessory to compatible general purpose diagnostic ultrasound systems.
The Caption Guidance software is indicated for use in two-dimensional transthoracic echocardiography (2D-TTE) for adult patients, specifically in the acquisition of the following standard views: Parasternal Long-Axis (PLAX), Parasternal Short-Axis at the Aortic Valve (PSAX-AV), Parasternal Short-Axis at the Mitral Valve (PSAX-MV), Parasternal Short- Axis at the Papillary Muscle (PSAX-PM), Apical 4-Chamber (AP4), Apical 5-Chamber (AP5), Apical 2-Chamber (AP2), Apical 3-Chamber (AP3), Subcostal 4-Chamber (SubC4), and Subcostal Inferior Vena Cava (SC-IVC).
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 G) |
|---|---|
| ----------------------------------------------------------------------------------------------- | ----------------------------------------------- |
|X Prescription Use (Part 21 CFR 801 Subpart D)
| | Over-The-Counter Use (21 CFR 801 Subpart C)
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3
K201992
510(k) SUMMARY Caption Health, Inc.'s Caption Guidance Software
Submitter
Caption Health, Inc. 2000 Sierra Point Parkway, 8th Floor Brisbane, CA 94005
Contact Person: Sam Surette, Head of RA/QA
Phone: (415) 671-4711
Email: sam@captionhealth.com
Date Prepared: July 17, 2020
Name of Device: Caption Guidance
Classification Name: Image Acquisition And/Or Optimization Guided By Artificial Intelligence
Regulatory Class: II
Product Code: QJU
Predicate Device: Caption Guidance (K200755)
Device Description:
The Caption Guidance software is a radiological computer assisted acquisition guidance system that provides real-time user quidance during acquisition of echocardiography to assist the user in obtaining anatomically correct images that represent standard 2D echocardiographic diagnostic views and orientations. Caption Guidance is a software-only device that uses artificial intelligence to emulate the expertise of sonographers.
Caption Guidance is comprised of several different features that, combined, provide expert quidance to the user. These include:
- Quality Meter: The real-time feedback from the Quality Meter advises the user on the expected diagnostic quality of the resulting clip, such that the user can make decisions to further optimize the quality, for example by following the prescriptive guidance feature below.
- Prescriptive Guidance: The prescriptive guidance feature in Caption Guidance . provides direction to the user to emulate how a sonographer would manipulate the transducer to acquire the optimal view.
- Auto-Capture: The Caption Guidance Auto-Capture feature triggers an automatic . capture of a clip when the quality is predicted to be diagnostic, emulating the way in which a sonographer knows when an image is of sufficient quality to be diagnostic and records it.
4
- Save Best Clip: This feature continually assesses clip quality while the user is scanning . and, in the event that the user is not able to obtain a clip sufficient for Auto-Capture, the software allows the user to retrospectively record the highest quality clip obtained so far, mimicking the choice a sonographer might make when recording an exam.
Intended Use / Indications for Use:
No differences exist between the subject device and the predicate device with respect to intended use or indications for use. The following summary of intended use / indications for use is reproduced here for reference:
The Caption Guidance software is intended to assist medical professionals in the acquisition of cardiac ultrasound images. The Caption Guidance software is an accessory to compatible general purpose diagnostic ultrasound systems.
The Caption Guidance software is indicated for use in two-dimensional transthoracic echocardiography (2D-TTE) for adult patients, specifically in the acquisition of the following standard views: Parasternal Long-Axis (PLAX), Parasternal Short-Axis at the Aortic Valve (PSAX-AV), Parasternal Short-Axis at the Mitral Valve (PSAX-MV), Parasternal Short-Axis at the Papillary Muscle (PSAX-PM), Apical 4-Chamber (AP4), Apical 5-Chamber (AP5), Apical 2-Chamber (AP2), Apical 3-Chamber (AP3), Subcostal 4-Chamber (SubC4), and Subcostal Inferior Vena Cava (SC-IVC).
Summary of Technological Characteristics:
The Caption Guidance software is identical to the predicate device, and as such, the technological characteristics are incorporated by reference.
Conclusions
The current iteration of the Caption Guidance software is as safe and effective as the previous iteration of such software. The Caption Guidance software has the same intended use, indications for use, technological characteristics, and principles of operation as its predicate device. Thus, the Caption Guidance software is substantially equivalent.
The purpose of the 510(k) submission is to address the modification of a predetermined change control plan (PCCP) to outline anticipated modifications to the Caption Guidance software and the methods that will be utilized to implement those modifications in a controlled manner while maintaining safety and efficacy. In accordance with the PCCP, all algorithm modifications will be trained, tuned, and locked prior to release of the software to the field. The PCCP does not include provisions for implementation of adaptive algorithms that will continuously learn in the field.