K Number
K202408
Date Cleared
2021-01-21

(153 days)

Product Code
Regulation Number
866.3393
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The cobas® CT/NG for use on the cobas® 6800/8800 Systems is an automated, qualitative in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician-instructed self-collected vaginal swab specimens (collected in a clinical setting), and clinician-collected vaginal swab specimens, endocervical swab specimens, oropharyngeal (throat) swab specimens and anorectal swab specimens all collected in cobas® PCR Media (Roche Molecular Systems, Inc.), and cervical specimens collected in PreservCyt® Solution. This test is intended as an aid in the diagnosis of chlamydial and gonococcal disease in both symptomatic and asymptomatic individuals.

Device Description

The cobas® CT/NG for use on the cobas® 6800/8800 systems is an automated, qualitative in vitro nucleic acid diagnostic test that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA. The current submission is a device modification for the claim extension to include oropharyngeal (throat) and anorectal swab specimens to cleared clinical specimen types. The assay’s principle relies on polymerase chain reaction (PCR) for amplification and a paired reporter and quencher fluorescence-labeled probes (TaqMan Technology) using fluorescence resonance energy transfer (FRET) for detection. Results are analyzed based on PCR cycle threshold analysis.

AI/ML Overview

Here's a summary of the acceptance criteria and study details for the cobas CT/NG device, extracted from the provided FDA 510(k) clearance letter:

1. Table of Acceptance Criteria (Implicit) and Reported Device Performance

The document doesn't explicitly state "acceptance criteria" as a separate table, but the clinical performance results serve as the evidence to meet the implied criteria for sensitivity and specificity in the new specimen types.

MetricTarget (Implicit Acceptance Criteria)Reported Device Performance (CT - Anorectal)Reported Device Performance (CT - Oropharyngeal)Reported Device Performance (NG - Anorectal)Reported Device Performance (NG - Oropharyngeal)
SensitivityHigh (e.g., typically >90% for diagnostic tests)95.1% (90.2%, 97.6%)100.0% (87.9%, 100.0%)99.0% (94.6%, 99.8%)100.0% (96.2%, 100.0%)
SpecificityHigh (e.g., typically >95-99% for diagnostic tests)99.2% (98.8%, 99.5%)99.8% (99.6%, 99.9%)99.3% (98.9%, 99.6%)98.9% (98.4%, 99.2%)

Note: The confidence intervals (CIs) are provided as ranges for the reported performance.

2. Sample Size Used for the Test Set and Data Provenance

  • Sample Size for Test Set:
    • Subjects Enrolled: 2,390 (2,439 subjects were consented, but 49 excluded).
    • Anorectal Specimens Tested: 2,365
    • Oropharyngeal Specimens Tested: 2,382
    • Total Samples: 4,747 (2,365 anorectal + 2,382 oropharyngeal)
  • Data Provenance: Multi-site, prospective collection study from 8 geographically diverse clinic sites (STD, HIV, Family Planning, and STD Research). The country of origin is not explicitly stated but is implied to be the US given the FDA clearance.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

The ground truth was established by a composite reference method using three commercially available CT/NG NAATs. There's no mention of human experts defining the ground truth for individual cases.

4. Adjudication Method for the Test Set

The adjudication method used for establishing the "Infection Status (IS)" (ground truth) was a 2-out-of-3 concordance rule involving three comparator NAAT assays:

  • A positive IS was derived when at least 2 of the 3 comparator reference assays were positive.
  • If one of the comparator assays was Uninterpretable/Invalid/Failed, the two remaining assays had to be concordant to define the IS as Positive (+) or Negative (-).
  • Any other combination of Uninterpretable/Invalid/Failed and valid results were excluded from the analyses.

5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was Done

No, an MRMC comparative effectiveness study was not conducted. This study focused on the standalone performance of the cobas CT/NG system against a composite reference standard, not on comparing human reader performance with and without AI assistance.

6. If a Standalone Study Was Done

Yes, a standalone study was done. The clinical performance evaluation directly tested the cobas CT/NG system against the established Infection Status (ground truth) for each specimen type. The results are presented as the device's sensitivity and specificity.

7. The Type of Ground Truth Used

The ground truth used was an expert consensus of commercially available NAATs, forming a "Infection Status (IS)" algorithm. It is a composite reference standard.

8. The Sample Size for the Training Set

The document does not provide information on the sample size used for the training set. The 510(k) pertains to a "device change" (claim extension) for an already cleared device (K173887). The training would have occurred during the development of the original cleared device. This submission focuses on the validation for new specimen types.

9. How the Ground Truth for the Training Set Was Established

The document does not provide information on how the ground truth for the training set was established. Similar to the training set size, this information would likely be part of the original K173887 submission for the device development. This current submission focuses on evaluating the device's performance for expanded claims.

FDA 510(k) Clearance Letter - cobas CT/NG for use on cobas 6800/8800 systems

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov

Doc ID # 04017.04.22

January 21, 2021

Roche Molecular Systems, Inc.
Aradhana Karthikeyan
Sr Regulatory Affairs Specialist
4300 Hacienda Drive
Pleasanton, California 94588-2722

Re: K202408
Trade/Device Name: cobas CT/NG for use on cobas 6800/8800 systems
Regulation Number: 21 CFR 866.3393
Regulation Name: Nucleic acid detection system for non-viral microorganism(s) causing sexually transmitted infections
Regulatory Class: Class II
Product Code: QEP, MKZ, LSL, OOI
Dated: August 20, 2020
Received: August 21, 2020

Dear Aradhana Karthikeyan:

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.

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K202408 - Aradhana Karthikeyan Page 2

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 and Part 809); medical device reporting (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 https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory-assistance/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,

Maria I. Garcia -S

Maria Ines Garcia, Ph.D.
Branch Chief
Division of Microbiology Devices
OHT7: Office of In Vitro Diagnostics and Radiological Health
Office of Product Evaluation and Quality
Center for Devices and Radiological Health

Enclosure

Page 3

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.

510(k) Number (if known): K202408

Device Name: cobas® CT/NG for use on cobas 6800/8800 systems

Indications for Use (Describe)

The cobas® CT/NG for use on the cobas® 6800/8800 Systems is an automated, qualitative in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician-instructed self-collected vaginal swab specimens (collected in a clinical setting), and clinician-collected vaginal swab specimens, endocervical swab specimens, oropharyngeal (throat) swab specimens and anorectal swab specimens all collected in cobas® PCR Media (Roche Molecular Systems, Inc.), and cervical specimens collected in PreservCyt® Solution. This test is intended as an aid in the diagnosis of chlamydial and gonococcal disease in both symptomatic and asymptomatic individuals.

Ancillary Collection Kits

The cobas® PCR Media Dual Swab Sample Kit is used to collect and transport human specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium.

Note: This kit has been validated for use with the following tests:

  • cobas® CT/NG v2.0 Test (for use on the cobas® 4800 Systems)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems

The cobas® PCR Media Uni Swab Sample Kit is used to collect and transport human specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium.

Note: This kit has been validated for use with the following tests:

  • cobas® CT/NG v2.0 Test (for use on the cobas® 4800 Systems)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems
  • cobas® Cdiff Test for use on the cobas® 4800 System

The cobas® PCR Urine Sample Kit is used to collect and transport urine specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium.

Note: This kit has been validated for use with the following tests:

  • cobas® CT/NG v2.0 Test (for use on cobas® 4800 Systems)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

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Page 4

cobas® CT/NG for use on the cobas® 6800/8800 Systems 510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92.

Submitter NameRoche Molecular Systems, Inc.
Address4300 Hacienda DrivePleasanton, CA, 94588-2722
ContactAradhana KarthikeyanPhone: (925) 353-7713FAX: (925) 730-8784Email: Aradhana.karthikeyan@roche.com
Date PreparedJan 12, 2021
Proprietary Namecobas® CT/NGfor use on cobas® 6800/8800 systems
Common NameReal-time PCR assay, in vitro nucleic acid amplification test for the quantitative detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG)
Classification NameNucleic acid detection system for non-viral microorganism(s) causing sexually transmitted infectionsChlamydia serological reagentsNeisseria spp. direct serological test reagentsReal Time Nucleic Acid Amplification System
Product CodesQEP: Sec. 866.3393MKZ: Sec. 866.3120LSL: Sec. 866.3390OOI: Sec. 862.2570
Predicate Devicescobas® CT/NG for use on the cobas® 6800/8800 systems (K173887)
Establishment RegistrationRoche Molecular Systems, Inc. (2243471)

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1. DEVICE CHANGE DESCRIPTION

The cobas® CT/NG for use on the cobas® 6800/8800 systems was originally cleared under K173887 as a qualitative test in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician-instructed self-collected vaginal swab specimens (collected in a clinical setting), clinician-collected vaginal swab specimens, and endocervical swab specimens.

This device modification is for the claim extension to include oropharyngeal (throat) and anorectal swab specimens to cleared clinical specimen types. There have been no changes to the device design to accommodate this change.

1.1. Principles of the procedure

Principle of the assay procedure remains the same as K173887.

2. INTENDED USE

The cobas® CT/NG for use on the cobas® 6800/8800 system is an automated, qualitative in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician-instructed self-collected vaginal swab specimens (collected in a clinical setting), and clinician-collected vaginal swab specimens, endocervical swab specimens, oropharyngeal (throat) swab specimens and anorectal swab specimens all collected in cobas® PCR Media (Roche Molecular Systems, Inc.), and cervical specimens collected in PreservCyt® solution. This test is intended as an aid in the diagnosis of chlamydial and gonococcal disease in both symptomatic and asymptomatic individuals.

2.1. Ancillary Collection Kits

The cobas® PCR Media Dual Swab Sample Kit is used to collect and transport human specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium.

Page 6

Note: This kit has been validated for use with the following tests:

  • cobas® CT/NG v2.0 Test (for use on cobas® 4800 System)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems

The cobas® PCR Media Uni Swab Sample Kit is used to collect and transport human specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium.

Note: This kit has been validated for use with the following tests:

  • cobas® CT/NG v2.0 Test (for use on cobas® 4800 System)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems
  • cobas® Cdiff Test for use on the cobas® 4800 System

The cobas® PCR Urine Sample Kit is used to collect and transport urine specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium. Use this collection kit only with the following tests:

  • cobas® CT/NG v2.0 Test (for use on cobas® 4800 System)
  • cobas® CT/NG for use on cobas® 6800/8800 Systems
  • cobas® TV/MG for use on the cobas® 6800/8800 Systems

3. TECHNOLOGICAL CHARACTERISTICS

The primary technological characteristics and intended use of the RMS cobas® CT/NG for use on the cobas® 6800/8800 systems are substantially equivalent to other legally marketed nucleic acid amplification tests intended for the qualitative detection of Chlamydia trachomatis (CT) and Neisseria gonorrhoeae (NG).

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As indicated in Table 1, the cobas® CT/NG for use on the cobas® 6800/8800 systems is substantially equivalent to significant characteristics of the identified predicate device, the currently cleared cobas® CT/NG Test (K173887).

Table 1: Comparison of the cobas® CT/NG for use on the cobas® 6800/8800 systems with the Predicate Device

Predicate Devicecobas® CT/NG for use on the cobas® 6800/8800 systems (K173887)Subject Devicecobas® CT/NG for use on the cobas® 6800/8800 systems (claim extension)
Intended UseThe cobas® CT/NG on the cobas® 6800/8800 system is an automated, qualitative in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician instructed self-collected vaginal swab specimens (collected in a clinical setting), clinician-collected vaginal swab specimens, and endocervical swab specimens, all collected in cobas® PCR Media (Roche Molecular Systems, Inc.), and cervical specimens collected in PreservCyt® solution. This test is intended as an aid in the diagnosis of chlamydial and gonococcal disease in both symptomatic and asymptomatic individuals.The cobas® CT/NG on the cobas® 6800/8800 system is an automated, qualitative in vitro nucleic acid diagnostic test, that utilizes real-time polymerase chain reaction (PCR), for the direct detection of Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) DNA in male and female urine, clinician-instructed self-collected vaginal swab specimens (collected in a clinical setting), and clinician-collected vaginal swab specimens, endocervical swab specimens, oropharyngeal (throat) swab specimens and anorectal swab specimens all collected in cobas® PCR Media (Roche Molecular Systems, Inc.), and cervical specimens collected in PreservCyt® solution. This test is intended as an aid in the diagnosis of chlamydial and gonococcal disease in both symptomatic and asymptomatic individuals.
Intended Use, cont.Ancillary Collection Kits:The cobas® PCR Media Dual Swab Sample Kit is used to collect and transport endocervical and vaginal swab specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium for gynecological specimens.The cobas® PCR Media Uni Swab Sample Kit is used to collect and transport human specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium for human specimensThe cobas® PCR Urine Sample Kit is used to collect and transport urine specimens. The cobas® PCR Media serves as a nucleic acid stabilizing transport and storage medium for urine specimensSame

Page 8

Predicate Devicecobas® CT/NG for use on the cobas® 6800/8800 systems (K173887)Subject Devicecobas® CT/NG for use on the cobas® 6800/8800 systems (claim extension)
Sample Types- Male and female urine,- Self-collected/clinician-collected vaginal swab specimens in cobas® PCR Media,- Endocervical swab specimens in cobas® PCR Media,- Cervical specimens in PreservCyt® solution- Male and female urine,- Self-collected/clinician-collected vaginal swab specimens in cobas® PCR Media,- Endocervical swab specimens in cobas® PCR Media,- oropharyngeal (throat) swab specimens in cobas® PCR Media,- anorectal swab specimens in cobas® PCR Media,- Cervical specimens in PreservCyt® solution
Reagentscobas® CT/NG KitSame
Positive Controlscobas® CT/NG Positive Control KitSame
Negative Controlscobas® 6800/8800 Buffer Negative Control KitSame
Subject StatusAsymptomatic and symptomaticSame
Sample Collection Devicescobas® PCR Media Dual Swab Sample Kitcobas® PCR Media Uni Swab Sample Kitcobas® PCR Urine Sample KitSame
CT Analyte targetsCT cryptic plasmid DNACT ompA geneSame
NG Analyte targetsNG genomic DNASame
Sample Preparation ProcedureAutomatedSame
Amplification TechnologyReal-time PCRSame
Detection ChemistryPaired reporter and quencher fluorescence labeled probes (TaqMan Technology) using fluorescence resonance energy transfer (FRET)Same
Result AnalysisBased on PCR cycle threshold analysisSame
Analyzercobas® 6800/8800 systemsSame

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4. NON-CLINICAL PERFORMANCE EVALUATION

4.1. Limit of Detection (LoD)

Analytical sensitivity (Limit of Detection or LoD) was determined by analyzing a dilution series of quantified cultures of Chlamydia trachomatis (serovars D and I) and Neisseria gonorrhoeae strains 2948 (ATCC 19424) and 891. CT and NG cultures were diluted into a matrix of pooled negative specimens of each sample type. All levels were analyzed across 3 unique lots of reagents. LoD for each specimen type is shown in Table 2 as the target concentration, which can be detected in ≥ 95% of the replicates for all lots.

Table 2: Analytical sensitivity (Limit of Detection)

Specimen TypesCT serovar D LoD (EB/mL)CT serovar D Mean Ct ValueCT serovar I LoD (EB/mL)CT serovar I Mean Ct ValueNG Strain 2948 LoD (CFU/mL)NG Strain 2948 Mean Ct ValueNG strain 891 LoD (CFU/mL)NG strain 891 Mean Ct Value
Oropharyngeal Swab in cobas® PCR Media237.34036.50.238.00.0837.3
Anorectal Swab in cobas® PCR Media237.22037.20.237.00.0837.2

*EB = Elementary Bodies, CFU= Colony Forming Units

4.2. Inclusivity

Inclusivity and verification of the LoD were performed for 13 additional CT serovars, the Swedish new variant strain (nvCT) and an additional 43 independently isolated strains of NG using one lot of reagents. Testing was performed using CT and NG cultures diluted into pools of negative specimens. Results are shown in Table 3 and Table 4 for CT serovars and NG strains, respectively.

Page 10

Table 3: Inclusivity and LoD verification for CT serovars

CT Serovar or VariantSwab Specimens EB/mL*Swab Specimens % Pos*
A40100%
B40100%
Ba40100%
C40100%
E40100%
F40100%
G40100%
H40100%
J40100%
K40100%
LGV Type 140100%
LGV Type 240100%
LGV Type 340100%
nvCT40100%

*Includes all swab sample types.

Table 4: Inclusivity and LoD verification for NG strains

Numbers of NG Strains (43 strains)Swab Specimens CFU/mL (% Pos)*
390.4 (≥ 95%)
41.0 (≥ 95%)
  • Includes all swab sample types.

4.3. Analytical specificity/Cross reactivity

A panel of 178 bacteria, fungi and viruses was tested in all specimen types to assess analytical specificity (Table 5). Multiple strains were tested for several organisms, including 20 representatives of non-gonorrhoeae Neisseria strains. High titer stocks of the potentially cross-reacting microorganisms were spiked into pools of negative oropharyngeal or anorectal swab specimens to a concentration level of 1.0E+06 units/mL (EB or CFU/mL) for bacteria and yeast, and 1.0E+05 units/mL (as cells/mL for protozoa or as determined by TCID50 Endpoint Dilution Assay for viruses). Testing was performed with each potentially interfering organism alone as well as with each organism mixed with 6 EB/mL of CT serovar D culture and

Page 11

0.6 CFU/mL of NG strain 2948 (ATCC 19424) culture. Results indicated that none of these organisms interfered with the detection of CT and NG or produced false positive results in the CT/NG negative matrices.

Table 5: Microorganisms tested for analytical specificity/cross reactivity

Achromobacter xerosisFusobacterium nucleatumNorovirus* ‡‡
Acinetobacter baumannii ‡‡Gardnerella vaginalisPantoea agglomerans
Acinetobacter calcoaceticusGemella haemolysansParacoccus denitrificans
Acinetobacter lwoffiGiardia lamblia ‡‡Parvinomas micra ‡
Actinomyces israeliiHaemophilus ducreyiPeptostreptococcus anaerobius
Adenovirus ‡Haemophilus influenzaePeptostreptococcus asaccharolyticus
Aerococcus viridansHelicobacter pyloriPeptostreptococcus magnus
Aeromonas hydrophilaHerpes simplex virus IPlesiomonas shigelloides
Aggregatibacter actinomycetemcomitans ‡‡Herpes simplex virus II *Porphyromonas gingivalis ‡
Alcaligenes faecalisHPV16 ***Prevotella bivia ‡‡‡
Anaerococcus prevotii ‡‡Human influenza virus A ‡Prevotella oralis ‡
Arcanobacterium haemolyticum ‡Human influenza virus B ‡Propionibacterium acnes
Atopobium vaginaeHuman metapneumovirus ‡Proteus mirabilis
Bacillus subtilisKingella dentrificansProteus penneri
Bacteriodes fragilisKingella kingaeProteus vulgaris
Bacteroides caccaeKlebsiella oxytocaProvidencia rettgeri
Bacteroides ureolyticusKlebsiella pneumoniaeProvidencia stuartii
Bergeriella denitrificansLactobacillus acidophillusPseudomonas aeruginosa
Bifidobacterium adolescentisLactobacillus brevisPseudomonas fluorescens
Bifidobacterium breveLactobacillus crispatusPseudomonas putida
Bifidobacterium longumLactobacillus jenseniiRahnella aquatilis
Blautia productaLactobacillus lactisRespiratory syncytial virus ‡
Bordetella pertussis ‡Lactobacillus leichmanniiRhinovirus* ‡
Branhamella catarrhalisLactobacillus orisRhizobium radiobacter
Brevibacterium linensLactobacillus parabuchnerriRhodospirillum rubrum
Campylobacter coliLactobacillus reuteriSaccharomyces cerevisiae
Campylobacter jejuniLactobacillus vaginalisSalmonella choleraesuis
Campylobacter rectus ‡Lactococcus lactis cremorisSalmonella minnesota
Candida albicansLegionella pneumophilaSalmonella typhimurium
Candida glabrataLeuconostoc paramensenteroidesSerratia denitrificans
Candida parapsilosisListeria monocytogenesSerratia marcescens
Candida tropicalisMicrococcus luteusShigella dysenteriae

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Chlamydophila pneumoniaeMoraxella catarrhalis ‡Shigella flexneri ‡‡
Chlamydophila psittaciMoraxella lacunataShigella sonnei ‡‡
Chromobacter violaceumMoraxella osloensisStaphylococcus aureus
Citrobacter freundiiMorganella morganiiStaphylococcus epidermidis
Clostridioides difficileMycobacterium smegmatisStaphylococcus saprophyticus
Clostridium perfringensMycoplasma pneumoniae ‡Streptococcus agalactiae
Coronavirus ‡Mycoplasma genitalium**Streptococcus anginosus
Corynebacterium diphtheriae ‡Mycoplasma hominisStreptococcus bovis
Corynebacterium genitaliumNeisseria cinereaStreptococcus dysgalactiae
Corynebacterium xerosisNeisseria elongata subsp. elongataStreptococcus equinis
Cryptococcus neoformansNeisseria elongata subsp. nitroreducensStreptococcus mitis
Cytomegalovirus *Neisseria flavaStreptococcus mutans
Deinococcus radioduransNeisseria flavescensStreptococcus pneumoniae
Derxia gummosaNeisseria kochiStreptococcus pyogenes
Eikenella corrodensNeisseria lactamicaStreptococcus salivarius
Entamoeba histolytica* ‡‡Neisseria macacaeStreptococcus sanguis
Enterobacter aerogenesNeisseria meningitides Serogroup W135Streptomyces griseinus
Enterobacter cloacaeNeisseria meningitidis Serogroup ATannerella forsythia ‡
Enterococcus aviumNeisseria meningitidis Serogroup BTreponema denticola ‡
Enterococcus casseliflavusNeisseria meningitidis Serogroup CTrichomonas vaginalis
Enterococcus faecalisNeisseria meningitidis Serogroup DTrueperella pyogenes
Enterococcus faeciumNeisseria meningitidis Serogroup YUreaplasma urealyticum
Enterovirus* ‡‡Neisseria mucosaVeillonela parvula
Erysipelothrix rhusiopathiaeNeisseria perflavaVibrio cholerae
Escherichia coliNeisseria polysacchareaVibrio parahaemolyticus
Escherichia fergusoniiNeisseria siccaYersinia enterocolitica
Flavobacterium meningosepticumNeisseria subflava-
Fusobacterium necrophorum ‡Neisseria weaverii-
  • organism was tested at a concentration of 1 x E04 Units/mL
    ** organism was tested at a concentration of 1 x E05 CFU/mL
    *** HPV16 was tested as CaSki cells
    ‡ Tested in oropharyngeal swabs only
    ‡‡ Tested in anorectal swabs only
    ‡‡‡ Tested in oropharyngeal and anorectal swabs only

4.4. Interference

The effects of over-the-counter (OTC) products that may be present in oropharyngeal and anorectal specimens (Table 6 and Table 7), were evaluated. Testing was done using pooled oropharyngeal and anorectal clinical specimens by spiking of potential interferents at levels

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expected from a typical clinical patient sampling. Interferents were tested in CT/NG negative specimen pools as well as in specimen pools spiked with Chlamydia trachomatis culture at the levels ranging from 6 to 120 EB/mL and Neisseria gonorrhoeae culture at the levels ranging from 0.24 to 0.6 CFU/mL, depending on the specimen type tested. CT serovars D and I, and NG strains 2948 (ATCC 19424) and 891 were used in this study.

None of the OTC oral hygiene products tested in oropharyngeal swabs or OTC anorectal hygiene products tested in anorectal swabs caused interference to the test when examined at concentrations expected through typical product use.

Table 6: List of substances tested for interference in Oropharyngeal Samples

Product NameOropharyngeal Swabs (mg/mL)
Cepacol Maximum Strength Throat Drop Lozenges7.5
Colgate Total ToothpasteResidual *
Robitussin Cough / Chest Congestion Cough Syrup4.4
Listerine Ultra Clean Antiseptic Mouthwash15.8
Scope Mouthwash20.1
Sucrets Complete Lozenges5.8
Vicks - Chloraseptic Sore Throat Spray Menthol18.1
Zicam Oral Mist12.2
  • Amount of toothpaste present on a swab collected immediately following a subject's brushing of their teeth

Table 7: List of substances tested for interference in Anorectal samples

Product NameAnorectal Swabs (mg/mL)
ANUSOL® Plus Ointment5.3
CB Fleet® Mineral Oil Enema4.8
Doproct Suppositories/ Hemorrhoidal Treatment4.9
K-Y Jelly5.0
Lotrimin Antifungal Cream4.2
Preparation H Hemorrhoidal Ointment4.9
PREPARATION H Hemorrhoidal Suppositories6.0
Driminate Generic for Dramamine Motion Sickness - Major Pharmaceuticals0.6
Target – Triple Paste Diaper Rash Ointment4.3
Tucks Medicated Cooling Hemorrhoidal Pads35.6
Vaseline Original Petroleum Jelly4.7

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Endogenous substances that may be present in oropharyngeal and anorectal specimens were tested for interference. The summary of acceptable levels of endogenous substances tested for oropharyngeal and anorectal samples are listed in Table 8. No interference was noted when testing oropharyngeal swab specimens collected in cobas® PCR Media. Stool caused interference at 0.4% (w/v) in anorectal swab specimens collected in cobas® PCR Media, however no interference was noted when testing anorectal swab specimens containing 0.3% (w/v) of stool.

Table 8: List of endogenous substance tested for interference in Oropharyngeal Anorectal samples

InterferentOropharyngeal SwabAnorectal Swab
Mucus (% w/v)1.0%1.0%
Peripheral Blood Mononuclear Cells (PBMCs as cells/mL)1.00E+061.00E+06
Saliva (% w/v)2.0%NT
Stool (% w/v)NT0.3%
Whole Blood (% v/v)10%10%

NT = Not Tested

5. CLINICAL PERFORMANCE EVALUATION

5.1. Clinical Performance

5.1.1. Study Design

The clinical utility and performance of cobas® CT/NG was established in a multi-site, prospective collection study by comparing the results to an Infection Status (IS) that used a combination of commercially available CT/NG assays using anorectal or oropharyngeal swab samples. The subjects were enrolled from 8 geographically diverse clinic sites (STD, HIV, Family Planning, and STD Research).

Specimens were tested for CT and NG using cobas® CT/NG and commercially available NAATs. All tests were run according to the respective manufacturers' Instructions For Use.

The clinical performance of cobas® CT/NG was determined by comparing the results from collected specimen types to a IS (Infected Status). A positive IS interpretation was derived when

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at least 2 of the 3 comparator reference assays were positive. The IS interpretations are further outlined in Table 9 below.

Table 9: Comparator Interpretation of Infection Status from "NAAT A" NAAT B" NAAT C" results for each specimen type

NAAT ANAAT BNAAT CIS Interpretation
++++
++-+
+-++
-+++
U+++
+U++
++U+
+---
-+--
--+-
----
++++
++-+
+-++
-+++
+---
-+--
--+-
----
U---
-U--
--U-
+U-U
+ or -UUU

IS = Infection status; + denotes Positive, - denotes Negative ; U = uninterpretable test result.

Note: Uninterpretable test results occurred when retesting of invalid or equivocal results failed to yield a positive or negative result.

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5.1.2. Results

A total of 2,439 subjects were consented to participate in this study, however, a total of 49 subjects were excluded, based on exclusion/inclusion criteria, that led to a total subject enrollment of 2,390. Of the 2,390 subjects contributing specimens, 2,365 anorectal and 2,382 oropharyngeal specimens were tested. Out of the 4,747 samples (2,365 rectal swabs and 2,382 oropharyngeal swabs), there were four final invalid results due to processing errors.

Table 10 summarizes the results from evaluable subjects designated as CT positive or negative according to the IS algorithm for both Anorectal(AR) and Oropharyngeal(OP) specimens.

Table 10: Chlamydia trachomatis: Summary of Infection status Interpretation for Anorectal and Oropharyngeal Specimen Types

Specimen Type^aNAAT ANAAT BNAAT CIS^b Interpretationcobas® CT/NGSS^c Symp^dSS^c Asymp^dSS^c Miss^dTotal
ARInv++Positive+1304
AR-++Positive-0303
AR-++Positive+412016
AR+-+Positive-0101
AR++-Positive+1001
AR+++Positive-2103
AR+++Positive+47680115
ARTotal Positive55880143
ARInv--Negative-2945175
AR-NA-Negative-72312
AR-NA-Negative+0101
AR-Inv-Negative-3306
AR--InvNegative-0101
AR--InvNegative+1001
AR---Negative-6351,411132,059
AR---Negative+5207
AR--+Negative-412016
AR--+Negative+0606
AR-+-Negative-1506
AR-+-Negative+1102
ARTotal Negative6861,489172,192

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Specimen Type^aNAAT ANAAT BNAAT CIS^b Interpretationcobas® CT/NGSS^c Symp^dSS^c Asymp^dSS^c Miss^dTotal
OPInv++Positive+0101
OP-++Positive+1203
OP++-Positive+0101
OP+++Positive+815023
OPTotal Positive919028
OPInv--Negative-3246179
OP-NA-Negative-57214
OP-Inv-Negative-1607
OP--InvNegative-1001
OP---Negative-6791,486142,179
OP---Negative+2002
OP--+Negative-1316029
OP-+-Negative-1102
OP-+-Negative+0202
OP+--Negative-1102
OPTotal Negative7351,565172,317

^a AR = anorectal; OP=oropharyngeal
^b IS = infection status.
^c SS = symptom status;
Symp = symptomatic, Asymp = asymptomatic, Miss = missing symptom status.

Note: NA = Not available, Inv = Invalid.

Note: Infection Status (IS) is determined for each specimen type. The IS of a sample will be established by the concordance results from at least 2 out of 3 comparator assays (NAAT A, NAAT B, NAAT C). If one of the comparator assays is Uninterpretable/Invalid/Failed, the two remaining assays must be concordant to define the IS as Positive (+) or Negative (-). Any other combination of Uninterpretable/Invalid/Failed and valid results are excluded from the analyses.

Note: Of the 2,365 contributing subjects for Rectum, 18 subjects had CT uninterpretable IS. Similarly, of the 2,382 contributing subjects for Oropharyngeal, 23 subjects had CT uninterpretable IS.

The overall point estimate of cobas® CT/NG sensitivity for CT detection was 95.1% with a 95% CI of 90.2% to 97.6% for anorectal specimens and 100.0% with a 95% CI of 87.9% to 100% for oropharyngeal specimens. The sensitivity estimates were similar between asymptomatic and symptomatic subjects with overlapping two-sided 95% CIs (Table 11).

The overall point estimate of cobas® CT/NG specificity for CT was 99.2% with a 95% CI of 98.8% to 99.5% for anorectal specimens and 99.8% with a 95% CI of 99.6% to 99.9% for oropharyngeal specimens. The specificity estimates were similar between asymptomatic and symptomatic subjects with overlapping two-sided 95% CIs (Table 11).

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Table 11: Chlamydia trachomatis: Overall Clinical Performance Compared with Infection Status by Sample Type and Symptom Status

Sample Type^aSymptom Status^bTotal (N)SENS95% Score CISPEC95% Score CIPREV (%)PPVNPV
ARSymp74196.4% (53/55)(87.7%, 99.0%)99.0% (679/686)(97.9%, 99.5%)7.488.3% (53/60)99.7% (679/681)
ARAsymp1,57794.3% (83/88)(87.4%, 97.5%)99.3% (1479/1489)(98.8%, 99.6%)5.689.2% (83/93)99.7% (1479/1484)
ARUnknown17NENE100.0% (17/17)(81.6%, 100.0%)0.0NE100.0% (17/17)
AROverall2,33595.1% (136/143)(90.2%, 97.6%)99.2% (2175/2192)(98.8%, 99.5%)6.188.9% (136/153)99.7% (2175/2182)
OPSymp744100.0% (9/9)(70.1%, 100.0%)99.7% (733/735)(99.0%, 99.9%)1.281.8% (9/11)100.0% (733/733)
OPAsymp1,584100.0% (19/19)(83.2%, 100.0%)99.9% (1563/1565)(99.5%, 100.0%)1.290.5% (19/21)100.0% (1563/1563)
OPUnknown17NENE100.0% (17/17)(81.6%, 100.0%)0.0NE100.0% (17/17)
OPOverall2,345100.0% (28/28)(87.9%, 100.0%)99.8% (2313/2317)(99.6%, 99.9%)1.287.5% (28/32)100.0% (2313/2313)

^a AR = anorectal, OP = oropharyngeal.
^b Symp = symptomatic, Asymp = asymptomatic.

Note: CI = confidence interval, PREV = prevalence; SENS = sensitivity; SPEC = specificity; PPV = positive predictive value; NPV = negative predictive value; NE =non-estimable.

Note: The predictive values shown above reflect performance specific to the clinical study population and may not be applicable to all individuals in the intended use population.

Table 12 summarizes the results from evaluable subjects designated as NG positive or negative according to the IS algorithm for both anorectal and Oropharyngeal specimens.

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Table 12: Neisseria gonorrhoeae: Summary of Infection status Interpretation for Anorectal and Oropharyngeal Specimen Types

Specimen Type^aNAAT ANAAT BNAAT CIS^b Interpretationcobas® CT/NGSS^d Symp^cSS^d Asymp^cSS^d Miss^cTotal
ARInv++Positive+2002
AR-++Positive-1001
AR-++Positive+3407
AR+NA+Positive+0101
AR+Inv+Positive+0101
AR+-+Positive+0101
AR+++Positive+3750188
ARTotal Positive43571101
ARInv--Negative-2750178
ARInv--Negative+1001
AR-NA-Negative-72312
AR-Inv-Negative-3205
AR---Negative-6461,461122,119
AR---Negative+3306
AR--+Negative-5005
AR--+Negative+6107
AR-+-Negative-0202
AR+--Negative-0101
AR+--Negative+1001
ARTotal Negative6991,522162,237
OPInv++Positive+1102
OP-++Positive+98017
OP+NA+Positive+0101
OP+Inv+Positive+0101
OP+-+Positive+1203
OP++-Positive+0101
OP+++Positive+4130071
OPTotal Positive5244096
OPInv--Negative-3053184
OP-NA-Negative-56213
OP-Inv-Negative-0505
OP--InvNegative-2002
OP--InvNegative+1001

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Specimen Type^aNAAT ANAAT BNAAT CIS^b Interpretationcobas® CT/NGSS^d Symp^cSS^d Asymp^cSS^d Miss^cTotal
OP---Negative-6311,452132,096
OP---Negative+67114
OP--+Negative-4307
OP--+Negative+4408
OP-+-Negative-515020
OP-+-Negative+0101
OP+--Negative-1001
OP+--Negative+0101
OPTotal Negative6891,547172,253

^a AR = anorectal; OP = oropharyngeal.
^b IS= infection status
^c Symp = symptomatic, Asymp = asymptomatic, Miss = missing symptom status.
^d SS=symptom status

Note: NA = Not available, Inv = Invalid.

Note: Infection status (IS) is determined for each specimen type. The IS of a sample will be established by the concordance results from at least 2 out of 3 comparator assays (NAAT A, NAAT B, NAAT C). If one of the comparator assays is Uninterpretable/Invalid/Failed, the two remaining assays must be concordant to define the IS as Positive (+) or Negative.Any othercombination of Uninterpretable/Invalid/Failed and valid results are excluded from analyses.

Note: Of the 2,365 contributing subjects for Rectum, 15 subjects had NG uninterpretable IS. Similarly, of the 2,382 contributing subjects for Oropharyngeal, 19 subjects had NG uninterpretable IS.

The overall point estimate of cobas® CT/NG sensitivity for NG detection was 99.0%, with a 95% CI of 94.6% to 99.8% for anorectal specimens and 100.0% with a 95% CI of 96.2% to 100% for Oropharyngeal specimens. The sensitivity estimates was 97.7% (42/43) and 100% (57/57) in anorectal specimens for symptomatic and asymptomatic subjects respectively (Table 13).

The overall point estimate of cobas® CT/NG specificity for NG was 99.3% with a 95% CI of 98.9% to 99.6% for anorectal specimens and 98.9% with a 95% CI of 98.4% to 99.2% for Oropharyngeal specimens. The specificity estimates were similar between asymptomatic and symptomatic subjects (Table 13).

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Table 13: Neisseria gonorrhoeae: Overall Clinical Performance Compared with Infection status by Sample Type and Symptom Status

Sample Type^aSymptom Status^bTotal (N)SENS95% Score CISPEC95% Score CIPREV (%)PPVNPV
ARSymp74297.7% (42/43)(87.9%, 99.6%)98.4% (688/699)(97.2%, 99.1%)5.879.2% (42/53)99.9% (688/689)
ARAsymp1,579100.0% (57/57)(93.7%, 100.0%)99.7% (1518/1522)(99.3%, 99.9%)3.693.4% (57/61)100.0% (1518/1518)
ARUnknown17100.0% (1/1)(20.7%, 100.0%)100.0% (16/16)(80.6%, 100.0%)5.9100.0% (1/1)100.0% (16/16)
AROverall2,33899.0% (100/101)(94.6%, 99.8%)99.3% (2222/2237)(98.9%, 99.6%)4.387.0% (100/115)100.0% (2222/2223)
OPSymp741100.0% (52/52)(93.1%, 100.0%)98.4% (678/689)(97.2%, 99.1%)7.082.5% (52/63)100.0% (678/678)
OPAsymp1,591100.0% (44/44)(92.0%, 100.0%)99.2% (1534/1547)(98.6%, 99.5%)2.877.2% (44/57)100.0% (1534/1534)
OPUnknown17NENE94.1% (16/17)(73.0%, 99.0%)0.00.0% (0/1)100.0% (16/16)
OPOverall2,349100.0% (96/96)(96.2%, 100.0%)98.9% (2228/2253)(98.4%, 99.2%)4.179.3% (96/121)100.0% (2228/2228)

^a AR = anorectal; OP = oropharyngeal.
^b Symp = symptomatic, Asymp = asymptomatic

Note: CI = confidence interval, PREV = prevalence, SENS = sensitivity, SPEC = specificity, PPV = positive predictive value, NPV = negative predictive value, NE = non-estimable.

Note: The predictive values shown above reflect performance specific to the clinical study population and may not be applicable to all individuals in the intended use population.

6. CONCLUSIONS

The cobas® CT/NG for use on the cobas® 6800/8800 systems is the same as the device cleared in K173887. There have been no changes to the device to accommodate this claim expansion to include oropharyngeal and anorectal swab specimens.

A comparison of the technological characteristics and conclusions drawn from the nonclinical studies and clinical study demonstrate that the device is substantially equivalent and performs as well as the legally marketed predicate device identified above.

§ 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.