(308 days)
The Dexcom G6 Glucose Program Continuous Glucose Monitoring System (Dexcom Glucose Program System) is a real time, continuous glucose monitoring device indicated for the management of diabetes in persons 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 several sequential 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 Glucose Program Continuous Glucose Monitoring (CGM) System measures and displays glucose values and trends for patients with diabetes who are not at significant risk of severe hypoglycemia. The system is factory calibrated and provides continuous glucose readings at five-minute intervals for up to ten days of use. The system consists of a sensor/applicator, a Bluetooth Low Energy (BLE) transmitter, and a BLE enabled mobile CGM display.
The sensor is a small and flexible wire, which is 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. The transmitter 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 mobile CGM displays the current glucose reading (updated every 5 minutes) and glucose trends. The mobile CGM display does not include any glucose related alarm or alerts but will alert the user when important system conditions occur.
The subject of this submission is a change to the primary display mobile device software. Compared to the predicate device which uses a standalone mobile CGM application, the proposed Glucose Program System uses a new mobile CGM software module (app module) that is embedded within a third party program provider's mobile app (host app).
This change is to help encourage CGM retention for those not at significant risk of severe hypoglycemia by providing Dexcom Glucose Program CGM functions and program provider's functions on a single unified mobile application. The app module is designed as a finished sovereign software that interacts directly with smart device hardware/operating system and maintains the same core CGM functionality as the predicate device, independent of the host app. The proposed Glucose Program System uses the same sensor/applicator and transmitter as the predicate device, with only changes to the mobile CGM software.
The change to the primary display mobile device software described in this submission does not impact the standalone G6 mobile application used in the G6 CGM System (last cleared K200876) and only affects the Glucose Program System which is designed for payor-sponsored, valuebased health programs.
The document describes the Dexcom G6 Glucose Program Continuous Glucose Monitoring (CGM) System and its comparison to a predicate device (K200876). The core of the information provided shows that the new device, referred to as the "subject device," is substantially equivalent to the predicate, with the primary change being a modification to the mobile display software.
Here's an analysis of the provided text in relation to the requested information:
1. Table of acceptance criteria and the reported device performance
The document does not explicitly present a table of acceptance criteria with corresponding reported device performance values. Instead, it asserts "substantial equivalence" to a predicate device, implying that the subject device meets the same performance standards as the predicate. The description highlights that the subject device "has the same core CGM functionality and meets the same system requirements as the predicate G6 Glucose Program System."
2. Sample size used for the test set and the data provenance
The document does not specify a sample size for a test set that was used to prove the device meets acceptance criteria. It mentions that "All testing referenced in the predicate device (K200876) in accordance with special controls for integrated continuous glucose monitors remain applicable." This suggests that new clinical performance testing with human subjects was not conducted for this specific submission because the underlying hardware and core algorithms are the same as the predicate.
Regarding data provenance (country of origin, retrospective/prospective), this information is also not provided as new clinical trials were not detailed for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided in the document. As stated above, new clinical performance data from human subjects is not detailed for this submission, as the claim is based on substantial equivalence to a predicate device for which such testing would have been performed.
4. Adjudication method for the test set
This information is not provided in the document.
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
This type of study is not applicable to this device. The Dexcom G6 Glucose Program CGM System is a continuous glucose monitoring device, not an AI-assisted diagnostic imaging or interpretation tool that would involve "human readers" in the context of an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The device itself is a continuous glucose monitoring system with an onboard algorithm that converts sensor measurements into estimated glucose values. The document states, "The transmitter samples the electrical current produced by the sensor and converts these measurements into estimated glucose values (EGV) using an onboard algorithm." This confirms a standalone algorithm that processes raw sensor data. The claim of substantial equivalence implies that the performance of this standalone algorithm has been previously validated as part of the predicate device's clearance.
7. The type of ground truth used
For a glucose monitoring device, the typical "ground truth" for evaluating accuracy would be laboratory reference standard blood glucose measurements (e.g., from a YSI analyzer). While the document doesn't explicitly state the ground truth used for this specific submission, it relies on the predicate device's clearance, which would have established accuracy against such a standard. The section "Glucose Value Estimation Algorithm" mentions an "Optimized Joint Probability Algorithm with improved data availability," which would be evaluated against such ground truth.
8. The sample size for the training set
The document does not provide information regarding the sample size for the training set. This is likely because the core algorithm remains the same as the predicate device, and new training data for algorithm development is not part of this specific submission.
9. How the ground truth for the training set was established
The document does not provide this information. It only states that the "Optimized Joint Probability Algorithm" is used, implying that any training and its associated ground truth establishment would have occurred during the development of this algorithm (likely for the predicate device).
§ 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.