K Number
K212495
Device Name
Leva Pelvic Health System
Manufacturer
Date Cleared
2021-09-08

(30 days)

Product Code
Regulation Number
884.1425
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The leva Pelvic Health System is intended for: 1) Strengthening of the pelvic floor muscles; 2) Rehabilitation and training of weak pelvic floor muscles for the treatment of stress, mixed and mild to moderate urgency urinary incontinence (including overactive bladder) in women. This device interacts with the user via smart phone technology.
Device Description
The leva Pelvic Health System ("leva System") is a prescription intra-vaginal device designed to allow the user (or woman) to rehabilitate and strengthen their pelvic floor muscles (PFM) as well as allow them to monitor their progress during pelvic floor muscle training (PFMT). The leva system is designed to wirelessly facilitate PFMT in women and to transmit real-time performance data through a dedicated mobile application that has been downloaded onto the patient's mobile device. The leva system is designed to be used vaginally and is intended to be used repeatedly by a single patient. The leva PHS consists of a probe, storage case, associated batteries, and the Renovia Digital Health App (App). Thermoplastic elastomer (TPE) was used as the material overlay for the electronics and six accelerometers are contained within the probe. Additional electronics are contained in the storage case to transmit data wirelessly between the device and the App.
More Information

Not Found

No
The summary describes a device that uses accelerometers to collect data and a mobile app to display it and provide educational content. There is no mention of AI or ML being used for data analysis, interpretation, or personalized feedback beyond basic progress monitoring.

Yes.
The device is intended for "strengthening of the pelvic floor muscles" and "rehabilitation and training of weak pelvic floor muscles for the treatment of stress, mixed and mild to moderate urgency urinary incontinence," which are therapeutic applications.

No

The device is described as an intra-vaginal device designed to allow the user to strengthen and rehabilitate pelvic floor muscles and monitor progress during training. Its intended uses relate to strengthening and rehabilitation, not diagnosis. While it transmits "real-time performance data" and has "diagnostic" modifications in its firmware, its primary purpose, and intended use as stated, is therapeutic.

No

The device description explicitly states that the system consists of a probe, storage case, batteries, and the mobile application. It also mentions hardware components like accelerometers within the probe and electronics in the storage case. This indicates it is a hardware device with accompanying software, not a software-only medical device.

Based on the provided information, the leva Pelvic Health System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is for strengthening and rehabilitation of pelvic floor muscles for the treatment of urinary incontinence. This is a therapeutic and monitoring function, not a diagnostic one.
  • Device Description: The device is an intra-vaginal probe with accelerometers that measures muscle activity and transmits data. It does not analyze biological samples (like blood, urine, or tissue) to diagnose a condition.
  • Lack of IVD Characteristics: The description does not mention any components or processes related to in vitro analysis of biological specimens, which is the defining characteristic of an IVD.

Therefore, the leva Pelvic Health System falls under the category of a therapeutic and monitoring medical device, not an IVD.

N/A

Intended Use / Indications for Use

The leva Pelvic Health System is intended for:

  1. Strengthening of the pelvic floor muscles;

  2. Rehabilitation and training of weak pelvic floor muscles for the treatment of stress, mixed and mild to moderate urgency urinary incontinence (including overactive bladder) in women.

This device interacts with the user via smart phone technology.

Product codes

HIR

Device Description

The leva Pelvic Health System ("leva System") is a prescription intra-vaginal device designed to allow the user (or woman) to rehabilitate and strengthen their pelvic floor muscles (PFM) as well as allow them to monitor their progress during pelvic floor muscle training (PFMT). The leva system is designed to wirelessly facilitate PFMT in women and to transmit real-time performance data through a dedicated mobile application that has been downloaded onto the patient's mobile device. The leva system is designed to be used vaginally and is intended to be used repeatedly by a single patient.

The leva PHS consists of a probe, storage case, associated batteries, and the Renovia Digital Health App (App). Thermoplastic elastomer (TPE) was used as the material overlay for the electronics and six accelerometers are contained within the probe. Additional electronics are contained in the storage case to transmit data wirelessly between the device and the App.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Vagina

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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)

The following non-clinical performance testing and risk analysis was performed to support modifications to the leva Pelvic Health System:

A. Biocompatibility
Biocompatibility assessment was done, as needed, based on the changes made to the device. To ensure patientsafety, all the patient-contacting material was subjected to biocompatibility testing in compliance with ISO 10993-1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process, for mucosal surface for limited, less than 24 hours duration including:

  • Cytotoxicity (ISO 10993-5)
  • . Sensitization (ISO 10993-10)
  • Irritation (ISO 10993-10)
    Biocompatibility testing demonstrated that the subject device, leva Pelvic Health System, is as safe and effective, and performs as well as the predicate device, leva Pelvic Digital Health System.

B. The sponsor reported other changes in this special 510 (k) which are stated below:

  • Hardware (H): Change of the adhesive on the battery case, Printed Circuit Board (PCB)/Printed Circuit . Board Assemblies (PCBA), battery vendor change, and product labeling modifications.

  • Embedded software (firmware) (F): Software changes related to performance improvement, communications, diagnostic and bug fix modifications.

  • . Mobile Application Software (RA): Updates and enhancements for bug fixes and addition/modification of general content (e.g., educational videos added) to provide additional information and clarity to improve the user experience.

  • Manufacturing (M) and Risk Analysis (D): Manufacturing quality control related changes and updates to the risk analysis modifications.
    The following testing was done on the subject device to ensure that the device continues to meet the requirements for substantial equivalence:

  • Software and firmware design verification testing

  • Manufacturing testing protocol verification
    All the changes reported above are minor and did not alter the substantial equivalence of the leva Pelvic Health System.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K192270

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 884.1425 Perineometer.

(a)
Identification. A perineometer is a device consisting of a fluid-filled sack for intravaginal use that is attached to an external manometer. The devices measure the strength of the perineal muscles by offering resistence to a patient's voluntary contractions of these muscles and is used to diagnose and to correct, through exercise, uninary incontinence or sexual dysfunction.(b)
Classification. Class II (performance standards).

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September 8, 2021

Renovia, Inc. % Jacqueline Schmainda Director, QA/RA Bold Type 2100 N. Alafaya Trail Orlando, FL 32826

Re: K212495

Trade/Device Name: leva Pelvic Health System Regulation Number: 21 CFR §884.1425 Regulation Name: Perineometer Regulatory Class: II Product Code: HIR Dated: August 6, 2021 Received: August 9, 2021

Dear Jacqueline Schmainda:

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.

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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 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-regulatoryinformation/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-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-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,

Jessica K. Nguyen, Ph.D. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.

510(k) Number (if known)

K212495

Device Name leva Pelvic Health System

Indications for Use (Describe)

The leva Pelvic Health System is intended for:

  1. Strengthening of the pelvic floor muscles;

  2. Rehabilitation and training of weak pelvic floor muscles for the treatment of stress, mixed and mild to moderate urgency urinary incontinence (including overactive bladder) in women.

This device interacts with the user via smart phone technology.

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.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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This 510(k) Summary has been prepared in accordance with 21 CFR 807.92.

1. Submitter

| Name and Address: | Renovia Inc.
263 Summer Street
Boston, MA 02210 |
|-------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Primary Contact: | Jacqueline Schmainda
Regulatory Consultant on behalf of Renovia
Renovia Inc.
263 Summer Street
Boston, MA 02210
Phone: 763-269-2069
Email: jackie@boldtype.com |

Date Prepared: September 8, 2021

2. Device Information

Trade Name:leva Pelvic Health System
Model:leva-02
Common Name:Perineometer
Product Code:HIR
Regulatory Class:Class II
Classification Number:21 CFR 884.1425
Classification Name:Perineometer
Review Panel:Gastroenterology/Urology

3. Predicate Information

510(k) NumberTrade NameModelSubmitter
K192270leva Pelvic Digital Health SystemLeva-02Renovia Inc.

4. Device Description

The leva Pelvic Health System ("leva System") is a prescription intra-vaginal device designed to allow the user (or woman) to rehabilitate and strengthen their pelvic floor muscles (PFM) as well as allow them to monitor their progress during pelvic floor muscle training (PFMT). The leva system is designed to wirelessly facilitate PFMT in women and to transmit real-time performance data through a dedicated mobile application that has been downloaded onto the patient's mobile device. The leva system is designed to be used vaginally and is intended to be used repeatedly by a single patient.

The leva PHS consists of a probe, storage case, associated batteries, and the Renovia Digital Health App (App). Thermoplastic elastomer (TPE) was used as the material overlay for the electronics and six accelerometers are contained within the probe. Additional electronics are contained in the storage case to transmit data wirelessly between the device and the App.

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5. Indications for Use

The leva Pelvic Health System is intended for:

    1. Strengthening of the pelvic floor muscles;
    1. Rehabilitation and training of weak pelvic floor muscles for the treatment of stress, mixed and mild to moderate urgency urinary incontinence (including overactive bladder) in women.

This device interacts with the user via smart phone technology.

6. Comparison of Technological Characteristics

The following table provides a comparison of the leva Pelvic Health System to the predicate device.

CharacteristicPredicate DeviceSubject Device
Regulatory Information
Device Nameleva Pelvic Digital Health Systemleva Pelvic Health System
ManufacturerRenovia Inc.Renovia Inc.
Technological Characteristics
Principle of
OperationProvides indication of relative
intensity of pelvic floor muscle
contraction using accelerometersProvides indication of relative
intensity of pelvic floor muscle
contraction using accelerometers
Muscle StimulationNoNo
Intended Anatomical
LocationVaginaVagina
Use ModelSingle patient, reusableSingle patient, reusable
SterilityClean, non-sterileClean, non-sterile
Display InformationGraphical and numeric based on
applied bending, anatomical overlayGraphical and numeric based on
applied bending, anatomical overlay
Device Materials• Probe: Thermoplastic Elastomer
(TPE)
• Probe Battery Pack: Acrylonitrile
Butadiene Styrene (ABS)• Probe: Thermoplastic Elastomer
(TPE)
• Probe Battery Pack: Acrylonitrile
Butadiene Styrene (ABS)
Patient Contact
(Contact Duration)• Probe: Direct (