(136 days)
P980025
Not Found
Yes
The device description explicitly states it is "AI-powered" and mentions "Supervised Deep Learning".
No.
The device is a computer-assisted detection (CADe) device used to analyze radiographs for identifying and localizing carious lesions, which is a diagnostic function, not a therapeutic one.
Yes
The device "analyzes intraoral radiographs to identify and localize carious lesions" and "returns a set of bounding boxes representing the carious lesions detected," which directly points to a diagnostic function of identifying and localizing a medical condition (carious lesions).
Yes
The device description explicitly states "Videa Caries Assist (VCA) software is a cloud-based AI-powered medical device" and that it is "available as a service via an API". It processes existing images and provides results back, without including or requiring any specific hardware component for its primary function.
Based on the provided information, the Videa Caries Assist device is not an In Vitro Diagnostic (IVD).
Here's why:
- IVDs analyze biological samples: In Vitro Diagnostics are designed to examine specimens taken from the human body, such as blood, urine, tissue, etc., to provide information about a person's health.
- Videa Caries Assist analyzes images: The Videa Caries Assist analyzes intraoral radiographs (X-ray images). It processes image data, not biological samples.
The device falls under the category of medical image analysis software or computer-assisted detection (CADe) software for radiology. It aids in the interpretation of medical images, which is distinct from the analysis of biological samples performed by IVDs.
No
The provided text does not contain any explicit statement that the FDA has reviewed, approved, or cleared a Predetermined Change Control Plan (PCCP) for this specific device.
Intended Use / Indications for Use
Videa Caries Assist is a computer-assisted detection (CADe) device that analyzes intraoral radiographs to identify and localize carious lesions. Videa Caries Assist is indicated for use by board licensed dentists for the concurrent review of bitewing (BW) radiographs acquired from adult patients aged 22 years or older.
Product codes (comma separated list FDA assigned to the subject device)
MYN
Device Description
Videa Caries Assist (VCA) software is a cloud-based AI-powered medical device for the automatic detection of carious lesions in dental radiographs. The device itself is available as a service via an API (Application Programming Interface) behind a firewalled network. Provided proper authentication and a bitewing image, the device returns a set of bounding boxes representing the carious lesions detected.
VCA is accessed by the dental practitioner through their Dental Viewer. From within the Dental Viewer the user can upload a radiograph to VCA and then review the results. The device outputs a binary indication to identify the presence or absence of findings are present the device outputs the coordinates of the bounding boxes for each finding. If no findings are present the device outputs a clear indication that there are no carious lesions identified.
Mentions image processing
Yes
Mentions AI, DNN, or ML
Videa Caries Assist (VCA) software is a cloud-based AI-powered medical device for the automatic detection of carious lesions in dental radiographs.
Development Technology: Supervised Deep Learning
Input Imaging Modality
X-Ray
Anatomical Site
Not Found
Indicated Patient Age Range
adult patients aged 22 years or older.
Intended User / Care Setting
board licensed dentists
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
Bench Testing (Standalone Study): The dataset was 1034 adult radiographs collected from 10 US sites that were ground-truthed by three US board-certified dentists. The patients in the dataset were 53% female and 47% male, with 55% having age 22-40, 34% age 41-60, 9% age 61-75, and 2% over age 76. The number of lesions per image was: 0 lesions (39%), 1 lesions (22%), 2-3 lesions (26%), and 4+ lesions (13%). Image sensors included in the study were: DEXIS Platinum, DEXIS Titanium, Gendex GXS-700, Kodak RVG, 6100, RVG 5200, RVG 6200, and Schick 33.
Clinical Data (Reader Study): The dataset was 226 adult radiographs collected from 10 US sites that were ground-truthed by three US board-certified dentists. The patients in the dataset were 55% female and 45% male, with 49% having age 22-40, 38% age 41-60, 11% age 61-75, and 6% over age 76. Image sensors included in the study were: DEXIS Platinum, DEXIS Titanium, Gendex GXS-700, Kodak RVG, 6100, RVG 5200, RVG 6200, and Schick 33.
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Bench Testing (Standalone Study): A Standalone Performance Assessment was conducted to measure and report the performance of Videa Caries Assist by itself, in the absence of any interaction with a dentist. The dataset was 1034 adult radiographs. The standalone overall average Alternative Free-response Receiver Operating Characteristic Figure of Merit (AFROC FOM) was found to be 0.740 (95% confidence interval: 0.721, 0.760) with a corresponding average image-based Sensitivity of 70.8% and PPV of 59.5%. We observed a False Positive Fraction FPF of 0.335 and a Non-Lesion Fraction of 0.599. VCA's standalone performance was assessed against the following potential subject and image confounders: age, sex, number of lesions per image, image quality, imaging sensor model, effective resolution, bit-depth, and image size. We observed very good generalizability for all confounders with the exception of image sensor model, with all reported confidence intervals including 0.74, the average AFROC FOM calculated on the full dataset. We did observe a somewhat lower average AFROC FOM of 0.608 for the Schick 33 sensor.
Clinical Data (Reader Study): A fully crossed randomized, multiple reader multiple case (MRMC) controlled study was performed to determine whether the diagnostic accuracy of readers aided by VCA is superior to reader accuracy when unaided by VCA, as determined by the AFROC Figure of Merit (AFROC FOM). The dataset was 226 adult radiographs. The overall average AFROC FOM for reads aided by VCA was 0.739 as compared to 0.667 for unaided reads. The difference was 0.072 (95% CI: 0.047, 0.097; p
§ 892.2070 Medical image analyzer.
(a)
Identification. Medical image analyzers, including computer-assisted/aided detection (CADe) devices for mammography breast cancer, ultrasound breast lesions, radiograph lung nodules, and radiograph dental caries detection, is a prescription device that is intended to identify, mark, highlight, or in any other manner direct the clinicians' attention to portions of a radiology image that may reveal abnormalities during interpretation of patient radiology images by the clinicians. This device incorporates pattern recognition and data analysis capabilities and operates on previously acquired medical images. This device is not intended to replace the review by a qualified radiologist, and is not intended to be used for triage, or to recommend diagnosis.(b)
Classification. Class II (special controls). The special controls for this device are:(1) Design verification and validation must include:
(i) A detailed description of the image analysis algorithms including a description of the algorithm inputs and outputs, each major component or block, and algorithm limitations.
(ii) A detailed description of pre-specified performance testing methods and dataset(s) used to assess whether the device will improve reader performance as intended and to characterize the standalone device performance. Performance testing includes one or more standalone tests, side-by-side comparisons, or a reader study, as applicable.
(iii) Results from performance testing that demonstrate that the device improves reader performance in the intended use population when used in accordance with the instructions for use. The performance assessment must be based on appropriate diagnostic accuracy measures (
e.g., receiver operator characteristic plot, sensitivity, specificity, predictive value, and diagnostic likelihood ratio). The test dataset must contain a sufficient number of cases from important cohorts (e.g., subsets defined by clinically relevant confounders, effect modifiers, concomitant diseases, and subsets defined by image acquisition characteristics) such that the performance estimates and confidence intervals of the device for these individual subsets can be characterized for the intended use population and imaging equipment.(iv) Appropriate software documentation (
e.g., device hazard analysis; software requirements specification document; software design specification document; traceability analysis; description of verification and validation activities including system level test protocol, pass/fail criteria, and results; and cybersecurity).(2) Labeling must include the following:
(i) A detailed description of the patient population for which the device is indicated for use.
(ii) A detailed description of the intended reading protocol.
(iii) A detailed description of the intended user and user training that addresses appropriate reading protocols for the device.
(iv) A detailed description of the device inputs and outputs.
(v) A detailed description of compatible imaging hardware and imaging protocols.
(vi) Discussion of warnings, precautions, and limitations must include situations in which the device may fail or may not operate at its expected performance level (
e.g., poor image quality or for certain subpopulations), as applicable.(vii) Device operating instructions.
(viii) A detailed summary of the performance testing, including: test methods, dataset characteristics, results, and a summary of sub-analyses on case distributions stratified by relevant confounders, such as lesion and organ characteristics, disease stages, and imaging equipment.
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April 21, 2022
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 the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
VideaHealth, Inc % Donna-Bea Tillman Senior Consultant Biologics Consulting Group 1555 King St. Suite 300 ALEXANDRIA VA 22314
Re: K213795
Trade/Device Name: Videa Caries Assist Regulation Number: 21 CFR 892.2070 Regulation Name: Medical Image Analyzer Regulatory Class: Class II Product Code: MYN Dated: March 23, 2022 Received: March 24, 2022
Dear Donna-Bea Tillman:
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
1
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 https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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,
Laurel Burk, Ph.D. Assistant Director Diagnostic X-ray Systems Team 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
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Indications for Use
510(k) Number (if known) K213795
Device Name Videa Caries Assist
Indications for Use (Describe)
Videa Caries Assist is a computer-assisted detection (CADe) device that analyzes intraoral radiographs to identify and localize carious lesions. Videa Caries Assist is indicated for use by board licensed dentists for the concurrent review of bitewing (BW) radiographs acquired from adult patients aged 22 years or older.
| 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) |
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In accordance with 21 CFR 807.87(h) and 21 CFR 807.92 the 510(k) Summary for the Videa Caries Assist device is provided below.
1. SUBMITTER
| Applicant: | VideaHealth, Inc.
19 Kingston St, Floor 3
Boston, MA, 02114
+1 617-340-9940
florian.hillen@videahealth.io |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Florian Hillen
CEO and Founder
VideaHealth, Inc.
617-528-8643
florian.hillen@videahealth.io |
| Submission Correspondent: | Donna-Bea Tillman, Ph.D.
Senior Consultant
Biologics Consulting
1555 King St, Suite 300
Alexandria, VA 22314
410-531-6542
dtillman@biologicsconsulting.com |
| Date Prepared: | March 23, 2022 |
2. DEVICE
| Device Trade Name: | Videa Caries Assist |
|---|---|
| Device Common Name: | Medical Image Analyzer |
| Classification Name | 21 CFR 892.2070 Analyzer, Medical Image |
| Regulatory Class: | 2 |
| Product Code: | MYN |
3. PREDICATE DEVICE
Predicate Device: P980025 Logicon Caries Detection Software (Carestream Dental LLC)
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DEVICE DESCRIPTION 4.
Videa Caries Assist (VCA) software is a cloud-based AI-powered medical device for the automatic detection of carious lesions in dental radiographs. The device itself is available as a service via an API (Application Programming Interface) behind a firewalled network. Provided proper authentication and a bitewing image, the device returns a set of bounding boxes representing the carious lesions detected.
VCA is accessed by the dental practitioner through their Dental Viewer. From within the Dental Viewer the user can upload a radiograph to VCA and then review the results. The device outputs a binary indication to identify the presence or absence of findings are present the device outputs the coordinates of the bounding boxes for each finding. If no findings are present the device outputs a clear indication that there are no carious lesions identified.
INTENDED USE/INDICATIONS FOR USE ട്.
Videa Caries Assist is a computer-assisted detection (CADe) device that analyzes intraoral radiographs to identify and localize carious lesions. Videa Caries Assist is indicated for use by board licensed dentists for the concurrent review of bitewing (BW) radiographs acquired from adult patients aged 22 years or older.
SUBSTANTIAL EQUIVALENCE 6.
Comparison of Indications
Logicon Caries Detector and Videa Caries Assist both analyze dental radiographs and identify regions of interest. Logicon Caries Detector aids in diagnosis of caries that have penetrated in the dentin for each tooth, where Videa Caries Assist detects carious lesions for all types of caries lesions. However, both devices are only intended as an aid to the physician and not intended to replace the diagnosis by the physician. The differences in Indications for Use do not constitute a new intended use, as both devices are intended to assist dental professional by identifying and marking Regions of Interest (ROI) in dental radiographs.
Technological Comparisons
Table 1 compares the key technological feature of the subject devices to the predicate device (Logicon Caries Detector, P980025).
| Proposed Device | Predicate Device | |
|---|---|---|
| 510(k) Number | TBD | P980025 |
| Applicant | VideaHealth, Inc. | Carestream Dental LLC |
| Device Name | Videa Caries Assist | Logicon Caries Detector |
| Classification Regulation | 892.2070 | 892.2070 |
| Proposed Device | Predicate Device | |
| Product Code | MYN | MYN |
| Indications for Use | Videa Caries Assist is a | |
| computer-assisted detection | ||
| (CADe) device that analyzes | ||
| intraoral radiographs to | ||
| identify and localize carious | ||
| lesions. Videa Caries Assist is | ||
| indicated for use by board | ||
| licensed dentists for the | ||
| concurrent review of bitewing | ||
| (BW) radiographs acquired | ||
| from adult patients aged 22 | ||
| years or older. | Logicon Caries Detector is a | |
| software device that is an aid in the | ||
| diagnosis of caries that have | ||
| penetrated into the dentin on un- | ||
| restored proximal surfaces of | ||
| secondary dentition through the | ||
| statistical analysis of digital intra- | ||
| oral radiographic imagery. The | ||
| device provides additional | ||
| information for the clinician to use in | ||
| his/her diagnosis of a tooth surface | ||
| suspected of being carious. It is | ||
| designed to work in conjunction with | ||
| an existing CareStream Dental RVG | ||
| Digital X-Ray Radiographic System | ||
| with Dental Imaging Software (DIS) | ||
| for Windows XP or higher. | ||
| Image Modality | X-Ray | X-Ray |
| Study Type | Bitewing Images | Digital intra-oral radiographic |
| imagery | ||
| Clinical Finding | Active and Secondary Caries | |
| at all penetration depths | Caries penetrating into dentin | |
| Tooth Surface | Proximal, Buccal/Lingual, | |
| Occlusal, Root, Cervical | Proximal | |
| Clinical Output | Message indicating if and | |
| how many carious lesion were | ||
| detected | ||
| Set of togglable bounding | ||
| boxes around suspected | ||
| lesions | Message indicating if a carious | |
| lesion was detected. | ||
| An outline of the potential lesion site | ||
| is shown | ||
| Patient Population | Adults ≥ 22 years of age | Adults ≥ 22 years of age |
| Intended User | US licensed dentists | Dentists |
| Development Technology | Supervised Deep Learning | Computer Vision |
| Image Source | X-Ray Sensor | X-Ray Sensor |
| Image Viewing | Image Viewer | CareStream Dental RVG Digital X- |
| Ray Radiographic System with | ||
| Dental Imaging Software (DIS) |
Table 1: Technological Comparison
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7. PERFORMANCE DATA
Biocompatibility, Sterilization, and Reprocessing
Not applicable. The subject device is a software-only device. There are no direct or indirect patient-contacting components of the subject device. There are no sterile or reprocessed components.
Electrical Safety and Electromagnetic Compatibility (EMC)
Not applicable. The subject device is a software-only device. It contains no electric components, generates no electrical emissions, and uses no electrical energy of any type.
Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices." The software for this device was considered as a moderate level of concern.
Bench Testing (Standalone Study)
A Standalone Performance Assessment was conducted to measure and report the performance of Videa Caries Assist by itself, in the absence of any interaction with a dentist. The dataset was 1034 adult radiographs collected from 10 US sites that were ground-truthed by three US boardcertified dentists. The patients in the dataset were 53% female and 47% male, with 55% having age 22-40, 34% age 41-60, 9% age 61-75, and 2% over age 76. The number of lesions per image was: 0 lesions (39%), 1 lesions (22%), 2-3 lesions (26%), and 4+ lesions (13%). Image sensors included in the study were: DEXIS Platinum, DEXIS Titanium, Gendex GXS-700, Kodak RVG, 6100, RVG 5200, RVG 6200, and Schick 33.
The standalone overall average Alternative Free-response Receiver Operating Characteristic Figure of Merit (AFROC FOM) was found to be 0.740 (95% confidence interval: 0.721, 0.760) with a corresponding average image-based Sensitivity of 70.8% and PPV of 59.5% (Table 2).
| Mean | 95% Confidence Interval | |
|---|---|---|
| Overall average FOM | 0.740 | (0.721, 0.760) |
| Overall average Se - image-based (%) | 70.8 | (68.0, 73.7) |
| Overall average PPV - image-based (%) | 59.5 | (56.5, 62.5) |
| Overall average Se (%) - lesion-based (pooled) | 73.6 | (71.1, 76.0) |
| Overall average PPV (%) - lesion-based | ||
| (pooled) | 64.9 | (62.3, 67.6) |
Standalone: AFROC FOM, Image-based Se, PPV. Lesion-based estimates in italics. Table 2:
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We observed a False Positive Fraction FPF of 0.335 and a Non-Lesion Fraction of 0.599 Comparing these results with the results from the readers study shows a decrease in the absolute number of false positives per image.
VCA's standalone performance was assessed against the following potential subject and image confounders: age, sex, number of lesions per image, image quality, imaging sensor model, effective resolution, bit-depth, and image size. We observed very good generalizability for all confounders with the exception of image sensor model, with all reported confidence intervals including 0.74, the average AFROC FOM calculated on the full dataset. We did observe a somewhat lower average AFROC FOM of 0.608 for the Schick 33 sensor. However, when we performed a sub-analysis of the reader study results for the Schick 33 images (n=28), we found a lower unaided reader performance for this sensor versus the mean performance across all sensors, and an improvement in mean AFROC FOM performance for aided (0.706) versus unaided (0.614) reads that was very similar to what was seen for the entire study dataset alleviating any concerns.
Animal Testing
Not applicable. Animal studies are not necessary to establish the substantial equivalence of this device.
Clinical Data (Reader Study)
A fully crossed randomized, multiple reader multiple case (MRMC) controlled study was performed to determine whether the diagnostic accuracy of readers aided by VCA is superior to reader accuracy when unaided by VCA, as determined by the AFROC Figure of Merit (AFROC FOM). The hypothesis to be tested is:
Ho: AFROC FOMaided - AFROC FOMunaided ≤ 0
H1: AFROC FOMaided - AFROC FOMunaided > 0
where AFROC FOMaided is the population-mean AFROC FOM for aided reads, and similarly with AFROC FOMunaided for unaided reads.
The dataset was 226 adult radiographs collected from 10 US sites that were ground-truthed by three US board-certified dentists. The patients in the dataset were 55% female and 45% male, with 49% having age 22-40, 38% age 41-60, 11% age 61-75, and 6% over age 76. Image sensors included in the study were: DEXIS Platinum, DEXIS Titanium, Gendex GXS-700, Kodak RVG, 6100, RVG 5200, RVG 6200, and Schick 33.
The overall average AFROC FOM for reads aided by VCA was 0.739 as compared to 0.667 for unaided reads (Table 3). The difference was 0.072 (95% CI: 0.047, 0.097; p