(617 days)
The NEUROShield™ medical image processing software is intended for automatic labelling, visualization, and volumetric quantification of the Hippocampus brain structure from a set of MR images.
NEUROShield™ is a fully automated brain geometry-based quantifying analytics tool/cloud platform that uses Al/Deep Net to support physicians as a clinical decision support tool for neurologists and neuroradiologists. NEUROShield™ takes 3D MR images as input and calculates brain volumes that can assist physicians in devising optimal treatment plans. The Al tool branded as NEUROShield™ provides volumetric measurements of the Hippocampus brain structure. It replaces time-consuming manual processes with leading-edge automated technology that accelerates the analysis for clinical and research purposes. Brain Volume Quantification is a wellestablished methodology for differential and enhanced interpretation of medical images. We are using a locked algorithm, and any proposed modifications will be submitted to the FDA for review.
Here's a summary of the acceptance criteria and the study that proves NEUROShield meets those criteria, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Measure | Threshold (Acceptance Criteria) | NEUROShield™ 95% Confidence Intervals (Reported Performance) | Criteria (Pass/Fail) |
|---|---|---|---|
| Dice Coefficient | 0.75 | (0.90, 0.92) | Pass |
| Hausdorff Distance (mm) | 6.1 | (3.57, 4.06) | Pass |
| Correlation (Volume) | 0.82 | (Not explicitly given as CI, but stated as "passed") | Pass |
| Relative Volume Difference | 24.6% | (Not explicitly given as CI, but stated as "passed") | Pass |
| Mean Difference in BA plots (Total Hippocampus) | 1010 mm³ | (Not explicitly given as CI, but stated as "passed") | Pass |
2. Sample Size for the Test Set and Data Provenance
- Sample Size: 280 subjects
- Data Provenance:
- Country of Origin: USA (collected from the publicly available ADNI - Alzheimer's Disease Neuroimaging Initiative - dataset, with approximately equal geographical distribution across East, Central, and West US regions).
- Retrospective or Prospective: Retrospective
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Number of Experts: 3
- Qualifications: US Board Certified Radiologists
4. Adjudication Method for the Test Set
- Adjudication Method: The ground truth was established by combining the manual segmentations of the 3 radiologists into one tracing per case using the STAPLE (Simultaneous Truth and Performance Level Estimation) algorithm. This STAPLE-derived ground truth was then compared with individual radiologist segmentations to ensure validity.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No, an MRMC comparative effectiveness study that assesses the effect size of human readers improving with AI vs. without AI assistance was not reported in this summary. The study focuses on evaluating the standalone performance of the NEUROShield™ algorithm against an expert-derived ground truth.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Yes, a standalone performance study was done. The NEUROShield™ algorithm's automated segmentations and volume calculations were directly compared against the ground truth established by expert radiologists.
7. The Type of Ground Truth Used
- Ground Truth Type: Expert consensus, specifically "STAPLE-derived ground truth building on the three US Board Certified Radiologists' provided segmentations."
8. The Sample Size for the Training Set
- Sample Size: 186 cases
9. How the Ground Truth for the Training Set Was Established
- The ground truth for the training set was established by manual segmentation of the Hippocampus structure by subject matter experts. This manually segmented data was then used as input to train the deep net Segmentation Model.
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In-Med Prognostics L3C Latha Poonamallee 4918 September Street San Diego, California 92110 September 14, 2023
Re: K220034
Trade/Device Name: NEUROShield Regulation Number: 21 CFR 892.2050 Regulation Name: Medical image management and processing system Regulatory Class: Class II Product Code: QIH Dated: June 19, 2023 Received: June 20, 2023
Dear Latha Poonamallee:
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.
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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 (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.
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Sincerely.
Robert Sauer Deputy Director OHT8: Office of Radiological Health 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
510(k) Number (if known) K220034
Device Name
NEUROShield
Indications for Use (Describe)
The NEUROShield™ medical image processing software is intended for automatic labelling, visualization, and volumetric quantification of the Hippocampus brain structure from a set of MR images.
| Type of Use (Select one or both, as applicable) | X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
|---|---|---|
| ------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------- |
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Revision: 01
Date: 11 Sept 2023
510(k) Summary
I. Submitter
| Name | In-Med Prognostics L3C |
|---|---|
| Address | 4918 September Street, San Diego, CA 92110, USA |
| Contact Person | Dr. Latha Poonamallee |
| Telephone Number | +1 (906) 231-1135 |
| drlatha@inmed.ai |
II. Device
| Device Trade Name | NEUROShield™ |
|---|---|
| Common Name | Medical Image Processing Software |
| Classification Name | Medical image management and processing system |
| Regulation Number | 21 CFR 892.2050 |
| Regulation Description | Picture archiving and communications system |
| Product Code | QIH |
| Classification Panel | Radiology |
III. Predicate Device:
| Device | NeuroQuant |
|---|---|
| 510(k) Number | K170981 |
| Manufacturer | CorTechs Labs, Inc |
| Product Code: | LLZ |
IV. Device Description:
NEUROShield™ is a fully automated brain geometry-based quantifying analytics tool/cloud platform that uses Al/Deep Net to support physicians as a clinical decision support tool for neurologists and neuroradiologists.
NEUROShield™ takes 3D MR images as input and calculates brain volumes that can assist physicians in devising optimal treatment plans. The Al tool branded as NEUROShield™ provides volumetric measurements of the Hippocampus brain structure. It replaces time-consuming manual processes
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with leading-edge automated technology that accelerates the analysis for clinical and research purposes. Brain Volume Quantification is a wellestablished methodology for differential and enhanced interpretation of medical images.
We are using a locked algorithm, and any proposed modifications will be submitted to the FDA for review.
V. Indications for Use:
The NEUROShield™ medical image processing software is intended for automatic labelling, visualization, and volumetric quantification of the Hippocampus brain structure from a set of MR images.
VI. Comparison of Technological Characteristics with the Predicate Device:
| Feature | Subject Device | Predicate Device |
|---|---|---|
| Device Name | NEUROShield™ | NeuroQuant |
| Organization | In Med Prognostics L3C | CorTechs Labs, Inc |
| Classification | Class II | Class II |
| Product Code | QIH | LLZ |
| Indications for Use | Automatic labelling,visualization, and volumetricquantification of theHippocampus brain structurefrom a set of MR images. | Automatic labelling, visualizationand volumetric quantification ofsegmentable brain structuresand lesions from a set of MRimages. Volumetric data may becompared to referencepercentile data. |
| Design andIncorporatedTechnology | • Software as a medicaldevice to be used in theprocess of Imaging andquantification of theHippocampus brainstructure from a set of MRimages.• Fully automated braingeometry-based quantifyinganalytics tool/cloud platformdeveloped using DeepNet /U-Net methodologies. | • Automated measurement ofbrain tissue volumes andstructures and lesions• Automatic segmentation andquantification of brain structuresusing a dynamic probabilisticneuroanatomical atlas, with ageand gender specificity, based onthe MR image intensity. |
| PhysicalCharacteristics | • Software package(accessible via web browser)• Operates on off-the-shelfhardware (multiple vendors) | • Software package• Operates on off-the-shelfhardware (multiple vendors) |
| Operating System | Supports Windows and MacOS latest (No older thanCatalina) | Supports Linux, Mac OS X andWindows. |
| ProcessingArchitecture | An automated internalpipeline that performs:- segmentation- volume calculation- report generation | Automated internal pipeline thatperforms:- artifact correction- segmentation- lesion quantification |
| - volume calculation- report generation | ||
| Feature | Subject Device | Predicate Device |
| Data Source • | • MRI scanner: 3D T1 MRIscans acquired with specifiedprotocols• NEUROShield requiresuncompressed DICOM filesas input. | • MRI scanner: 3D T1 MRIscans acquired with specifiedprotocols • NeuroQuantSupports DICOM format as input |
| Output | Provides volumetricmeasurements ofHippocampus brain structure. | Provides volumetricmeasurements of brainstructures and lesions.Includes segmented coloroverlays and morphometricreports• Automatically compares resultsto reference percentile data andto prior scans when available• Supports DICOM format asoutput of results that can bedisplayed on DICOMworkstations and Picture Archiveand Communications Systems |
| Safety | • Automated quality controlfunctions- Scan protocol verification• Results must be reviewedby a trained physician. | • Automated quality controlfunctions- Tissue contrast check- Scan protocol verification- Atlas alignment check• Results must be reviewed by atrained physician. |
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VII. Performance Testing:
NEUROShield is a machine learning/deep learning algorithm-based device. This algorithm was developed by training the Deep Net Segmentation Models with the help of the training set.
Specifications of the Training dataset
Data was collected from multiple sites across India, between January 2020 to December 2021.
The dataset of 186 cases, which was used for training, was carefully gathered and brought together by studying several factors such as variance, Tesla-strength (1.5T, 3T), qualities of image and equipment manufacturers. The collected data was prepared as the ground truth by manual segmentation of the Hippocampus structure by subject matter experts, and this was used as an input to the deep net Segmentation Model.
The table below provides the categorization of subjects.
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| Subgroups | Count | |
|---|---|---|
| Healthy controls | 186 | |
| Magnetic fieldstrength | 1.5T | 109 |
| 3 T | 77 | |
| Slice thickness | 1 | 81 |
| 1.2 | 50 | |
| 2 | 7 | |
| 2.2 | 48 | |
| EquipmentManufacturers | GE | 57 |
| Siemens | 112 | |
| Philips | 17 |
Validation Study:
NEUROShield's performance was evaluated by a validation study summarized as follows:
A. Data Description:
The performance testing/ validation dataset was collected from the publicly available ADNI (Alzheimer's Disease Neuroimaging Initiative) dataset. This dataset is independent of the training data and was not used to develop the NEUROShield's algorithm.
- Data Size: 280 subjects ●
- Study Type: Analytical & Cross-Sectional ●
- Data collection type: Retrospective ●
- Data Sampling: Stratified Random Sampling .
- Recruitment factors: ADNI 1 & ADNI 3 dataset (Alzheimer's Disease ● Neuroimaging Initiative)
- MRI Equipment manufacturers: GE medical systems, Philips medical systems, ● Siemens Healthineers.
- Magnetic Field Strength: 1.5 & 3 T ●
- MRI Sequences/ protocol: 3D T1 MPRAGE ●
- . Slice thickness: 1, 1.2
- Approximately equal geographical distribution in USA: East coast, Central US ● regions, West coast.
The distribution for age bands is as follows:
| Age group | Count |
|---|---|
| 55-64 | 109 |
| 65-69 | 56 |
| 70-74 | 50 |
| 75-79 | 29 |
| 80-84 | 20 |
| 85-90 | 16 |
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The mean age of subjects was found to be 68 ± 8.3 years.
| Subgroups | Count | Mean (mL) | Standard deviation (mL) | |
|---|---|---|---|---|
| Clinical Sub-groups | ADNI-control | 140 | 6.8 | 1 |
| ADNI-MCI | 70 | 6.6 | 1.1 | |
| ADNI-AD | 70 | 5.5 | 1.1 | |
| Gender | Male | 140 | 6.6 | 1.1 |
| Female | 140 | 6.2 | 1.3 | |
| Magnetic field strength | 1.5T | 139 | 6.2 | 1.2 |
| 3 T | 141 | 6.7 | 1.1 | |
| Slice thickness | 1 | 118 | 6.7 | 1 |
| 1.2 | 162 | 6.2 | 1.2 | |
| US Region | East | 100 | 6.5 | 1.2 |
| West | 87 | 6.3 | 1.3 | |
| Central | 93 | 6.5 | 1 |
The table below provides the categorization of subjects according to selection criteria:
B. Ground Truth:
-
- 3 US Board Certified Radiologists performed manual segmentation of 280 subjects' MRI Brain scans using a widely accepted segmentation guideline method. This ground truth was combined into one tracing per case by the STAPLE (Simultaneous Truth and Performance Level Estimation) algorithm. The STAPLE-derived ground truth was then compared with segmentation provided by each radiologist and statistical tests were performed to ensure the validity of ground truth.
-
- NEUROShield™ algorithm provided automated segmentation for the Hippocampus brain structure with markings and labelling on all subjects using algorithms and performed segmentation and computed volumes.
C. Statistical Analysis:
-
- Validation of Ground Truth: Ground truth validation using 3 radiologist segmentations was performed by comparing the segmentations obtained by these radiologists with the STAPLE annotations, utilizing Dice coefficient, sensitivity, specificity and Hausdorff distance.
Statistical analysis revealed no significant differences between the ground truth and radiologist segmentations (p > 0.05) for all comparisons, supporting the reliability of the ground truth annotations and the consistency of the radiologist segmentations.
- Validation of Ground Truth: Ground truth validation using 3 radiologist segmentations was performed by comparing the segmentations obtained by these radiologists with the STAPLE annotations, utilizing Dice coefficient, sensitivity, specificity and Hausdorff distance.
-
- Geometric comparison of NEUROShield™ with Ground Truth: Ground Truth was compared with the segmentation output generated by NEUROShield™ and validated using Dice score and Hausdorff distance. NEUROShield passed the criteria for both statistical methods.
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-
- Quantitative Comparison of volumes of NEUROShield™ (NS) with Ground Truth: STAPLE-derived ground truth building on the three US Board Certified Radiologists' provided segmentations was used to calculate the volume of the Hippocampus brain structure for all the cases. ITK Snap was used for this purpose. These volumes were compared with the volumes computed by NEUROShield™ using correlation analysis, Bland-Altman plots, and relative volume difference. NEUROShield passed the criteria for all three of the statistical methods, showing correspondence between NEUROShield™ volume and STAPLE volume.
-
- Pass/fail criteria: The pass/fail criteria were defined by selecting thresholds for each measure and performing hypothesis testing for the same. The thresholds for Dice score and Hausdorff distance are 75% and 6.1mm respectively, whereas for correlation and relative volume difference the passing criteria was defined as 0.82 and 24.6% respectively. For mean difference in BA plots, the threshold selected for total hippocampus was 1010 mm3
-
- Subgroup Error Analysis: For all the different subgroups, like magnetic field strength, gender, slice thickness, clinical subgroups and US geographical regions, the dice score values were above 90% and Hausdorff distance was less than 4 mm which represents a high level of accuracy of NEUROShield™ Hippocampus segmentation. Furthermore, NEUROShield™ passes the criteria both for correlation and relative volume differences for different subgroups.
D. Results:
-
- The average dice coefficient and Hausdorff distance was found to be 0.91 and 3.8 mm respectively. The following table shows the 95% confidence interval for both.
| Measure | Threshold | NEUROShield™ 95 %confidence intervals | Criteria(Pass/Fail) |
|---|---|---|---|
| Dice | 0.75 | (0.90, 0.92) | Pass |
| Hausdorff distance | 6.1 | (3.57, 4.06) | Pass |
-
- The outcomes of subgroup error analysis are as follows:
| Dice score | Hausdorff distance (mm) | |||||
|---|---|---|---|---|---|---|
| Clinical subgroups | Control | MCI | AD | Control | MCI | AD |
| Measured value | 0.91 | 0.92 | 0.9 | 3.77 | 3.43 | 4.3 |
| NEUROShieldTM 95 % confidence intervals | (0.9, 0.92) | (0.91, 0.93) | (0.88, 0.91) | (3.42, 4.13) | (3.03, 3.82) | (3.75, 4.85) |
| Criteria | Pass | Pass | Pass | Pass | Pass | Pass |
a) Clinical subgroups:
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b) Gender:
| Dice score | Hausdorff distance (mm) | |||
|---|---|---|---|---|
| Gender | Female | Male | Female | Male |
| Measured value | 0.91 | 0.91 | 3.92 | 3.71 |
| NEUROShield™ 95 %confidence intervals | (0.90,0.92) | (0.90,0.92) | (3.5,4.3) | (3.4,4.02) |
| Criteria | Pass | Pass | Pass | Pass |
c) Magnetic field strength:
| Dice score | Hausdorff distance (mm) | |||
|---|---|---|---|---|
| MRI strength | 3T | 1.5T | 3T | 1.5T |
| Measured value | 0.92 | 0.9 | 3.66 | 3.9 |
| NEUROShield™95 % confidenceintervals | (0.92,0.93) | (0.89, 0.91) | (3.36, 3.96) | (3.59, 4.37) |
| criteria | Pass | Pass | Pass | Pass |
d) Slice thickness:
| Dice score | Hausdorff distance (mm) | |||
|---|---|---|---|---|
| slice thickness | 1 mm | 1.2mm | 1 mm | 1.2mm |
| Average value | 0.92 | 0.9 | 3.5 | 4 |
| NEUROShield™95 % confidenceintervals | (0.92,0.93) | (0.89,0.91) | (3.21, 3.8) | (3.68,4.41) |
| criteria | Pass | Pass | Pass | Pass |
e) US geographical regions:
| Dice score | Hausdorff distance | |||||
|---|---|---|---|---|---|---|
| Region | East US | West US | Central US | East US | West US | Central US |
| Averagevalue | 0.91 | 0.9 | 0.92 | 3.78 | 3.94 | 3.73 |
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| 95 %confidenceintervals | (0.9, 0.92) | (0.88, 0.91) | (0.91, 0.93) | (3.37, 4.19) | (3.43, 4.45) | (3.38, 4.09) |
|---|---|---|---|---|---|---|
| Criteria | Pass | Pass | Pass | Pass | Pass | Pass |
The analysis of Neuroshield hippocampus segmentation revealed that the overall dice score values were above 90% and Hausdorff distance consistently below 4mm, reflecting a remarkable level of accuracy. These findings affirm the precision in both correlation and relative volume differences for segmenting hippocampal structures.
VIII. Conclusions:
This comprehensive evaluation demonstrates the reliability and effectiveness of NeuroShield in hippocampal segmentation. The assessment concludes that Neuroshield is a highly accurate device/tool for its intended use, thereby promising significant contributions to neuroimaging research and clinical applications.
§ 892.2050 Medical image management and processing system.
(a)
Identification. A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.(b)
Classification. Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).