(265 days)
Not Found
Yes
The summary mentions a "biometric identification algorithm" used for user identification, which is a common application of machine learning.
No
The device is used for measuring, reviewing, and storing physiological data (SpO2 and heart rate) for monitoring purposes, and is not intended to provide therapy or treatment.
No
The device is marketed as a monitoring system that collects physiological data (SpO2 and heart rate) for healthcare providers to review, rather than providing a diagnosis itself. The "Intended Use" states it is for "measuring, reviewing and storing" data, and the "Device Description" clarifies it is a "remote monitoring system" and a "tool intended to support clinicians by providing them with data to help them better manage patients." This indicates its role is in data collection and presentation, not diagnostic interpretation.
No
The device description explicitly states it is "built into a toilet seat" and involves "physiological monitoring in the home setting," indicating a physical hardware component is integral to its function. The performance studies also validate the accuracy of measurements taken by the physical seat.
Based on the provided information, the Heart Seat is not an In Vitro Diagnostic (IVD) device.
Here's why:
- IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information about a person's health. This testing is done outside of the body (in vitro).
- Heart Seat Function: The Heart Seat measures physiological parameters (SpO2 and heart rate) directly from the user's body while they are sitting on the seat. This is a non-invasive, in vivo measurement.
- Intended Use: The intended use describes measuring, reviewing, and storing SpO2 and heart rate. It does not involve the analysis of bodily specimens.
Therefore, the Heart Seat falls under the category of a medical device that performs physiological monitoring, but it does not meet the definition of an In Vitro Diagnostic device.
No
The letter does not state that the FDA has reviewed and approved or cleared a PCCP for this specific device.
Intended Use / Indications for Use
The Heart Seat is a replacement for a standard toilet seat that is indicated for use in a home environment. The Heatt Seat is intended to be used for measuring, reviewing and storing non-invasive functional oxygen saturation of arterial hemoglobin (SpO2) and heart rate (HR) in adults of at least 22 years of age with weight ranging from 90 to 350 pounds. Data from the Heart Seat are collected whenever the seat is used and are automatically uploaded to the Casana Cloud where they can be viewed by the healthcare provider. The Heart Seat is not intended for continuous monitoring.
Product codes (comma separated list FDA assigned to the subject device)
MWI, DQA
Device Description
The Heart Seat™ is a prescription use remote monitoring system built into a toilet seat. It is intended for physiological monitoring in the home setting. The device and platform are tools intended to support clinicians by providing them with data to help them better manage patients. Monitored users (or Patients) sit on the seat for their data to be captured and sent to the cloud. Clinical users interact with the clinical cloud-based application that provides the patient measurements.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Thigh (for SpO2 and HR measurement)
Fingertip (for predicate device SpO2 and HR measurement)
Indicated Patient Age Range
adults of at least 22 years of age
Intended User / Care Setting
Home environment; healthcare provider (for viewing data)
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
Heart Rate Validation study:
- Sample size: 117 healthy subjects
- Data source: Heart rate measurements reported by the Heart Seat compared to those obtained from a 3-lead ECG device.
- Annotation protocol: A total of 349 heart rate measurement pairs were collected.
SpO2 Clinical Validation study:
- Sample size: Thirteen subjects, three of whom had Fitzpatrick VI skin tone.
- Data source: Not explicitly stated beyond "under steady state no-motion conditions."
- Annotation protocol: In accordance with the FDA Pulse Oximeter Guidance Document and the FDA recognized standard ISO 80601-2-61:2017.
BioID Validation study:
- Sample size: 125 subjects with a range of ages, BMI, and skin tone.
- Data source: Not explicitly stated beyond "demonstrate that the biometric identification algorithm used by the Heart Seat is capable of identifying someone using the seat as the desired/designated user."
- Annotation protocol: Not explicitly stated.
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Heart Rate Validation study:
- Study type: Validation study
- Sample size: 117 healthy subjects
- Key results: 348/349 data points over the range of 40 to 103 bpm meet the Pass/Fail criteria of an Absolute Accuracy
§ 870.2300 Cardiac monitor (including cardiotachometer and rate alarm).
(a)
Identification. A cardiac monitor (including cardiotachometer and rate alarm) is a device used to measure the heart rate from an analog signal produced by an electrocardiograph, vectorcardiograph, or blood pressure monitor. This device may sound an alarm when the heart rate falls outside preset upper and lower limits.(b)
Classification. Class II (performance standards).
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April 24, 2023
Casana Care, Inc. % Donna-Bea Tillman Senior Consultant Biologics Consulting 1555 King Street, Suite 300 Alexandria, Virginia 22314
Re: K222330
Trade/Device Name: The Heart Seat Regulation Number: 21 CFR 870.2300 Regulation Name: Cardiac Monitor (Including Cardiotachometer And Rate Alarm) Regulatory Class: Class II Product Code: MWI, DQA Dated: March 27, 2023 Received: March 27, 2023
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.
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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); 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 (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.
Shruti N. Mistry -S
for
Jennifer Shih Kozen Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K222330
Device Name The Heart Seat
Indications for Use (Describe)
The Heart Seat is a replacement for a standard toilet seat that is indicated for use in a home environment. The Heatt Seat is intended to be used for measuring, reviewing and storing non-invasive functional oxygen saturation of arterial hemoglobin (SpO2) and heart rate (HR) in adults of at least 22 years of age with weight ranging from 90 to 350 pounds. Data from the Heart Seat are collected whenever the seat is used and are automatically uploaded to the Casana Cloud where they can be viewed by the healthcare provider. The Heart Seat is not intended for continuous monitoring.
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 Heart Seat is provided below.
1. SUBMITTER
| Applicant: | Casana Care, Inc.
150 Metro Park Suite A
Rochester, NY 14623 |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Kara Johnson
Vice President Regulatory Affairs and Quality
Assurance
Casana Care, Inc.
150 Metro Park Suite A
Rochester, NY 14623
kjohnson@casanacare.com |
| 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: | April 18, 2023 |
2. DEVICE
Device Trade Name: | The Heart Seat |
---|---|
Device Common Name: | Multi-Parameter Patient Monitor |
Classification Name | 21 CFR 870.2300 Cardiac monitor (including cardiotachometer and rate alarm) |
Regulatory Class: | II |
Product Code: | Primary: MWI |
Secondary: DQA |
PREDICATE DEVICE 3.
Predicate Device: K210086 Vitals360® Multi-Vitals Mobile Monitor
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DEVICE DESCRIPTION 4.
The Heart Seat™ is a prescription use remote monitoring system built into a toilet seat. It is intended for physiological monitoring in the home setting. The device and platform are tools intended to support clinicians by providing them with data to help them better manage patients. Monitored users (or Patients) sit on the seat for their data to be captured and sent to the cloud. Clinical users interact with the clinical cloud-based application that provides the patient measurements.
INTENDED USE/INDICATIONS FOR USE 5.
The Heart Seat is a replacement for a standard toilet seat that is indicated for use in a home environment. The Heart Seat is intended to be used for measuring, displaying, reviewing and storing non-invasive functional oxygen saturation of arterial hemoglobin (SpO2) and heart rate (HR) in adults of at least 22 years of age with weight ranging from 90 to 350 pounds. Data from the Heart Seat are collected whenever the seat is used and are automatically uploaded to the Casana Cloud where they can be viewed by the healthcare provider. The Heart Seat is not intended for continuous monitoring.
6. SUBSTANTIAL EQUIVALENCE
Comparison of Indications
The Vitals360 and the Heart Seat are both prescription-use devices intended to be used in the home environment to collect physiological data from users 18 years and older. The physiological data collected by the Heart Seat is a subset of that collected by the Vitals360. While there are differences in the form factors of the devices, they have the same intended use, which is to provide for the measurement, display, review, and storage of physiological data.
Technological Comparisons
The table below compares the key technological feature of the subject devices to the predicate device (Vitals360® Multi-Vitals Mobile Monitor, K210086).
Proposed Device | Predicate Device | Discussion of Differences | |
---|---|---|---|
510(k) Number | TBD | K210086 | N/A |
Applicant | Casana Care, Inc. | VoCare, Inc. | N/A |
Device Name | Heart Seat | Vitals360® Multi- | |
Vitals Mobile Monitor | N/A | ||
Proposed Device | Predicate Device | Discussion of | |
Differences | |||
Classification | |||
Regulation | 21 CFR 870.2300 | 21 CFR 870.2300 | N/A |
Product Code | MWI, DQA | MWI, DQA, DSH, | |
DXN, FLL | Heart Seat provides a | ||
subset of the predicate | |||
features | |||
Prescription/OTC | Prescription | Prescription | Same |
Use environment | Home | Home, clinic | Heart Seat can be used in |
a subset of the predicate | |||
use environments | |||
Intended | |||
Population | 18 years and older | 18 years and older | Same |
Modes | Remote monitoring | Point of Care | |
Remote monitoring | Heart Seat provides a | ||
subset of the predicate | |||
features | |||
Parameters | |||
measured | SpO2, HR | SpO2, HR, NIBP, | |
Temp, Height, Weight | Heart Seat provides a | ||
subset of the predicate | |||
features | |||
Data upload | Automatically - WiFi | Automatically - WiFi | |
or Cellular | Heart Seat provides a | ||
subset of the predicate | |||
features | |||
Data storage | |||
location | Casana Cloud | Third party MDDS | Both provide options for |
remote storage of data | |||
Patient | |||
Identification | Uses BioID software | ||
algorithm | None | Clinical testing | |
demonstrates that device | |||
meets specifications, user | |||
needs and intended uses | |||
SpO2 Functionality | |||
Principle of | |||
operation | PPG | PPG | Same |
Measurement site | Thigh | Fingertip | Different locations; |
clinical data | |||
demonstrates equivalent | |||
performance | |||
Measurement range | 70% - 100% | 70% - 100% | Same |
Proposed Device | Predicate Device | Discussion of | |
Differences | |||
Measurement | |||
accuracy | |||
performance | |||
(Arms) | ±3.5% (70-100%) | ±2% (90~100%), | |
±4% (70~89%) | Clinical data | ||
demonstrates equivalent | |||
performance | |||
Heart Rate | |||
Source | Single lead ECG | Single lead ECG (two | |
embedded metal | |||
electrodes) | Same | ||
Measurement site | Thigh | Fingertip | Different locations; |
clinical data | |||
demonstrates equivalent | |||
performance | |||
Measurement range | 40-200 bpm | 30 - 240 bpm | Heart Seat provides a |
subset of the predicate | |||
range. Outside of the | |||
Heart Seat range, no | |||
value is reported. | |||
Resolution | 1 bpm | 1 bpm | Same |
Measurement | |||
accuracy | Specification: ±5bpm | ||
or ±10%, whichever is | |||
greater |
Actual Performance:
Mean error 0.8bpm | Specification: ±2bpm
or ±2%, whichever is
greater | Clinical data
demonstrates equivalent
performance |
Table 1: Technological Comparison
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In conclusion, the differences in technological characteristics do not raise new questions of safety and effectiveness.
PERFORMANCE DATA 7.
Biocompatibility Testing
The subject device is considered surface contacting for a or a limited duration (