K Number
K223229
Device Name
MOSAIQ® OIS (Oncology Information System)
Date Cleared
2023-02-23

(128 days)

Product Code
Regulation Number
892.5050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
MOSAIQ® is an oncology information system used to manage workflows for treatment planning and delivery. It supports information flow among healthcare facility personnel and can be used wherever radiotherapy and/or chemotherapy are prescribed. Users can configure MOSAIQ® for Medical Oncology use, Radiation Oncology use, or the two together. Medical oncology dose calculations are designed to support both adult and pediatric patients. It lets users: - · Assemble electronic patient charts and treatment plans, order diagnostic tests, and prescribe medications. - · Generate and keep medication formulary lists and calculate applicable medication dosages for medical oncology. - · Import, view, annotate, adjust, enhance, manage and archive images. - · Compare radiation treatment plans and evaluate dose coverage. - · Design leaf plans for operation with radiotherapy treatment machines that have multi-leaf collimators. - · Make sure radiation treatment plans imported from treatment planning systems agree with treatment machine constraints. MOSAIQ® reads actual settings from the treatment machine communication interface. It compares these settings with predefined values. If a mismatch occurs between the planned values and the actual machine settings, the system warns the user. - · View reference images to setup treatment. MOSAIQ® refers to predefined settings to help treatment machine setup and communicates patient and machine setup instructions. - · Record actual delivered radiation values in an electronic chart to track treatment. - · Use stereotactic localization to calculate set-up coordinates for treatments. - · Monitor Intrafractional motion with real time image overlay. MOSAIQ® is not intended for use in diagnosis.
Device Description
The MOSAIQ® Oncology Information System (OIS) is an image-enabled electronic medical record system. It manages clinical and administrative workflows within oncology departments and facilitates efficient patient care. It can be configured for Medical Oncology, Radiation Oncology, or both. The Medical Oncology (MO) configuration is a medical oncology charting solution that includes customizable regimens (Care Plans) that automate chemotherapy orders for labs, procedures, and appointments. Configurable flowsheet views are used for reviewing treatment administration, documents, assessment and lab data. Users can enter medications and screen for drug/drug and drug/allergy interactions. MOSAIQ also performs standard calculations such as Body Surface Area (BSA) and Area Under the Curve (AUC). The Medical Administration Record (MAR) supports all information related to chemotherapy and blood product administration, clinical trial study drugs, dose amounts, infusion time, multiple administration, etc. The Radiation Oncology configuration is also a charting solution with Computerized Physician Order Entry (CPOE) capability, along with added features for image management, patient setup and positioning, verify and record, plan import, review, and approval, stereotactic localization, and pretreatment checks. MOSAIQ's Radiation Oncology functionality can be used to support a wide variety of treatment modalities including Intensity Modulated Radio Therapy (IMRT), Image Guided Radio Therapy (IGRT), particle therapy, and stereotactic radiotherapy. It can import and store treatment plans from Therapy Planning Systems (TPS) via DICOM import/DICOM RT import. In addition to these, the current version of MOSAIQ introduces the following modifications for radiation oncology: - · Anatomic Position Monitoring (APM) with Manual interrupt (also referred to as True Tracking as it 'tracks' in 3D and enables the system to gate using the 3D position of the anatomy's motion) - · APM with Anatomic Tolerance Check (ATC) - · Adaptive Therapy with optional Baseline Shift (BLS) Recoverv - · Care Rules for motion management. These modifications are not contained solely within MOSAIQ, as the full clinical benefit is achieved with interoperability of Unity, Monaco RTP, and MOSAIQ OIS.
More Information

MOSAIQ OIS (K203172)

Not Found

No
The document does not mention AI or ML, and the described functionalities are typical of an oncology information system managing workflows and data, not employing learning algorithms for analysis or decision support.

No

Explanation: MOSAIQ® is an oncology information system used to manage workflows and information flow related to treatment planning and delivery, not to directly treat a disease or condition. Its functions include managing patient charts, orders, calculations, and image management for oncology treatments like radiotherapy and chemotherapy.

No

MOSAIQ® is an oncology information system explicitly stated to not be intended for use in diagnosis. Its primary function is to manage workflows for treatment planning and delivery, and it facilitates clinical and administrative workflows within oncology departments.

No

The device description explicitly states that "These modifications are not contained solely within MOSAIQ, as the full clinical benefit is achieved with interoperability of Unity, Monaco RTP, and MOSAIQ OIS." This indicates that the device relies on interaction with other hardware components (Unity and Monaco RTP) to achieve its intended clinical benefit, therefore it is not a software-only medical device.

Based on the provided text, the MOSAIQ® Oncology Information System is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section explicitly states: "MOSAIQ® is not intended for use in diagnosis." IVD devices are specifically intended for use in the examination of specimens derived from the human body to provide information for diagnostic purposes.
  • Functionality: The described functionalities of MOSAIQ® are focused on managing workflows, treatment planning and delivery, patient charting, medication management, image management for treatment setup and monitoring, and verification of treatment machine settings. These are all related to the treatment and management of cancer, not the diagnosis of it through in vitro testing.
  • Lack of IVD Characteristics: The description does not mention any components or processes related to the analysis of biological specimens (blood, urine, tissue, etc.) or the use of reagents, which are hallmarks of IVD devices.

Therefore, based on the provided information, MOSAIQ® is a medical device, but it falls under a different classification than an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

MOSAIQ® is an oncology information system used to manage workflows for treatment planning and delivery. It supports information flow among healthcare facility personnel and can be used wherever radiotherapy and/or chemotherapy are prescribed. Users can configure MOSAIQ® for Medical Oncology use, Radiation Oncology use, or the two together. Medical oncology dose calculations are designed to support both adult and pediatric patients. It lets users:

  • · Assemble electronic patient charts and treatment plans, order diagnostic tests, and prescribe medications.
  • · Generate and keep medication formulary lists and calculate applicable medication dosages for medical oncology.
  • · Import, view, annotate, adjust, enhance, manage and archive images.
  • · Compare radiation treatment plans and evaluate dose coverage.
  • · Design leaf plans for operation with radiotherapy treatment machines that have multileat collimators.
  • · Make sure radiation treatment plans imported from treatment planning systems agree with treatment machine constraints.

MOSAIQ® reads actual settings from the treatment machine through the machine communication interface. It compares these settings with predefined values. If a mismatch occurs between the planned values and the actual machine settings, the system warns the user.

  • · View reference images to setup treatment. MOSAIQ® refers to predefined settings to help treatment machine setup, and communicates patient and machine setup instructions.
  • · Record actual delivered radiation values in an electronic chart to track treatment.
  • · Use stereotacticlocalization to calculate set-up coordinates for treatments.
  • · Monitor intrafractional motion with real time image overlay.

MOSAIQ is not intended for use in diagnosis.

Product codes (comma separated list FDA assigned to the subject device)

IYE

Device Description

The MOSAIQ® Oncology Information System (OIS) is an image-enabled electronic medical record system. It manages clinical and administrative workflows within oncology departments and facilitates efficient patient care. It can be configured for Medical Oncology, Radiation Oncology, or both.

The Medical Oncology (MO) configuration is a medical oncology charting solution that includes customizable regimens (Care Plans) that automate chemotherapy orders for labs, procedures, and appointments. Configurable flowsheet views are used for reviewing treatment administration, documents, assessment and lab data. Users can enter medications and screen for drug/drug and drug/allergy interactions. MOSAIQ also performs standard calculations such as Body Surface Area (BSA) and Area Under the Curve (AUC). The Medical Administration Record (MAR) supports all information related to chemotherapy and blood product administration, clinical trial study drugs, dose amounts, infusion time, multiple administration, etc.

The Radiation Oncology configuration is also a charting solution with Computerized Physician Order Entry (CPOE) capability, along with added features for image management, patient setup and positioning, verify and record, plan import, review, and approval, stereotactic localization, and pretreatment checks. MOSAIQ's Radiation Oncology functionality can be used to support a wide variety of treatment modalities including Intensity Modulated Radio Therapy (IMRT), Image Guided Radio Therapy (IGRT), particle therapy, and stereotactic radiotherapy. It can import and store treatment plans from Therapy Planning Systems (TPS) via DICOM import/DICOM RT import.

In addition to these, the current version of MOSAIQ introduces the following modifications for radiation oncology:

  • · Anatomic Position Monitoring (APM) with Manual interrupt (also referred to as True Tracking as it 'tracks' in 3D and enables the system to gate using the 3D position of the anatomy's motion)
  • · APM with Anatomic Tolerance Check (ATC)
  • · Adaptive Therapy with optional Baseline Shift (BLS) Recoverv
  • · Care Rules for motion management.

These modifications are not contained solely within MOSAIQ, as the full clinical benefit is achieved with interoperability of Unity, Monaco RTP, and MOSAIQ OIS.

Mentions image processing

Yes

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

DICOM import/DICOM RT import

Anatomical Site

Not Found

Indicated Patient Age Range

Adult and pediatric patients

Intended User / Care Setting

Healthcare facility personnel wherever radiotherapy and/or chemotherapy are prescribed.

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)

Design verification and performance testing were carried out in accordance with design controls of FDA's Quality System Regulation (21 CFR §820.30), applicable ISO 13485 Quality Management System requirements, ISO 14971 risk management requirements, IEC 62304 requirements for software life-cycle processes.

Non-clinical testing was performed to evaluate device performance and functionality against design and risk management requirements at sub-system, integration and system levels. Software verification testing was conducted and documented in accordance with FDA guidance for devices that pose a major level of concern (Class C per IEC 62304).

Basic safety and essential performance have been satisfied through conformance with device-specific recognized consensus standards, as well as the general and collateral safety and essential performance standards for medical devices listed below.

No animal or clinical tests were performed to establish substantial equivalence with the predicate device. The performance data demonstrate that MOSAIQ is as safe and effective and performs as well as the predicate device.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

MOSAIQ OIS (K203172)

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 892.5050 Medical charged-particle radiation therapy system.

(a)
Identification. A medical charged-particle radiation therapy system is a device that produces by acceleration high energy charged particles (e.g., electrons and protons) intended for use in radiation therapy. This generic type of device may include signal analysis and display equipment, patient and equipment supports, treatment planning computer programs, component parts, and accessories.(b)
Classification. Class II. When intended for use as a quality control system, the film dosimetry system (film scanning system) included as an accessory to the device described in paragraph (a) of this section, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.

0

February 23, 2023

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Elekta Solutions AB % Melinda Smith Director, Regulatory Affairs & Quality - Americas Elekta, Inc. 400 Perimeter Center Terrace NE Suite 50 ATLANTA GA 30346

Re: K223229

Trade/Device Name: MOSAIO® Oncology Information System Regulation Number: 21 CFR 892.5050 Regulation Name: Medical charged-particle radiation therapy system Regulatory Class: Class II Product Code: IYE Dated: January 26, 2023 Received: January 27, 2023

Dear Melinda Smith:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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 medical devices and radiation-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,

Image /page/1/Picture/5 description: The image shows a digital signature. The signature is for Lora D. Weidner. The signature was created on February 23, 2023 at 14:33:58 -05'00'.

Lora D. Weidner, Ph.D. Assistant Director Radiation Therapy Team DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known)

K223229

Device Name

MOSAIQ® Oncology Information System

Indications for Use (Describe)

MOSAIQ® is an oncology information system used to manage workflows for treatment planning and delivery. It supports information flow among healthcare facility personnel and can be used wherever radiotherapy are prescribed. Users can configure MOSAIQ® for Medical Oncology use, Radiation Oncology use, or the two together. Medical oncology dose calculations are designed to support both adult and pediatric patients. It lets users:

  • · Assemble electronic patient charts and treatment plans, order diagnostic tests, and prescribe medications.
  • · Generate and keep medication formulary lists and calculate applicable medication dosages for medical oncology.
  • · Import, view, annotate, adjust, enhance, manage and archive images.
  • · Compare radiation treatment plans and evaluate dose coverage.
  • · Design leaf plans for operation with radiotherapy treatment machines that have multi-leaf collimators.
  • · Make sure radiation treatment plans imported from treatment planning systems agree with treatment machine

constraints. MOSAIQ® reads actual settings from the treatment machine communication interface. It compares these settings with predefined values. If a mismatch occurs between the planned values and the actual machine settings, the system warns the user.

· View reference images to setup treatment. MOSAIQ® refers to predefined settings to help treatment machine setup and communicates patient and machine setup instructions.

  • · Record actual delivered radiation values in an electronic chart to track treatment.
  • · Use stereotactic localization to calculate set-up coordinates for treatments.
  • · Monitor Intrafractional motion with real time image overlay.

MOSAIQ® is not intended for use in diagnosis.

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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TRADITIONAL 510(K) SUMMARY (21 CFR § 807.92)

-SUBMITTER

Contact:

Elekta Solutions AB Kungstensgatan 18 Box 7593 Stockholm, SE SE10393

Melinda Smith, MS, RAC, CBA Melinda.Smith@elekta.com

Establishment Registration #: 510(k) Number: Date Prepared:

3015232217 K223229 7 December 2022

DEVICE II.

Trade Name:MOSAIQ Oncology Information System
Product Classification:Class II
Common Name:Radiation charged-particle radiation system
Regulation Number:21 CFR § 892.5050
Regulation Description:Medical charged-particle radiation therapy system
Product Code:IYE

lll. PREDICATE DEVICE

Predicate Device: MOSAIQ OIS (K203172)

IV. DEVICE DESCRIPTION

The MOSAIQ® Oncology Information System (OIS) is an image-enabled electronic medical record system. It manages clinical and administrative workflows within oncology departments and facilitates efficient patient care. It can be configured for Medical Oncology, Radiation Oncology, or both.

The Medical Oncology (MO) configuration is a medical oncology charting solution that includes customizable regimens (Care Plans) that automate chemotherapy orders for labs, procedures, and appointments. Configurable flowsheet views are used for reviewing treatment administration, documents, assessment and lab data. Users can enter medications and screen for drug/drug and drug/allergy interactions. MOSAIQ also performs standard calculations such as Body Surface Area (BSA) and Area Under the Curve (AUC). The Medical Administration Record (MAR) supports all information related to chemotherapy and blood product administration, clinical trial study drugs, dose amounts, infusion time, multiple administration, etc.

The Radiation Oncology configuration is also a charting solution with Computerized Physician Order Entry (CPOE) capability, along with added features for image management, patient setup and positioning, verify and record, plan import, review, and approval, stereotactic localization, and pretreatment checks. MOSAIQ's Radiation Oncology functionality can be used to support a wide variety of treatment modalities including Intensity Modulated Radio Therapy (IMRT), Image Guided Radio Therapy (IGRT), particle therapy, and stereotactic radiotherapy. It can import and store treatment plans from Therapy Planning Systems (TPS) via DICOM import/DICOM RT import.

4

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In addition to these, the current version of MOSAIQ introduces the following modifications for radiation oncology:

  • · Anatomic Position Monitoring (APM) with Manual interrupt (also referred to as True Tracking as it 'tracks' in 3D and enables the system to gate using the 3D position of the anatomy's motion)
  • · APM with Anatomic Tolerance Check (ATC)
  • · Adaptive Therapy with optional Baseline Shift (BLS) Recoverv
  • · Care Rules for motion management.

These modifications are not contained solely within MOSAIQ, as the full clinical benefit is achieved with interoperability of Unity, Monaco RTP, and MOSAIQ OIS.

V. INTENDED USE / INDICATIONS FOR USE

MOSAIQ® is an oncology information system used to manage workflows for treatment planning and delivery. It supports information flow among healthcare facility personnel and can be used wherever radiotherapy and/or chemotherapy are prescribed. Users can configure MOSAIQ® for Medical Oncology use, Radiation Oncology use, or the two together. Medical oncology dose calculations are designed to support both adult and pediatric patients. It lets users:

  • · Assemble electronic patient charts and treatment plans, order diagnostic tests, and prescribe medications.
  • · Generate and keep medication formulary lists and calculate applicable medication dosages for medical oncology.
  • · Import, view, annotate, adjust, enhance, manage and archive images.
  • · Compare radiation treatment plans and evaluate dose coverage.
  • · Design leaf plans for operation with radiotherapy treatment machines that have multileat collimators.
  • · Make sure radiation treatment plans imported from treatment planning systems agree with treatment machine constraints.

MOSAIQ® reads actual settings from the treatment machine through the machine communication interface. It compares these settings with predefined values. If a mismatch occurs between the planned values and the actual machine settings, the system warns the user.

  • · View reference images to setup treatment. MOSAIQ® refers to predefined settings to help treatment machine setup, and communicates patient and machine setup instructions.
  • · Record actual delivered radiation values in an electronic chart to track treatment.
  • · Use stereotacticlocalization to calculate set-up coordinates for treatments.
  • · Monitor intrafractional motion with real time image overlay.

MOSAIQ is not intended for use in diagnosis.

VI. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH PREDICATE

MOSAIQ® Oncology Information System version 3.2 is an updated version of the predicate device and has identical intended use and technological characteristics (identical designs, principles of operation, and use environments) as well as the same indications for use as the predicate device cleared per K203172.

The similarities and differences in key device characteristics and performance specifications of the current and predicate MOSAIQ configuration are noted in the table below. Through adequate verification, validation and usability evaluations. Elekta has concluded that the differences do not impact the substantial equivalence with the predicate device.

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| Technological Characteristics Comparison | | MOSAIQ
(Subject Device) | MOSAIQ
(K203172) |
|-------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|---------------------|
| Administrative Features
– MDDS (non-medical)
Features | Practice management features – billing,
scheduling, scheduling, billing, management
reporting and data analysis | ✓ | ✓ |
| Medical oncology
management | Includes plan of care management, calculation of
medication dosage, and dose delivery tracking | ✓ | ✓ |
| Radiation Oncology
Management | Ability to add a radiation prescription, import
radiation therapy treatment plans, machine setup
including
patient positioning, treatment calendar
management, cumulative dose tracking and
eChart Check feature for weekly chart check.
Review of treatment plans through Evaluate
feature. | ✓ | ✓ |
| Imaging Functionality | Ability to import, view, annotate, manipulate,
enhance, manage and archive images | ✓ | ✓ |
| Record and Verify-
Sequencer | Verifies radiation treatment plans against
treatment machine constraints, provides the
capability to notify clinicians of actions that need
to take place prior to treatment, displays
reference images for setup purposes, and
facilitates treatment machine setup according to
predefined settings. Recording of actual treatment
values and interfaces with treatment machines. | ✓ | ✓ |
| MLC Fit | Design leaf plans for operation with radiotherapy
treatment machines that have multi-leaf
collimators. | ✓ | ✓ |
| Modality support | Supports IMRT, IGRT, particle therapy,
stereotactic radiotherapy and MR-Linac
treatments | ✓ | ✓ |
| Motion
Management in
Treatment
Session
Manager | Motion monitoring with manual interrupt | ✓ | ✓ |
| | Anatomical Position Monitoring (APM) with
manual interrupt | ✓ | X |
| | APM with ATC (Anatomical Tolerance Check) | ✓ | X |
| | Adaptive Therapy with optional BLS (Baseline
Shift) Recovery | ✓ | X |
| Stereotactic
Localization | Stereotactic localization through MOSAIQ
LOCATE feature allows clinicians to visualize the
target on patient images, perform image
calibration, and calculate stereotactic coordinates. | ✓ | ✓ |
| DICOM Connectivity | DICOM connectivity with compatible systems | ✓ | ✓ |
| Operating System | Windows operating system
Support for Windows 10 | ✓ | ✓ |

SUMMARY OF PERFORMACE TESTING (NON-CLINICAL) VII.

Design verification and performance testing were carried out in accordance with design controls of FDA's Quality System Regulation (21 CFR §820.30), applicable ISO 13485 Quality Management System requirements, ISO 14971 risk management requirements, IEC 62304 requirements for software life-cycle processes.

Non-clinical testing was performed to evaluate device performance and functionality against design and risk management requirements at sub-system, integration and system levels. Software verification testing was conducted and documented in accordance with

6

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FDA guidance 1 for devices that pose a major level of concern (Class C per IEC 62304).

Basic safety and essential performance have been satisfied through conformance with device-specific recognized consensus standards, as well as the general and collateral safety and essential performance standards for medical devices listed below.

Standard No.Standard Title
ISO 14971Medical Devices – Application of risk management to medical devices
IEC 62304Medical device software - Software life-cycle processes
ISO 62083Medical electrical equipment - Requirements for the safety of radiotherapy
treatment planning systems
IEC 61217Radiotherapy equipment - Coordinates, movements and scales
IEC 62274Medical electrical equipment - Safety of radiotherapy record and verify systems
AAMI RT2:2017Radiation therapy readiness check
IEC 62366-1Medical devices - Application of usability engineering to medical devices
ISO 15223Medical devices -Symbols to be used with medical devices, labeling and information
to be supplied - Part 1: General requirements

VIII. SUMMARY OF PERFORMACE TESTING (CLINICAL)

No animal or clinical tests were performed to establish substantial equivalence with the predicate device. The performance data demonstrate that MOSAIQ is as safe and effective and performs as well as the predicate device.

IX. SUBSTANTIAL EQUIVALENCE CONCLUSION

MOSAIQ is substantially equivalent (SE) to the predicate device, MOSAIQ (K203172). The intended use and indications for use are identical to the predicate device and the principles of operation remain unchanged.

The technological characteristics are substantially equivalent to the predicate device; the additional motion management strategies do not affect the fundamental scientific technology or raise different questions of safety or effectiveness of the device.

The device safety and performance have been addressed by non-clinical testing in conformance with pre-determined performance criteria, FDA guidance, and recognized consensus standards.

The results of verification and validation as well as conformance to relevant safety standards demonstrate that MOSAIQ meets the established safety and performance criteria and is substantially equivalent to the predicate device.

1 Content of Premarket Submissions for Software Contained in Medical Devices – Guidance for Industry and Food and Drug Administration Staff, May 2005