K Number
K230823
Device Name
AusculThing ACC
Manufacturer
Date Cleared
2023-07-12

(110 days)

Product Code
Regulation Number
870.1875
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The AusculThing ACC software is a decision-support SW for the healthcare provider (the user) in the evaluation of patient heart sounds. The ACC is used to record, display, and analyze acoustic signals of the heart recorded by means of an electronic stethoscope. It is intended for use on adult and pediatric patients. The automated analysis will categorize heart sounds as either "abnormal" if any heart murmur of any intensity is identified in any position across the precordium, or "normal" if either no murmurs or benign murmurs are identified. ACC is indicated for use in a setting where auscultation would typically be performed by a healthcare provider. It is not intended as a sole means of diagnosis. The heart sound interpretation offered by the software is only significant when used in conjunction with physician over-read and including all other relevant patient data. The device is intended for Rx use only. The AusculThing ACC shall be used together with Thinklabs One electronic stethoscope.
Device Description
AusculThing ACC is a decision support SW that collects heart sounds from adult and pediatric patients. The ACC software receives the data using a Thinklabs One electronic stethoscope. The SW is running on a mobile device, where the electronic stethoscope is connected to. The SW guides the user how relevant heart sound recordings should be obtained from different parts of the body. After recording, the ACC analyzes the recordings in conjunction automatically using an AI -based algorithm, which is trained using a proprietary echocardiogram validated high-quality data database. The basic functionality of the ACC SW is to give a user an instant, automated, analysis of the patient under evaluation and differentiate between normal and pathological sounds. For the abnormal heart sounds, the ACC delivers information on suspected murmurs. The ACC software is a SW that allows a user to upload heart sounds/phonocardiogram (PCG) data to the device for analysis and visualization. The AusculThing ACC Mobile App runs on a mobile device. The app permits the electronic recording of heart sound signals via a compatible electronic stethoscope (Thinklabs One). The app also permits visual and acoustic playback of heart sounds in the mobile device. After analysis, results are returned to the user in the App. The Murmur detection algorithm is based on a neural network model that uses heart sounds to detect the presence of pathological heart sounds. The user can utilize the heart sound analysis results and the acoustic and visual representation of the heart sound recordings as decision support data in their decision-making process regarding the presence and type of a heart murmur.
More Information

Not Found

Yes
The device description explicitly states that the analysis is performed using an "AI-based algorithm" and that the murmur detection algorithm is based on a "neural network model".

No.
The device is a decision-support software used to record, display, and analyze acoustic signals of the heart for evaluation, not to provide therapy.

Yes

The device records, displays, and analyzes acoustic signals of the heart, categorizing heart sounds as "abnormal" or "normal" based on the identification of heart murmurs. While it states it is not intended as a sole means of diagnosis, its primary function is to interpret patient data to aid in a medical evaluation.

No

The device description explicitly states that the software "receives the data using a Thinklabs One electronic stethoscope" and "shall be used together with Thinklabs One electronic stethoscope." This indicates a required hardware component (the electronic stethoscope) that is integral to the device's function, making it not solely software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Function: The AusculThing ACC software analyzes acoustic signals of the heart recorded by an electronic stethoscope. This is a non-invasive method of collecting data directly from the patient's body, not from a sample taken from the body.
  • Intended Use: The intended use is to provide decision support to healthcare providers in the evaluation of patient heart sounds. This involves listening to and analyzing sounds produced by the body, not analyzing biological samples.

Therefore, the AusculThing ACC falls under the category of a medical device, but not specifically an In Vitro Diagnostic device.

No
The letter does not explicitly state that a PCCP was reviewed and approved or cleared by the FDA for this device.

Intended Use / Indications for Use

The AusculThing ACC software is a decision-support SW for the healthcare provider (the user) in the evaluation of patient heart sounds. The ACC is used to record, display, and analyze acoustic signals of the heart recorded by means of an electronic stethoscope. It is intended for use on adult and pediatric patients. The automated analysis will categorize heart sounds as either "abnormal" if any heart murmur of any intensity is identified in any position across the precordium, or "normal" if either no murmurs or benign murmurs are identified. ACC is indicated for use in a setting where auscultation would typically be performed by a healthcare provider. It is not intended as a sole means of diagnosis. The heart sound interpretation offered by the software is only significant when used in conjunction with physician over-read and including all other relevant patient data. The device is intended for Rx use only. The AusculThing ACC shall be used together with Thinklabs One electronic stethoscope.

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

DQD, DQC

Device Description

AusculThing ACC is a decision support SW that collects heart sounds from adult and pediatric patients. The ACC software receives the data using a Thinklabs One electronic stethoscope. The SW is running on a mobile device, where the electronic stethoscope is connected to. The SW guides the user how relevant heart sound recordings should be obtained from different parts of the body. After recording, the ACC analyzes the recordings automatically using an AI -based algorithm, which is trained using a proprietary echocardiogram validated high-quality data database.

The basic functionality of the ACC SW is to give a user an instant, automated, analysis of the patient under evaluation and differentiate between normal and pathological sounds. For the abnormal heart sounds, the ACC delivers information on suspected murmurs.

The ACC software is a SW that allows a user to upload heart sounds/phonocardiogram (PCG) data to the device for analysis and visualization. The AusculThing ACC Mobile App runs on a mobile device. The app permits the electronic recording of heart sound signals via a compatible electronic stethoscope (Thinklabs One). The app also permits visual and acoustic playback of heart sounds in the mobile device. After analysis, results are returned to the user in the App. The Murmur detection algorithm is based on a neural network model that uses heart sounds to detect the presence of pathological heart sounds.

The user can utilize the heart sound analysis results and the acoustic and visual representation of the heart sound recordings as decision support data in their decision-making process regarding the presence and type of a heart murmur.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Yes - "AI -based algorithm", "neural network model"

Input Imaging Modality

Not Found

Anatomical Site

precordium (for heart sound recording)

Indicated Patient Age Range

Adult and pediatric patients

Intended User / Care Setting

Healthcare provider (the user).
Setting where auscultation would typically be performed by a healthcare provider.

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

The algorithm in this submission has been validated using proprietary data captured with the ACC. A total of 519 recordings were captured from a study population consisting of 133 patients. Of the population 84 were below 18 years of age and 49 were above. Out of the 133 patients 84 had a confirmed heart defect. All data was collected in a clinical study in accordance with GCP/ISO14155.
Heart sounds were recorded from all patients either by a cardiologist. An echocardiogram was conducted by a cardiologist on all patients to establish the golden standard for diagnosis to which the algorithm performance was compared.
Data source details:

  • Children population: Kuopio University Hospital (Puijo Hospital) - 14 patients, Oulu University Hospital - 70 patients. Audio recordings obtained by Cardiologist.
  • Adults population: Hospital district of Helsinki and Uusimaa (Lohja Hospital) - 20 patients, Hyvinkää Hospital - 29 patients. Audio recordings obtained by Cardiologist.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Study Type: Clinical Testing (Validation study)
Sample Size: 133 patients, 519 recordings.
Key Results: The obtained accuracy, sensitivity and specificity were compared to the predicate device performance metrics as provided in the predicate device 510k summary (K181988). The results from the study demonstrate that ACC does not perform worse than the predicate device in the given test setting.

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

Sensitivity: 90.5% (82.3%-95.1%)
Specificity: 96.0% (86.3%-98.9%)
Accuracy: 92.5% (86.7%-95.9%)

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.

K181988

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

§ 870.1875 Stethoscope.

(a)
Manual stethoscope —(1)Identification. A manual stethoscope is a mechanical device used to project the sounds associated with the heart, arteries, and veins and other internal organs.(2)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.(b)
Electronic stethoscope —(1)Identification. An electronic stethoscope is an electrically amplified device used to project the sounds associated with the heart, arteries, and veins and other internal organs.(2)
Classification. Class II (special controls). The device, when it is a lung sound monitor, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.

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July 12, 2023

AusculThing Oy Jani Virtanen Process owner, Regulatory and Quality Affairs Ruusutorpanpuisto 4 A 15 Espoo, 02600 Finland

Re: K230823

Trade/Device Name: AusculThing ACC Regulation Number: 21 CFR 870.1875 Regulation Name: Stethoscope Regulatory Class: Class II Product Code: DQD, DQC Dated: June 12, 2023 Received: June 12, 2023

Dear Jani Virtanen:

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.

1

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-regulatoryinformation/postmarketing-safety-reporting-combination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Hetal B. Patel -S

for

Robert Kazmierski Acting Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known)

Device Name

Indications for Use (Describe)

Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

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Type of Use (Select one or both, as applicable)

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5. 510(k) Summary

Submitter information

Name:AusculThing Ltd.
Address:Ruusutorpanpuisto 4 A 15
02600 Espoo, Finland
Phone:+358 50 3801 134
Contact person:Jani Virtanen, D.Sc.
Regulatory and Quality Affairs, Process Owner
Submission date:15 March 2023

Device information

Trade name:AusculThing ACC
Common name:Decision support SW, Computer Aided Auscultation, Heart Sound Analyzer
Classification name:Electronic Stethoscope, Phonocardiograph
Regulation number:21 CFR 870.1875, 870.2390
Product code:DQD, DQC
Classification panel:Cardiology
Predicate devices
Primary predicate:K181988Emurmur ID

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5.1 Device Description

AusculThing ACC is a decision support SW that collects heart sounds from adult and pediatric The ACC software receives the data using a Thinklabs One electronic patients. stethoscope. The SW is running on a mobile device, where the electronic stethoscope is connected to. The SW guides the user how relevant heart sound recordings should be obtained from different parts of the body. After recording, the ACC analyzes the recordings in conjunction automatically using an AI -based algorithm, which is trained using a proprietary echocardiogram validated high-quality data database. An image below shows the basic architecture of the use environment for the ACC.

Image /page/4/Figure/4 description: The image shows an electronic stethoscope connected to a mobile device with ACC. The mobile device displays a waveform and an image of a chest with several points marked on it. The image also mentions BT/USB/WIFI connection for software updates and a database consisting of clinically validated pediatric heart sounds.

Image 5.1. Basic structure of the ACC use environment.

The basic functionality of the ACC SW is to give a user an instant, automated, analysis of the patient under evaluation and differentiate between normal and pathological sounds. For the abnormal heart sounds, the ACC delivers information on suspected murmurs.

The ACC software is a SW that allows a user to upload heart sounds/phonocardiogram (PCG) data to the device for analysis and visualization. The AusculThing ACC Mobile App runs on a mobile device. The app permits the electronic recording of heart sound signals via a compatible electronic stethoscope (Thinklabs One). The app also permits visual and acoustic playback of heart sounds in the mobile device. After analysis, results are returned to the user in the App. The Murmur detection algorithm is based on a neural network model that uses heart sounds to detect the presence of pathological heart sounds.

The user can utilize the heart sound analysis results and the acoustic and visual representation of the heart sound recordings as decision support data in their decision-making process regarding the presence and type of a heart murmur.

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Image /page/5/Picture/1 description: The image contains the logo for AusculThing. The logo consists of a stylized blue icon to the left, resembling interconnected lines, followed by the name "AusculThing" in a dark gray sans-serif font. Below the name, there is a tagline that reads "Reinventing auscultation" in a lighter gray, smaller font.

5.2 Intended use

The AusculThing ACC software is a decision-support SW for the healthcare provider (the user) in the evaluation of patient heart sounds. The ACC is used to record, display, and analyze acoustic signals of the heart recorded by means of an electronic stethoscope. It is intended for use on adult and pediatric patients. The automated analysis will categorize heart sounds as either "abnormal" if any heart murmur of any intensity is identified in any position across the precordium, or "normal" if either no murmurs or benign murmurs are identified. ACC is indicated for use in a setting where auscultation would typically be performed by a healthcare provider. It is not intended as a sole means of diagnosis. The heart sound interpretation offered by the software is only significant when used in conjunction with physician over-read and including all other relevant patient data. The device is intended for Rx use only. The AusculThing ACC shall be used together with Thinklabs One electronic stethoscope.

5.3 Technological characteristics

AusculThing ACC has technological characteristics that are comparable to the predicate device:

  1. Both systems host a heart sound analysis algorithm.

  2. Both systems provide the user with a mobile app, which is used to record heart sounds and patient information. Both systems perform an analysis to the data and display the analysis results to the user.

  3. Both systems require an FDA-cleared off-the-shelf electronic stethoscope for the acquisition of the heart sounds.

  4. Both devices provide similar heart sound analysis output and similar additional supporting information to the user.

The predicate device in this 510(k) Premarket Notification submission is eMurMur ID (K181988) which function and indication are substantially equivalent for the Ausculthing ACC software. On a table below is presented the technical characteristics of the ACC software and eMurMur ID.

The ACC does not raise different questions of safety or effectiveness in comparison to the predicates. While some of the predicate devices feature additional technological capabilities (e.g., the predicate device additional parameters on heart sound), this does not raise different questions of safety or effectiveness because in all cases the subject device features are a subset of those cleared predicate devices.

ACCEmurmur ID
Device typeSoftware onlySoftware only
Physiological inputHeart soundsHeart sounds
Classification
product codeDQD, DQCDQD, DQC
510(k) numberK230823K181988
Patient populationAdult and pediatricAdult and pediatric
Intended
/
use
Indications for UseThe AusculThing ACC software is a
decision-support SW for the healthcare
provider (the user) in the evaluation of
patient heart sounds. The ACC is used
to record, display, and analyze acoustic
signals of the heart recorded by means
of an electronic stethoscope. It is
intended for use on adult and pediatric
patients. The automated analysis will
categorize heart sounds as either
"abnormal" if any heart murmur of any
intensity is identified in any position
across the precordium, or "normal" if
either no murmurs or benign murmurs
are identified. ACC is indicated for use
in a setting where auscultation would
typically be performed by a healthcare
provider. It is not intended as a sole
means of diagnosis. The heart sound
interpretation offered by the software is
only significant when used in
conjunction with physician over-read
and including all other relevant patient
data. The device is intended for Rx use
only. The AusculThing ACC shall be
used together with Thinklabs One
electronic stethoscope.The eMurmur ID software system is a
decision support device for the healthcare
provider (the user) in the evaluation of
patient heart sounds. eMurmur ID is used
to record, display, analyze, and store the
acoustic signal of the heart, recorded by
means of an electronic stethoscope. The
automated analysis will identify specific
heart sounds that may be present,
including S1, S2, physiological heart
murmurs, pathological heart murmurs
and absence of a heart murmur.
eMurmur ID is indicated for use in a
setting where auscultation would
typically be performed by a healthcare
provider. It is not intended as a sole
means of diagnosis. The heart sound
interpretations offered by eMurmur ID
are only significant when considered in
conjunction with healthcare provider
over-read and including all other relevant
patient data.
PrescribedPrescription onlyPrescription only
User interfaceApp (iOS/Android) for recording heart
sounds, performing analysis of
recordings locally on the device and
presenting the analysis results.App for recording heart sounds, sending
analysis requests and receiving analysis
results. Web portal for reviewing and
editing user and patient data.
Murmur detectionYes (Classification)Yes (Classification)
Acquires and records
heart soundsYes - acoustic signal of heart by means
of electronic stethoscope and mobile
appYes - acoustic signal of heart by
means of electronic stethoscope and
mobile app
Analyzes heart
soundsYes - distinguishes between normal
and pathological heart murmursYes – distinguishes between
normal/physiological and pathological
heart murmurs
Intended userHealthcare provider licensed orHealthcare provider licensed or
authorized to perform auscultationauthorized to perform auscultation
BackendThe mobile device analyzes the data
and communicates with the other
components of AusculThing ACC.
Results from the analysis can be shared
via email.Server analyzes (algorithm) and stores
(database) patient-related data and
communicates with the other components
of eMurmur ID. The interface to the other
components is a REST/JSON web API.
Safety featuresNo protected health information is
stored on the user's devices. User has
authentication on the app and the
mobile device.Encrypted internet traffic, data stored in
the database on the backend is encrypted,
data in the database is duplicated to
another database in a different datacenter,
no protected health information is stored
on the user's devices, user needs to
authenticate, user can only access
authorized data.

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Image /page/6/Picture/1 description: The image contains the logo for AusculThing. The logo consists of a stylized graphic to the left of the company name. Below the company name is the tagline "Reinventing auscultation."

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5.4 Performance data - Non-clinical Testing

Performance data included software verification and validation testing, no performance data under non-clinical testing have been included.

5.5 Performance data - Clinical Testing

The algorithm in this submission has been validated using proprietary data captured with the ACC. A total of 519 recordings were captured from a study population consisting of 133 patients. Of the population 84 were below 18 years of age and 49 were above. Out of the 133 patients 84 had a confirmed heart defect. All data was collected in a clinical study in accordance with GCP/ISO14155.

In the table below the content (age distribution, gender, diagnoses and auscultation findings) of the validation data is described. Some of the patients have multiple diagnoses.

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R01.0 : Benign murmurQ21.0 : Ventricular Septal DefectQ21.10 : Atrial Septal DefectQ21.11 : Patent foramen ovaleQ23.0 : Stenosis congenita valva e aortaQ23.11 : Valvae aortae biscupidalisQ22.1 : Stenosis congenita valva pulmonalis (inc. ToF)Q25.1 : Coarctation of the aortaQ25.0 : Patent ductus arteriosusQ23.10 : Insufficientia congenita valvae aortaeQ22.2 : Insufficientia congenita valvae pulmonalisQ23.3 : Insufficientia congenita valvae mitralisQ25.7 : Stenosis pulmonalisQ35.0: Stenosis valvae aortaeQ37.0 : Stenosis valvae pulmonalisQ34.2: Stenosis valvae mitralisQ35.1 : Insufficientia valvae aortaeQ37.1 : Insufficientia valvae pulmonalisQ34.0 : Insufficientia valvae mitralisQ36.1 : Insufficientia valvae tricuspidalisNormal (no murmur nor heart defect)
Age group0 - 1 months063000112000000000003
1 - 6 months634000200000100000003
6 - 12 months322100001000100000000
1 - 4 years500011102000000000001
4 - 12 years940062231000100000107
12 -18 years310021000200010000003
18 - 55 years300000000000050010101
55 -80 years4000000000000200030531
>80 years000000000000080010100
SexMale16510633202002220040839
Female18900313160001120010007
Systolic findings241410946362003330050831
Diastolic finding000010104000000000000
Systolic gradus11300000002100000000000
21041012221000170000101
30600323111002110020410
4020040102000000000000
5000000000000020000000
6000000000000000000000
Diastolic gradus1000010001000000000000
2000000103000000000000
3000000000000000000000
4000000000000000000000
Punctum MaximumA400062110100080010000
B4000004030003150030220
C8130021001100070000000
D400000000000020010600
Unspecified14110111220000200000116

Heart sounds were recorded from all patients either by a cardiologist. An echocardiogram was conducted by a cardiologist on all patients to establish the golden standard for diagnosis to which the algorithm performance was compared. The table below shows the amount of recordings made in each hospitals.

K230823

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| Population | Hospital District | Hospital | Audio recordings
obtained by | Patient count |
|------------|-------------------------------------------------|-----------------------------|---------------------------------|---------------|
| Children | Kuopio University
Hospital | Puijo Hospital | Cardiologist | 14 |
| Children | Oulu University
Hospital | Oulu University
Hospital | Cardiologist | 70 |
| Adults | Hospital district of
Helsinki and
Uusimaa | Lohja Hospital | Cardiologist | 20 |
| Adults | Hospital district of
Helsinki and
Uusimaa | Hyvinkää Hospital | Cardiologist | 29 |

The obtained accuracy, sensitivity and specificity were compared to the predicate device performance metrics as provided in the predicate device 510k summary (K181988) and are shown in the following table:

ACCeMurmur ID
Sensitivity90.5% (82.3%-95.1%)85.0% (72.9%-92.5%)
Specificity96.0% (86.3%-98.9%)86.7% (74.9%-93.7%)
Accuracy92.5% (86.7%-95.9%)85.8% (78.0%-91.3%)

The results from the study demonstrate that ACC does not perform worse than the predicate device in the given test setting.

Conclusions

The ACC Analysis Software is as safe and effective as the predicate device. Performance data demonstrate that the AusculThing ACC software performs in a manner that is comparable to the reference device, meeting the criteria that it be at least non-inferior. The ACC Analysis Software has the same intended use and similar indications, technological characteristics, and principles of operation as its predicate device. The minor technological differences between AusculThing ACC and its predicate device raise no new questions of safety or effectiveness when used as labeled. Thus, the ACC Analysis Software is substantially equivalent.