K Number
K233842
Manufacturer
Date Cleared
2024-05-31

(179 days)

Product Code
Regulation Number
866.3984
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The iHealth COVID-19 Antigen Rapid Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 virus nucleocapsid protein antigen directly in anterior nasal swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days of symptom onset. This test is for nonprescription home use by individuals aged 15 years or older testing themselves, or adults testing individuals aged 2 years or older.

The iHealth COVID-19 Antigen Rapid Test does not differentiate between SARS-CoV-2.

All negative results are presumptive. Symptomatic individuals with an initial negative test result must be re-tested once between 48 and 72 hours after the first test using either an antigen test or a molecular test for SARS-CoV-2. Negative results do not preclude SARS-CoV-2 infections or other pathogens and should not be used as for treatment. Positive results do not rule out co-infection with other respiratory pathogens.

This test is not a substitute for visits to a healthcare provider or appropriate follow-up and should not be used to determine any treatments without provider supervision. Individuals who test negative and experience continued or worsening COVID-19 like symptoms, such as fever, cough and/or shortness of breath, should seek follow up care from their healthcare provider.

The performance characteristics for SARS-CoV-2 were established from October 2022 to June 2023 when the COVID-19 variant Omicron was dominant. Test accuracy may change as new SARS-CoV-2 viruses emerge. Additional testing with a lab-based molecular test (e.g., PCR) should be considered in situations where a new virus or variant is suspected.

Device Description

The iHealth COVID-19 Antigen Rapid Test employs lateral flow immunoassay technology. Using this test allows for the rapid detection of nucleocapsid protein from SARS-CoV-2.

To begin the test, a self-collected anterior nares swab sample in individuals aged 15 and older or individuals between the age of 2 to 14 with a swab collected by a parent or quardian is inserted into a tube that has been pre-filled with reagent. The reagent in the tube interacts with the specimen and facilitates exposure of the appropriate viral antigens to the antibodies used in the test. The liguid in the tube, now containing the specimen, is added to the Sample Port of the COVID-19 Test Card.

If the extracted specimen contains SARS-CoV-2 antigens, a pink-to-purple T Line, along with a pink-to-purple C Line will appear on the COVID-19 Test Card indicating a positive result. If SARS-CoV-2 antigens are not present at very low levels, only a pinkto-purple C Line will appear.

AI/ML Overview

Acceptance Criteria and Study to Prove Device Meets Criteria: iHealth COVID-19 Antigen Rapid Test

The iHealth COVID-19 Antigen Rapid Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 virus nucleocapsid protein antigen directly in anterior nasal swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days of symptom onset. This test is for nonprescription home use by individuals aged 15 years or older testing themselves, or adults testing individuals aged 2 years or older.

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Implicit from provided data on clinical performance)Reported Device Performance (Clinical Study)
Positive Percent Agreement (PPA): High agreement with highly sensitive molecular SARS-CoV-2 assays for positive samples.88.9% (95% Confidence Interval: 81.9% to 93.4%)
Negative Percent Agreement (NPA): High agreement with highly sensitive molecular SARS-CoV-2 assays for negative samples.99.9%; (95% Confidence Interval: 99.3% to 100.0%)
PPA by Days Since Symptom Onset: Expected performance across different days since symptom onset, especially higher PPA earlier in symptom onset.Day 1: 50.0% (Note: Low sample size); Day 2: 100.0%; Day 3: 91.9%; Day 4: 88.0%; Day 5: 75.0%; Day 6: 71.4%
Precision/Reproducibility: Consistent and reliable results across different lots, operators, and sites, particularly for negative, low positive (1x LoD), and moderate positive (3x LoD) samples.100% agreement for all samples (negative, 1x LoD, 3x LoD) across 3 sites, 3 operators, and 3 lots over 5 non-consecutive days. (95% CI: 99.1-100%)
Limit of Detection (LoD): Ability to detect low concentrations of SARS-CoV-2 virus.1.33x10^4 TCID50/mL (665 TCID50/swab) for Omicron Variant. 4.00x10^2 IU/mL (20 IU/swab) for WHO Standard.
Cross-Reactivity (Analytical Specificity): No false positives or interference from common respiratory pathogens and commensal organisms.No cross-reactivity or interference observed with 53 commensal and pathogenic microorganisms (22 bacteria and 31 viruses) tested.
Endogenous Interfering Substances: Performance not affected by common substances found in respiratory specimens or artificially introduced to the nasal cavity.No cross-reactivity or interference observed with 31 potentially interfering substances tested at relevant concentrations.
Hook Effect: No decrease in signal at very high concentrations of the analyte.No Hook effect observed at 3.98x10^6 TCID50/mL (300x LoD), the highest concentration tested.
Inclusivity (Analytical Reactivity): Ability to detect various SARS-CoV-2 variants.Successfully detected 14 SARS-CoV-2 strains including Alpha, Beta, Gamma, Delta, Omicron, and several Omicron sub-lineages (BA.2, BA.2.3, BA.4, BA.4.6, BA.5, BQ.1, BQ.1.1, XBB), with specified lowest variant concentrations for 5/5 positive replicates.
Flex Studies: Robustness of the test under variations in test procedure and environmental conditions.Studies support that the test is robust with an insignificant risk of erroneous results under various conditions (swab extraction time, sample drops, development time, sample analysis delay, agitation, temperature, humidity, cassette disturbance, sample/reagent temperature, lighting).

2. Sample Size Used for the Test Set and Data Provenance

  • Test Set Sample Size: 915 individuals.
  • Data Provenance:
    • Country of Origin: United States (investigational sites throughout the U.S.).
    • Retrospective or Prospective: Prospective. The clinical performance characteristics were evaluated in a study where subjects with signs and symptoms of COVID-19 were enrolled, collected samples, and the test was performed. Data was collected between October 2022 to June 2023.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

The document does not explicitly state the number of "experts" used for ground truth or their specific qualifications for the clinical study.

  • Ground Truth Method: The iHealth COVID-19 Antigen Rapid Test results were compared to a highly sensitive molecular FDA EUA Authorized SARS-CoV-2 assays (RT-PCR) to determine test performance. This molecular test is considered the gold standard for SARS-CoV-2 detection, establishing the definitive ground truth for the presence or absence of the virus.

4. Adjudication Method for the Test Set

The document indicates that for discordant results (false positives or false negatives against the initial comparator method), a "second FDA EUA high sensitivity molecular SARS-CoV-2 assay" was used. This suggests a form of 2+1 adjudication where the initial comparator result is one "read," the iHealth test result is the other, and a second molecular assay acts as the tie-breaker or confirmatory truth.

  • Specifically:
    • Of 13 false negative samples (iHealth negative, comparator positive), 1 was confirmed negative by a second molecular assay, and 12 were confirmed positive.
    • Of 1 false positive sample (iHealth positive, comparator negative), it was confirmed positive by a second molecular assay.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

No, an MRMC comparative effectiveness study was not explicitly done in the context of comparing human readers with and without AI assistance, as this is an antigen rapid test that is visually read by lay users. The study evaluated the standalone performance of the test as interpreted by lay users (self-testers or adult testers for children).

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done

For the clinical performance evaluation, the test was performed by lay users (individuals aged 15+ testing themselves, or adults testing individuals aged 2-14). Therefore, the clinical performance data presented (PPA, NPA) represents the device's performance with human-in-the-loop interpretation by the intended user. It is not a purely "algorithm-only" or "standalone" performance without any human involvement in interpreting the visual result. However, the device itself is a diagnostic test, not an AI/algorithm for image interpretation. The "algorithm" here (lateral flow immunoassay) is inherent to the device's physical mechanism.

Other analytical studies (precision, LoD, cross-reactivity, etc.) represent technical performance without human interpretation error as these are typically performed in a controlled lab setting by trained personnel.

7. The Type of Ground Truth Used

The primary ground truth for the clinical study (testing individuals) was established using a highly sensitive molecular FDA EUA Authorized SARS-CoV-2 assay (RT-PCR). For discordant results, a second molecular assay was used for confirmation.

8. The Sample Size for the Training Set

This document describes a premarket notification for a medical device (an antigen rapid test). It does not explicitly mention a "training set" in the context of machine learning. The term "training set" is typically used for AI/ML models. If the underlying assay development involved any statistical modeling or calibration, the data used for that would precede this type of submission. However, for a lateral flow immunoassay, the "training" involves optimizing the biochemical reagents and visual readout.

9. How the Ground Truth for the Training Set Was Established

Given that this is a lateral flow immunoassay device and not an AI/ML diagnostic, the concept of a "training set" with established ground truth as commonly understood in AI/ML is not directly applicable. The "ground truth" during the development and optimization phases would involve rigorous analytical validation using known positive and negative samples, purified viral cultures, and clinical samples characterized by gold standard molecular tests (like RT-PCR), similar to the analytical studies detailed (e.g., LoD, inclusivity, cross-reactivity) but performed during product development before clinical trials.

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May 31, 2024

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: on the left, there is a circular seal with an abstract image of an eagle or a similar bird-like figure, surrounded by text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA". To the right of the seal, there is the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue, with "ADMINISTRATION" appearing in a smaller font size below "FOOD & DRUG".

Tianyang Liu Director of Regulatory and Policy 880 W Maude Ave Sunnyvale, California 94085

Re: K233842

Trade/Device Name: iHealth COVID-19 Antigen Rapid Test Regulation Number: 21 CFR 866.3984 Regulation Name: Over-the-counter test to detect SARS-CoV-2 from clinical specimens Regulatory Class: Class II Product Code: QYT Dated: December 4, 2023 Received: December 4, 2023

Dear Tianyang Liu:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov

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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safetyreporting-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Digitally signed by Silke Silke Schlottmann -S Schlottmann -S Date: 2024.05.31 15:51:47

Silke Schlottmann, Ph.D. Deputy Assistant Director Bacteriology Respiratory and Medical Countermeasures Branch Division of Microbiology Devices OHT7: Office of In Vitro Diagnostics Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Indications for Use

510(k) Number (if known) K233842

Device Name iHealth COVID-19 Antigen Rapid Test

Indications for Use (Describe)

The iHealth COVID-19 Antigen Rapid Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 virus nucleocapsid protein antigen directly in anterior nasal swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days of symptom onset. This test is for nonprescription home use by individuals aged 15 years or older testing themselves, or adults testing individuals aged 2 years or older.

The iHealth COVID-19 Antigen Rapid Test does not differentiate between SARS-CoV-2.

All negative results are presumptive. Symptomatic individuals with an initial negative test result must be re-tested once between 48 and 72 hours after the first test using either an antigen test or a molecular test for SARS-CoV-2. Negative results do not preclude SARS-CoV-2 infections or other pathogens and should not be used as for treatment. Positive results do not rule out co-infection with other respiratory pathogens.

This test is not a substitute for visits to a healthcare provider or appropriate follow-up and should not be used to determine any treatments without provider supervision. Individuals who test negative and experience continued or worsening COVID-19 like symptoms, such as fever, cough and/or shortness of breath, should seek follow up care from their healthcare provider.

The performance characteristics for SARS-CoV-2 were established from October 2022 to June 2023 when the COVID-19 variant Omicron was dominant. Test accuracy may change as new SARS-CoV-2 viruses emerge. Additional testing with a lab-based molecular test (e.g., PCR) should be considered in situations where a new virus or variant is suspected.

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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510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirement of 21 CFR 807.92.

1.0 Submitter's Information

Name:iHealth Labs, Inc.
Address:880W Maude Ave Sunnyvale, CA 94085 USA
Phone number:(408) 398 0318
Contact:Tianyang Liu
Contact email:policy@ihealthlabs.com
Date Prepared:May 31, 2024

2.0 Device Information

Device trade name: iHealth COVID-19 Antigen Rapid Test Device Common Name: Coronavirus Antigen Detection Test

3.0 Classification

Product code:QYT
Classification Regulation:21 CFR 866.3984 - Over-The-Counter Test To DetectSARS-Cov-2 From Clinical Specimens
Classification:Class II
Review Panel:Microbiology

4.0 Predicate Device Information

510(k) numberK230828
ManufacturerACON Laboratories,Inc
Trade/Proprietary NameFlowflex COVID-19 Antigen Home Test
ClassificationRegulation21 CFR 866.3984 - Over-The-Counter Test ToDetect SARS-CoV-2 From Clinical Specimens
ClassificationClass II
Product CodeQYT

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5.0 Device Description

The iHealth COVID-19 Antigen Rapid Test employs lateral flow immunoassay technology. Using this test allows for the rapid detection of nucleocapsid protein from SARS-CoV-2.

To begin the test, a self-collected anterior nares swab sample in individuals aged 15 and older or individuals between the age of 2 to 14 with a swab collected by a parent or quardian is inserted into a tube that has been pre-filled with reagent. The reagent in the tube interacts with the specimen and facilitates exposure of the appropriate viral antigens to the antibodies used in the test. The liguid in the tube, now containing the specimen, is added to the Sample Port of the COVID-19 Test Card.

If the extracted specimen contains SARS-CoV-2 antigens, a pink-to-purple T Line, along with a pink-to-purple C Line will appear on the COVID-19 Test Card indicating a positive result. If SARS-CoV-2 antigens are not present at very low levels, only a pinkto-purple C Line will appear.

6.0 Intended Use

The iHealth COVID-19 Antigen Rapid Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 nucleocapsid protein antigens directly in anterior nasal (nares) swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days from symptom onset. This test is for nonprescription home use by individuals aged 15 years or older testing themselves, or adults testing individuals aged 2 years or older.

The iHealth COVID-19 Antigen Rapid Test does not differentiate between SARS-CoV and SARS-CoV-2.

All negative results are presumptive. Symptomatic individuals with an initial neqative test result must be re-tested once between 48 and 72 hours after the first test using either an antigen test or a molecular test for SARS-CoV-2. Negative results do not preclude SARS-CoV-2 infections or other pathogens and should not be used as the sole basis for treatment. Positive results do not rule out co-infection with other respiratory pathogens.

This test is not a substitute for visits to a healthcare provider or appropriate follow-up and should not be used to determine any treatments without provider supervision. Individuals who test negative and experience continued or worsening COVID-19 like symptoms, such as fever, cough and/or shortness of breath, should seek follow up care from their healthcare provider.

The performance characteristics for SARS-CoV-2 were established from October 2022 to June 2023 when the COVID-19 variant Omicron was dominant. Test accuracy may change as new SARS-CoV-2 viruses emerge. Additional testing with a lab-based molecular test (e.g., PCR) should be considered in situations where a new virus or variant is suspected.

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7.0 Comparison with Predicate Device

CharacteristicsSubject DevicePredicate Device
Product NameiHealth COVID-19 Antigen Rapid TestFlowflex COVID-19 Antigen Home Test
510(K) NumberK233842K230828
Product CodeQYTQYT
Regulation Number21 CFR 866.398421 CFR 866.3984
Regulatory ClassClass IIClass II
Assay TargetCOVID-19 nucleocapsid protein antigenCOVID-19 nucleocapsid protein antigen
Intended UseThe iHealth COVID-19 Antigen Rapid Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 nucleocapsid protein antigens directly in anterior nasal (nares) swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days from symptom onset. This test is for non-prescription home use by individuals aged 15 years or older testing themselves, or adults testing individuals aged 2 years or older.The Flowflex COVID-19 Antigen Home Test is a visually read lateral flow immunoassay device intended for the rapid, qualitative detection of SARS-CoV-2 virus nucleocapsid protein antigen directly in anterior nasal swab specimens from individuals with signs and symptoms of COVID-19 within the first 6 days of symptom onset. This test is for non-prescription home use by individuals aged 14 years or older testing themselves, or adults testing individuals aged 2 years or older.
The iHealth COVID-19 Antigen Rapid Test does not differentiate between SARS-CoV and SARS-CoV-2.The Flowflex COVID-19 Antigen Home Test does not differentiate between SARS-CoV and SARS CoV-2.
All negative results are presumptive. Symptomatic individuals with an initial negative test result must be re-tested once between 48 and 72 hours after the first test using either an antigen test or a molecular test for SARS-CoV-2. Negative results do not preclude SARS-CoV-2 infections or other pathogens and should not be used as the sole basis for treatment. Positive results do not rule out co-infection with other respiratory pathogens.All negative results are presumptive. Symptomatic individuals with an initial negative test result must be re-tested once between 48 and 72 hours after the first test using either an antigen test or a molecular test for SARS-CoV2. Negative results do not preclude SARS-CoV-2 infections or other pathogens and should not be used as the sole basis for treatment. Positive results do not rule out coinfection with other respiratory pathogens.
This test is not a substitute for visits to a healthcare provider or appropriate follow-up and should not be used to determine any treatments without provider supervision Individuals whoThis test is not a substitute for visits to a healthcare provider or appropriate follow-up and should not be used to determine any treatments without
CharacteristicsSubject DevicePredicate Device
test negative and experiencecontinued or worsening COVID-19like symptoms, such as fever, coughand/or shortness of breath, shouldseek follow up care from theirhealthcare provider.provider supervision. Individuals whotest negative and experiencecontinued or worsening COVID-19like symptoms, such as fever, coughand/or shortness of breath, shouldseek follow up care from theirhealthcare provider.
The performance characteristics forSARS-CoV-2 were established fromOctober 2022 to June 2023 when theCOVID-19 variant Omicron wasdominant. Test accuracy may changeas new SARS-CoV-2 viruses emerge.Additional testing with a lab-basedmolecular test (e.g., PCR) should beThe performance characteristics forSARS-CoV-2 were established fromDecember 2022 to March 2023 whenSARSCOV-2 Omicron was dominant.Test accuracy may change as newSARS-CoV-2 viruses emerge.Additional testing with a
considered in situations where a newvirus or variant is suspected.lab-based molecular test (e.g., PCR)should be considered in situationswhere a new virus or variant issuspected.
AnalyteSARS-CoV-2 nucleocapsid proteinantigenSARS-CoV-2 nucleocapsid proteinantigen
Intended UsePopulationIndividuals with symptoms of COVID-19Individuals with symptoms of COVID-19
Prescription orOTCOTCOTC
UsageSingle use testSingle use test
Specimen TypeAnterior nasal swab specimensAnterior nasal swab specimens
Assay ResultQualitativeQualitative
TechnologyLateral flow immunoassayLateral flow immunoassay
Rapid TestYesYes
ResultInterpretationVisually readVisually read
InstrumentNoNo
Time to Result15-30 min15-30 min
StorageCondition2-30°C2-30°C

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8.0 Performance Summary

8.1 Precision/Reproducibility

The purpose of the study was to assess between-site and between-lot variability of three different lots of the iHealth COVID-19 Antigen Rapid Test. Three (3) levels of heatinactivated SARS-CoV-2 were spiked in negative clinical matrix (NCM, Nasal fluid diluted in 1:3 Saline) as follows:

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  • A. Negative, NCM
  • B. Low positive (1x LoD)
  • C. Positive (3x LoD)

The lot-to-lot precision of the iHealth COVID-19 Antigen Rapid Test was evaluated by using three (3) product lots. A series of coded, contrived samples were prepared as negative, low positive (1xLoD), and moderate positive (3xLoD) using heat inactivated SARS-CoV-2. Each sample level was tested in triplicate in each run per day with three (3) operators at three (3) CLIA waived sites for 5 non-consecutive days. The agreement of obtained results with expected results was 100% for all samples across all lots, operators, and days. Variability in results was not observed between the three independently manufactured lots.

Precision/Reproducibility Study - Summary Results
SiteTrue NegativeLow Positive(1x LoD)Positive(3x LoD)
Site 1(External, 3 operators)135/135135/135135/135
Site 2(External, 3 operators)135/135135/135135/135
Site 3(External, 3 operators)135/135135/135135/135
Total405/405405/405405/405
% Agreement100%100%100%
95% CI99.1-100%99.1-100%99.1-100%

8.2 Limit of Detection (LOD)

The LoD of the iHealth COVID-19 Antigen Rapid Test was established by using limiting dilutions of heat inactivated SARS-CoV-2 virus (BA.5. Omicron Variant). The virus was spiked into negative clinical matrix prepared by mixing raw nasal fluid in saline (1:2) that was confirmed as SARS-CoV-2 negative by RT-PCR.

At each dilution, 50 µL of sample was added to swabs and then tested through the full assay workflow, from processing in the extraction reagent to reading the test result. Testing was performed with 5 replicates per concentration. The estimated LoD was found from testing the initial 5 different concentrations. Using this preliminary concentration, the LoD was confirmed with a 3-fold dilution series, using three test lots tested on consecutive davs The LoD was determined as the lowest virus concentration that was detected ≥ 95% of the time (concentration at which at least 19 out of 20 replicates tested positive) for each lot.

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The iHealth COVID-19 Antigen Rapid Test LOD in natural nasal swab matrix is 1.33×104 TCIDso/mL. Based upon the testing procedure for this study, the LoD of iHealth COVID-19 Antigen Rapid Test TCID50/mL equates to 665 TCID50/swab.

The 1st WHO International Standard for SARS-CoV-2 Antigen (NIBSC 21/368) was also tested to determine the LoD of the iHealth COVID-19 Antigen Rapid Test with a standardized material for SARS-CoV-2.

A preliminary LoD concentration with the WHO standard material was determined for the iHealth COVID-19 Antigen Rapid Test by testing a series of two-fold dilutions starting at 4000 IU/mL. Three replicates using three test kit lots were tested for this two-fold dilution series, flowed by an additional series of two-fold dilutions to refine the preliminary LoD. The preliminary LoD was then confirmed by testing an additional twenty (20) replicates with each of 3 test lots.

Limit of Detection - Summary Results
Virus StrainLoD in NCMLoD per Swab#Positive/#total TestedPercent Detected (%)
Omicron Variant$1.33\times10^4$ TCID50/mL665 TCID50/swab60/60100%
WHO Standard (NIBSC 21/368)$4.00\times10^2$ IU/mL20 IU/swab59/6098.3%

8.3 Cross Reactivity (Analytical Specificity) and Microbial Interference

The potential cross-reactivity (exclusivity) of a panel of common organisms was evaluated with SARS-CoV-2 negative samples using the iHealth COVID-19 Antigen Rapid Test. Potential microbial interference was evaluated with samples containing heat inactivated SARS-CoV-2 virus (BA.5. Omicron Variant) sample at approximately 2 x LoD.

A total of 53 commensal and pathogenic microorganisms (22 bacteria and 31 viruses) that may be present in the nasal cavity were evaluated in this study. Each of the organism and virus were tested in five replicates in the absence or presence of heat inactivated SARS-CoV-2 virus.

No cross-reactivity or interference was observed with the microorganisms.

Cross Reactivity (Analytical Specificity) and Microbial Interference - SummaryResults
List of OrganismConcentrationtestedCross-reactivityresultsMicrobialinterferenceresults
Human coronavirus 229E$4.50\times10^4$TCID50/mLNo cross-reactivityNo interference
Human coronavirus OC43$1.36\times10^5$TCID50/mLNo cross-reactivityNo interference
Human coronavirus NL63$2.84\times10^5$TCID50/mLNo cross-reactivityNo interference
MERS-coronavirus27.1( Ct value)No cross-reactivityNo interference
SARS-coronavirus$1\times10^5$ PFU/mLNo cross-reactivityNo interference
Human coronavirus HKU133.8 (Ct value)*No cross-reactivityNo interference
Adenovirus)Adenovirus Type 1$2.82\times10^6$TCID50/mLNo cross-reactivityNo interference
Adenovirus Type 4$2.84\times10^5$TCID50/mLNo cross-reactivityNo interference
Adenovirus Type 7A$3.16\times10^5$TCID50/mLNo cross-reactivityNo interference
Adenovirus Type 8$1.13\times10^5$ U/mLNo cross-reactivityNo interference
Adenovirus Type 31$1.13\times10^5$TCID50/mLNo cross-reactivityNo interference
Adenovirus Type 41$3.80\times10^5$TCID50/mLNo cross-reactivityNo interference
HumanMetapneumovirusus (hMPV)HumanMetapneumovirus 3(hMPV-3) Type B1$0.94\times10^5$TCID50/mLNo cross-reactivityNo interference
HumanMetapneumovirus 4(hMPV-4) Type B2$3.33\times10^5$TCID50/mLNo cross-reactivityNo interference
HumanMetapneumovirus 9(hMPV-9) Type A1$1.13\times10^5$TCID50/mLNo cross-reactivityNo interference
ParainfluenzavirusParainfluenza VirusType 1$3.80\times10^5$TCID50/mLNo cross-reactivityNo interference
Parainfluenza VirusType 2$3.39\times10^6$TCID50/mLNo cross-reactivityNo interference
Parainfluenza VirusType 3$1.15\times10^6$TCID50/mLNo cross-reactivityNo interference
Parainfluenza VirusType 4A$1.13\times10^5$TCID50/mLNo cross-reactivityNo interference
Parainfluenza VirusType 4B$9.55\times10^5$TCID50/mLNo cross-reactivityNo interference
Influenza A & BInfluenza A H3N2$1.13\times10^5$TCID50/mLNo cross-reactivityNo interference
Influenza B Victoria$1.26\times10^5$TCID50/mLNo cross-reactivityNo interference
EnterovirusEnterovirus Type 68$2.84\times10^5$TCID50/mLNo cross-reactivityNo interference
Enterovirus Type 71$1.13\times10^5$TCID50/mLNo cross-reactivityNo interference
Respiratorysyncytial virusRespiratory SyncytialVirus Type A (RSV-A)$1.05×10^5$ TCID50/mLNo cross-reactivityNointerference
Respiratory SyncytialVirus Type B (RSV-B)$1.51×10^5$ TCID50/mLNo cross-reactivityNointerference
Rhinovirus Type 1A$1.13×10^5$ TCID50/mLNo cross-reactivityNointerference
Haemophilus influenzae$1.42×10^8$ CFU/mLNo cross-reactivityNointerference
Streptococcus pneumoniae$7.22×10^7$ CFU/mLNo cross-reactivityNointerference
Streptococcus pyogenes$4.60×10^8$ CFU/mLNo cross-reactivityNointerference
Candida albicans$1.31×10^7$ CFU/mLNo cross-reactivityNointerference
Pooled human nasal wash –representative of normal respiratorymicrobial flora-No cross-reactivityNointerference
Bordetella pertussis$1.16×10^9$ CFU/mLNo cross-reactivityNointerference
Mycoplasma pneumoniae$2.16×10^8$ CCU/mLNo cross-reactivityNointerference
Chlamydia pneumoniae$1.33×10^8$ IFU/mLNo cross-reactivityNointerference
Legionella pneumophila$1.42×10^9$ CFU/mLNo cross-reactivityNointerference
Staphylococcus aureus$1.42×10^8$ CFU/mLNo cross-reactivityNointerference
Staphylococcus epidermidis$6.84×10^8$ CFU/mLNo cross-reactivityNointerference
Mycobacterium tuberculosis$1.21×10^7$ CFU/mLNo cross-reactivityNointerference
Pseudomonas aeruginosa$7.09×10^8$ CFU/mLNo cross-reactivityNointerference
Streptococcus salivarius$1.35×10^8$ CFU/mLNo cross-reactivityNointerference
Corynebacterium diphtheriae$3.43×10^7$ CFU/mLNo cross-reactivityNointerference
Escherichia coli$8.16×10^8$ CFU/mLNo cross-reactivityNointerference
Lactobacillus Acidophilus$6.58×10^7$ CFU/mLNo cross-reactivityNointerference
Moraxella catarrhalis$5.92×10^7$ CFU/mLNo cross-reactivityNointerference
Neisseria elongata$1.07×10^9$ CFU/mLNo cross-reactivityNointerference
Neisseria meningitidis serogroup A$2.04×10^7$ CFU/mLNo cross-reactivityNointerference
Neisseria meningitidis serogroup B$9.15×10^7$ CFU/mLNo cross-reactivityNointerference
Neisseria meningitidis serogroup C$7.90×10^7$ CFU/mLNo cross-reactivityNointerference
Epstein-Barr virus$0.97\times10^7$ cp/mLNo cross-reactivityNo interference
Mumps virus$9.55\times10^5$ TCID50/mLNo cross-reactivityNo interference
Cytomegalovirus (CMV)$1.13\times10^5$ TCID50/mLNo cross-reactivityNo interference
Measles virus$1.23\times10^7$ TCID50/mLNo cross-reactivityNo interference
* Note: one HKU1 NP clinical sample has been tested in 5 replicates

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8.4 Endogenous Interfering Substances

Substances, naturally present in respiratory specimens or that may be artificially introduced into the nasal cavity or nasopharynx, were evaluated with the iHealth COVID-19 Antigen Rapid Test.

The SARS-CoV-2 target concentration in the positive samples was approximately 2 x LoD. All samples were tested in 5 replicates and produced expected results, demonstrating that the iHealth COVID-19 Antigen Rapid Test performance was not affected by any of the 31 potentially interfering substances at the tested concentration.

Endogenous Interfering Substances - Summary Results
SubstanceConcentration innegative/positivesampleCross-reactivityInterference
Throat lozenges, oral anestheticand analgesic (Benzocaine)3mg/mLNo cross-reactivityNo interference
Throat lozenges, oral anestheticand analgesic (Menthol)3mg/mLNo cross-reactivityNo interference
Sore throat spray (Phenol)5% w/vNo cross-reactivityNo interference
Mucin : bovine submaxillary gland,type I-S or pooled mucous(Purified mucin protein)2.5 mg/mLNo cross-reactivityNo interference
Whole Blood (human)2.5%No cross-reactivityNo interference
Leukocytes4.8×106 cells/mLNo cross-reactivityNo interference
Zinc (common ingredient in manynasal sprays)5% v/vNo cross-reactivityNo interference
Nasal drops (Phenylephrine)15% v/vNo cross-reactivityNo interference
Nasal sprays(Cromolyn)15% v/vNo cross-reactivityNo interference
Afrin (Oxymetazoline)15% v/vNo cross-reactivityNo interference
Saline nasal spray (Sodiumchloride with preservatives)15% v/vNo cross-reactivityNo interference
Nasal corticosteroids(Beclomethasone dipropionate)15% v/vNo cross-reactivityNo interference

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Nasal corticosteroids(Dexamethasone)15% v/vNo cross-reactivityNo interference
Nasal corticosteroids (Flunisolide)15% v/vNo cross-reactivityNo interference
Nasocort Allery 24 hour(Triamcinolone)15% v/vNo cross-reactivityNo interference
Rhinocort (Budesonide/Glucocorticoid)15% v/vNo cross-reactivityNo interference
Nasal corticosteroids(Mometasone furoate)15% v/vNo cross-reactivityNo interference
Nasal corticosteroids (FluticasonePropionate)15% v/vNo cross-reactivityNo interference
(Homeopathic Luffa opperculataGalphimia glauce)1.25%No cross-reactivityNo interference
Nasal gel (Luffa opperculatasulfur)1.25%No cross-reactivityNo interference
Homeopathic allergy relief, ornasal wash (Galphimia glauca)15% v/vNo cross-reactivityNo interference
Homeopathic allergy relief, ornasal wash (Histaminumhydrochloricum)15% v/vNo cross-reactivityNo interference
Homeopathic allergy relief, ornasal wash(Alkalol)15% v/vNo cross-reactivityNo interference
Homeopathic allergy relief, ornasal wash (Zicam)15% v/vNo cross-reactivityNo interference
Anti-viral drugs (Tamiflu)5mg/mLNo cross-reactivityNo interference
Anti-viral drugs (Remdesivir)5mg/mLNo cross-reactivityNo interference
Anti-viral drugs (Molnupiravir)5mg/mLNo cross-reactivityNo interference
Antibiotic, nasal ointment(Mupirocin)10mg/mLNo cross-reactivityNo interference
Hand sanitizer15% v/vNo cross-reactivityNo interference
Hand soap15% v/vNo cross-reactivityNo interference
Biotin*200 ng/mLNo cross-reactivityNo interference

8.5 Hook Effect

There is no Hook effect at 3.98×10 TCIDso/mL corresponding to 300x LoD, which is the highest concentration that have been tested.

8.6 Inclusivity (Analytical Reactivity)

The inclusivity of the iHealth COVID-19 Antigen Rapid Test was evaluated with 14 strains of SARS-CoV-2 representing temporal, geographic, and genetic diversity within the currently circulating subtypes and lineages.

Inclusivity (Analytical Reactivity) - Summary Results
SARS-CoV-2 VariantLowest Variant Concentrationwith 5/5 positive replicates

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[TCID50/mL]
SARS-CoV-2 virus (USA-WA1/2020)4.57 x 103
B.1.1.7 (Alpha)9.55x 103
B.1.351 (Beta)3.80 x 103
P.1 (Gamma)1.7 x 103
B.1.617.2 (Delta)1.26 x 104
B.1.1.529 (Omicron)5.01 x 102
BA.2. (Omicron)1.0 x 103
BA.2.3 (Omicron)1.17 x 103
BA.4 (Omicron)6.31 x 103
BA.4.6 (Omicron)1.00 x 104
BA.5(Omicron)3.98 x 103
BQ.1(Omicron)2.0 x 103
BQ.1.1(Omicron)7.94 x 104
XBB (Omicron)1.0 x 103

8.7 Flex Studies

To assess the robustness of the iHealth COVID-19 Antigen Rapid Test, flex studies were conducted that assessed all major aspects of the test procedure (e.q., swab extraction time, drops of sample added to test cassette, development time, delay in sample analysis, swab agitation, sample buffer agitation) and variability of environmental test conditions that the test may be subjected to when in use (e.g., various temperature and humidity stress, cassette disturbance, sample/reagent temperature, lighting). Testing was performed with contrived positive nasal swabs prepared by diluting heat inactivated SARS-CoV-2 virus into negative clinical nasal swab matrix at 2x LoD. The studies support that the test is robust in the intended use condition with an insignificant risk of erroneous results.

9.0 Clinical Testing Summary

Clinical performance characteristics of the iHealth COVID-19 Antigen Rapid Test were evaluated in a total of eight (8) investigational sites throughout the U.S. A total of 915 individuals with signs and symptoms of COVID-19 within the first six (6) days of symptom onset completed the study and obtained a valid result. Each subject was provided an iHealth COVID-19 Antigen Rapid Test., Subjects fifteen (15) years and older collected an anterior nasal sample by themselves, conducted the test, interpreted and reported the result. The parents of subjects two (2) to fourteen (14) years of age collected the anterior nasal sample, conducted the test, interpreted and recorded the test result for the child. The iHealth COVID-19 Antigen Rapid Test results were compared to a highly sensitive molecular FDA EUA Authorized SARS-CoV-2 assays to determine test performance. The iHealth COVID-19 Antigen Rapid Test when conducted by a lay user correctly identified 88.9% of positive samples. Additionally, the iHealth COVID-19 Antigen Rapid Test correctly identified 99.9% of negative samples. The performance is shown in the following

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iHealt

table.

Comparator Method
iHealth COVID-19 Antigen Rapid TestPositiveNegativeTotal
Positive1041b108
Negative13a797810
Total117798915
Positive Agreement: (104/117) 88.9% 95% Confidence Interval: 81.9% to 93.4%

Negative Agreement: (797/798) 99.9%; 95% Confidence Interval: 99.3% to 100.0%

ª Of the 13 false negative samples, 1 of them was negative on a second FDA EUA high sensitivity molecular SARS-CoV-2 assay, 12 of them was positive on a second FDA EUA high sensitivity molecular SARS-CoV-2 assay.

b Of the 1 false positive sample was positive on a second FDA EUA high sensitivity molecular SARS-CoV-2 assay.

Age and gender distribution and positive rate of symptomatic subjects within first 6 days of symptom onset

Age Group (years)FemaleMalePositivePositivity Rate % (totalpositive/total tested)
2 to 13636653.9% (5/129)
14 to 24139943314.2% (33/233)
25 to 643232067213.6% (72/529)
≥65168729.2% (7/24)
Total54137411712.8% (117/915)
Positive results broken down by days since symptom onset
Days SinceSymptom OnsetRT-PCRPositive (+)iHealth testPositive (+)PPA95 % Confidence Interval
14250.0%15.0% - 85.0%
23232100.0%89.0% - 100.0%
3373491.9%78.7% - 98.2%
4252288.0%70.0% - 95.8%
512975.0%46.7% - 91.1%
67571.4%35.9% - 91.7%
Total11710488.9%81.9% - 93.4%

10.0 Conclusion

Based on the data submitted in this traditional 510(k) submission, the device has been shown to be substantially equivalent in term of intended use, design, technological characteristics and assay performance to the predicate device K230828.

N/A