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510(k) Data Aggregation

    K Number
    K223905
    Manufacturer
    Date Cleared
    2023-10-06

    (282 days)

    Product Code
    Regulation Number
    870.2200
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Avicena, LLC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Vivio® System is indicated to non-invasively estimate left ventricular end-diastolic pressure (LVEDP) is above or below 18mmHg. This measurement can aid in the diagnosis of heart failure when used by qualified healthcare professionals as an adjunct alongside other clinically relevant information. For use in adults only.

    Device Description

    The Vivio System consists of an Arm Cuff system (BP cuff electronics, connection tubinq), EKG patch, and a software application that runs on an off-the-shelf computer tablet. Data is collected non-invasively at the brachial artery and via a single-lead EKG Patch. An off-the-shelf blood pressure arm cuff is attached to the patient's upper arm as if taking a blood pressure measurement. The Arm Cuff is attached to the blood pressure cuff with the quick connect end connected to the pneumatic pump within the Arm Cuff Electronics Enclosure. Two off-the-shelf electrodes are attached to the snap connections on the bottom of the EKG Patch and then connected on the left side of the patient's chest. Both the pneumatic pump attached to the Arm Cuff and EKG Patch are then powered on by pressing and releasing their respective power buttons. The Vivio App is opened on an off-the shelf computer tablet, and the on-screen prompts are followed to connect the Arm Cuff and the EKG Patch. The user is prompted to enter required patient and user data, initiating a patient recording session. Data from the recording session is processed by a proprietary algorithm and results reported on the computer tablet.

    AI/ML Overview

    The provided document focuses on the 510(k) summary for the Vivio® System, which is an "Adjunctive Cardiovascular Status Indicator" device. It outlines the regulatory classification, device description, indications for use, technological characteristics, and summaries of non-clinical and clinical tests.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    Indications for Use: The Vivio® System is indicated to non-invasively estimate left ventricular end-diastolic pressure (LVEDP) as above or below 18mmHg. This measurement aids in the diagnosis of heart failure when used by qualified healthcare professionals as an adjunct alongside other clinically relevant information, for use in adults only.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document states "The primary efficacy objectives for the study were met." The acceptance criteria for efficacy are directly linked to diagnostic performance metrics:

    Acceptance Criteria (Performance Metric)Reported Device Performance (95% Confidence Interval)
    Sensitivity80% (64-91)
    Specificity80% (73-86)

    Note: The document does not explicitly state these as acceptance criteria but rather as "primary efficacy objectives for the study." In the context of a 510(k) submission, meeting these pre-specified performance thresholds demonstrates the device's ability to achieve its intended use. The LVEDP threshold for diagnosis is 18mmHg.


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

    • Sample Size (Test Set):

      • Cath Lab Cohort: 195 subjects scheduled for non-emergent left heart catheterization.
      • Non-Aged Healthy Cohort: 101 subjects.
      • Aged Healthy Cohort: 40 subjects.
      • Total Enrolled: 195 + 101 + 40 = 336 subjects.
      • However, the statistical analysis was performed on a "subset of validation data that had passed the completeness and quality requirements outlined in the data management plan and procedure." The exact size of this final validation subset, specifically used for the reported sensitivity and specificity, is not explicitly stated, but it would be derived from the 195 subjects in the "Cath Lab Cohort" used for comparison to invasive LVEDP. The sensitivity and specificity numbers are specifically tied to the LVEDP estimate, which would rely on the cohort with ground truth LVEDP measurements (Cath Lab Cohort).
    • Data Provenance:

      • Geographic Origin: The Cath Lab Cohort was enrolled "across 9 sites" (locations not specified, assuming within the US for FDA clearance), and the two Healthy Cohorts were enrolled "at a single site" (location not specified).
      • Nature of Data: Prospective validation study.

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

    • The document states that the ground truth for the Cath Lab Cohort was "gold-standard invasive LVEDP obtained via the Millar Mikro-Cath." This is a direct physiological measurement, not established by human experts in a subjective reading context.
    • For the "reference-standard non-invasive echocardiographic indices" used for the Aged Healthy Cohort, the document does not specify the number or qualifications of experts involved in establishing these indices. However, echocardiographic indices are objective measurements and calculations, typically performed by trained sonographers and interpreted by cardiologists/echocardiographers.

    4. Adjudication Method for the Test Set

    • Since the primary ground truth for LVEDP was an invasive, objective measurement (Millar Mikro-Cath), no expert adjudication method (like 2+1 or 3+1) would have been necessary for this part of the ground truth establishment.
    • For the echocardiographic indices, the document does not provide details on adjudication, but as noted above, these are typically objective measurements.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • The document does not indicate that an MRMC comparative effectiveness study was done to show how human readers improve with AI vs. without AI assistance.
    • The Vivio System is described as a device that "estimates LVEDP" and "aids in the diagnosis of heart failure when used by qualified healthcare professionals as an adjunct." It provides a calculated clinical parameter, not necessarily an AI-driven image interpretation system that assists human readers.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    • Yes, the reported "sensitivity of 80% (64-91), and specificity of 80% (73-86)" appear to be a measure of the Vivio System's (algorithm's) standalone performance in classifying LVEDP as above or below 18mmHg against the invasive gold standard. The device generates the estimate, and these metrics directly assess its accuracy.

    7. Type of Ground Truth Used

    • Primary Ground Truth: "Gold-standard invasive LVEDP obtained via the Millar Mikro-Cath" for the Cath Lab Cohort. This is direct physiological outcomes data.
    • Reference Standard: "Reference-standard non-invasive echocardiographic indices" for the Aged Healthy Cohort. This relies on established clinical measurements, not subjective expert consensus.

    8. Sample Size for the Training Set

    • The document does not specify the sample size used for the training set. It mentions a "proprietary algorithm" and a "fixed parameter model" (as opposed to AI/machine learning), but no details on its development data are provided.

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

    • The document does not specify how the ground truth for the training set was established. Given the device uses a "fixed parameter model" rather than a machine learning model, it implies that the algorithm's parameters were likely determined based on physiological principles and pre-existing clinical data/models, rather than a large-scale data-driven training process with established ground truth labels in the same way as an AI model.

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    K Number
    K183710
    Device Name
    Vivio System
    Manufacturer
    Date Cleared
    2019-10-04

    (277 days)

    Product Code
    Regulation Number
    870.1875
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Avicena LLC

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Vivio System is indicated for low frequency (

    Device Description

    The Vivio Unit is an electronic stethoscope containing a membrane, placed on the skin over the carotid artery, that is displaced due to vibrations produced by the arterial pulse waveform and heart sounds associated with the aortic valve opening and closing. An infrared light photo reflector transmits and detects light to/from the membrane and outputs a current relative to the detected light (or membrane movement). Sensor electronics inside the Vivio Unit generate a current to operate the sensor, read the current produced by the sensor and output a voltage relative to the current. Filter electronics condition the sensor signal, process the data and communicate the data to the tablet with the Avicena App. The Vivio Unit is powered by an internal, rechargeable battery.

    AI/ML Overview

    The provided text describes a 510(k) submission for the Avicena Vivio System, a digital electronic stethoscope. While it outlines the device's intended use, comparison to a predicate device, and compliance with various standards, it does not contain specific acceptance criteria or a study proving the device meets acceptance criteria related to its diagnostic accuracy or clinical performance.

    The document explicitly states: "This submission does not include animal or clinical performance testing."

    Therefore, I cannot provide the requested information regarding acceptance criteria and a study that proves the device meets them from the provided text, as such information is not present. The submission focuses on substantial equivalence based on technical characteristics, safety, and non-clinical bench testing.

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