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510(k) Data Aggregation
(244 days)
Bioness Inc.
The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.
The StimRouter Neuromodulation System consists of two main parts - the implantable lead, and the external (to the body) accessories for the StimRouter include a clinician programmer with software (CPS), a disposable hydrogel electrode patch, an external pulse transmitter, an external pulse transmitter stimulation tester and a device used by the patient to wirelessly control the external pulse transmitter. The StimRouter Neuromodulation System is provided with three labeling documents: the Clinician's Guide, the Procedure Manual and the User's Guide. The complete StimRouter System consists of three kits: a Lead and Lead Introducer Kit, a Clinician Kit and User Kit. The Lead Kit contains the StimRouter implantable multielectrode lead with integrated receiver, used for peripheral nerve stimulation. The Lead receives an electrical signal transmitted transcutaneously by the external pulse transmitter which is mounted on an electrode patch on the skin and delivers that electrical signal down the lead's length to a target peripheral nerve. The Lead is supplied in Lead Loader that is used during intraoperative testing of the lead and to verify proper placement during implantation. The Lead and Lead Introducer Kit consists of two stimulation probes, two stimulation cables, and introducer set, a lead adapter, a Tunneling Needle, and a Tunneling Needle Stylet. The included tools and components allow for insertion of the StimRouter Lead and confirmation of optimal location of the stimulation electrode contacts of the StimRouter Lead. The Clinician Kit is used for the programming of the external pulse transmitter. The components of the Clinician Kit are a tablet PC with programming software that is capable of connecting to and configuring the external pulse transmitter. The User Kit contains the patient-use components of the StimRouter System. The components are the External Electric Field Conductor (E-EFC), an external pulse transmitter, with included charger and the StimRouter Electrode Carrying Case. After the E-EFC is programmed, the E-EFC can be connected to the StimRouter Electrode through which it can deliver stimulation transcutaneously to the implanted lead receiver.
The provided text describes a 510(k) premarket notification for the StimRouter Neuromodulation System, arguing for its substantial equivalence to a previously cleared predicate device (K200482). The submission primarily focuses on comparing the technological characteristics of the new device (modified StimRouter) with the predicate, rather than presenting a study with specific acceptance criteria and performance data for a standalone algorithmic device.
Therefore, many of the requested details about acceptance criteria, specific device performance metrics, sample sizes for test/training sets, ground truth establishment, and multi-reader multi-case studies are not available in the provided document. The document describes a comparison study, not a standalone performance study as would be typical for an AI/ML device.
Here's a breakdown of what can be extracted and what is missing:
1. Table of Acceptance Criteria and Reported Device Performance
This information is not provided in the document as specific numerical acceptance criteria and corresponding reported device performance for an algorithm's classification or prediction capabilities. The document describes a comparison of technical characteristics between the modified StimRouter and its predicate, rather than reporting performance against predefined acceptance criteria.
The "Equivalency Assessment" column in the table on pages 5-6 indicates similarity to the predicate and states that differences do not affect safety and effectiveness of intended use. For example:
- EWD Electrical Signal Transmitter: "Similar. The E-EFC circuitry is functionally equivalent to the EPT circuitry. The differences do not affect safety and effectiveness of intended use."
- EWD Phase Duration: "The reduction in number of positive phase duration values (due to a simplified code base) does not affect safety and effectiveness of the intended use because minor adjustments can be made to other parameters to create therapeutic programs equivalent to those provided by the EPT."
- EWD Max Compliance Voltage: The E-EFC's maximum compliance voltage increased to 130V from the predicate's 100V. The assessment states: "This difference in hardware does not affect safety and effectiveness of the intended use."
2. Sample size used for the test set and the data provenance
Not applicable/Not provided. This document does not describe a study involving a test set of data for evaluating an AI/ML algorithm's performance. The "performance testing" mentioned on page 15 refers to electrical compatibility, wireless coexistence, biocompatibility, shipping, storage, shelf life, functional verification, usability, and software verification/validation—these are not related to a data-driven performance evaluation with a test set in the context of AI.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable/Not provided. As there is no described test set or ground truth establishment in the context of an AI/ML algorithm's performance, this information is not present.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable/Not provided.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable/Not provided. This submission is for a neuromodulation system, not an AI/ML diagnostic or assistive device that would involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable/Not provided. The device described is a physical neuromodulation system, not a standalone algorithm. The software components are for controlling the device (CPS, MAPP app) and are evaluated through software verification and validation, not standalone diagnostic performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable/Not provided.
8. The sample size for the training set
Not applicable/Not provided. No AI/ML training is described.
9. How the ground truth for the training set was established
Not applicable/Not provided.
Summary of the Study Performed (as described in the document):
The "study" described in the 510(k) submission is a comparison of technological characteristics and performance testing to demonstrate substantial equivalence to a predicate device (StimRouter Neuromodulation System cleared in K200482).
The core of the submission (pages 5-6) is a detailed table comparing the "Subject Device (Modified StimRouter)" to the "Predicate (StimRouter cleared in K200482)" across numerous technical attributes, including:
- Manufacturer, 510(k) number, Intended use (all identical)
- Implantable Lead and Lead Introducer Kit components (packaging, lead characteristics, introduction method, tools) - indicated as "No changes" or "Same"
- User Kit accessories (External Electrical Field Conductor (E-EFC) vs. External Pulse Transmitter (EPT), MAPP Smartphone Application vs. Patient Programmer)
- Clinician Kit accessories (Modified Clinician's Programming Software (CPS) vs. original CPS)
The "Equivalency Assessment" column justifies why any differences (e.g., changes in electronics, wireless protocol, charging port, integrated controls, maximum compliance voltage, or phase duration values) do not affect the safety and effectiveness of the intended use, arguing that similar functionality is maintained or improved.
Performance Testing Mentioned (page 15):
The document lists "Performance Testing" categories that the StimRouter Neuromodulation System was qualified through:
- Electrical compatibility and safety
- Wireless coexistence
- Biocompatibility Testing
- Shipping and storage
- Shelf life
- Functional Verification
- Usability
- Software Verification and Validation Testing
These tests are standard for medical devices and demonstrate the device's adherence to relevant standards and its functional capabilities, rather than an AI/ML algorithm's data-driven performance. The document concludes that based on these comparisons and performance tests, the modified StimRouter is substantially equivalent to its predicate and does not raise new safety or effectiveness concerns.
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(29 days)
Bioness Inc.
The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.
The StimRouter Neuromodulation System consists of two main parts - the implantable lead, and the external (to the body) accessories. Accessories for the StimRouter include a clinician programmer with software (CPS), a patient programmer, disposable hydrogel electrode patch, external pulse transmitter (EPT), and an EPT stimulation tester (EPTT). The StimRouter Neuromodulation System is provided with three labeling documents: the Clinician's Guide, the Procedure Manual and the User's Guide. Only the Procedure Manual has been modified to include an alternative implantation procedure for situations in which an open implantation of the implantable StimRouter Lead is indicated.
The complete StimRouter System consists of three kits: A Lead and Lead Introducer Kit, a Clinician Kit and User Kit. The Lead Kit contains the StimRouter implantable multielectrode lead with integrated receiver, used for peripheral nerve stimulation. The Lead receives an electrical signal transmitted transcutaneously by the EPT which is mounted on an electrode patch on the skin and delivers that electrical signal down the lead's length to a target peripheral nerve. The Lead is supplied in Lead Loader that is used during intraoperative testing of the lead and to verify proper placement during implantation.
The Lead and Lead Introducer Kit consists of two stimulation probes, two stimulation cables, and introducer set, a lead adapter, a Tunneling Needle and a Tunneling Needle Stylet. The included tools and components allow for insertion of the StimRouter Lead and confirmation of optimal location of the stimulation electrode contacts of the StimRouter Lead.
The Clinician Kit is used for the programming of the StimRouter patient programmer and the EPT. The components of the Clinician Kit are a tablet PC with programming software and the accessories for connecting to the Patient Programmer and the EPT.
The User Kit contains the patient-use components of the StimRouter System. The components are the Patient Programmer and the EPT. After the EPT is programmed, the StimRouter electrode interfaces with the EPT and function to delivery stimulation to the implanted lead receiver.
This document is a 510(k) premarket notification for a modified version of the StimRouter Neuromodulation System. It's a submission to the FDA to demonstrate substantial equivalence to a previously cleared device, not a report of a new clinical study proving effectiveness with specific acceptance criteria in the traditional sense of a clinical trial.
Therefore, many of the requested categories related to clinical study design, ground truth establishment, expert adjudication, and comparative effectiveness studies are not applicable or directly provided in this type of regulatory document. This document focuses on demonstrating that a modification to an already cleared device does not introduce new questions of safety or effectiveness.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't present a table of quantitative acceptance criteria and reported device performance because it's a 510(k) submission for a modification to a previously cleared device (K190047). The primary "acceptance criterion" for a 510(k) is demonstrating "substantial equivalence" to a predicate device, which largely relies on showing that the modifications do not raise new questions of safety or effectiveness and that the technological characteristics are similar or that any differences do not affect safety or effectiveness.
The document states:
- "As noted in the Predicate Device Comparison Matrix below, other than the update of the Procedure Manual to include an alternative implantation procedure for situations in which an open implantation of the implantable StimRouter Lead is indicated, there are no other modifications with respect to the K190047 predicate all other technological characteristics are equivalent."
- "The new procedure is being provided for situations in which the surgical field has been previously opened and does not introduce additional risks to the patient. Also, the new method of placing the Lead allows for similarly effective stimulation of target nerve and receipt of stimulation from EPT."
- "Bioness Inc. concludes that the Risks vs. Benefits assessment remains unchanged, where the benefits accrued from the use of the device outweigh any identified residual risk."
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not applicable. This document is not a clinical study report with a test set of patients. It's a regulatory submission for a device modification. The assessment is based on design controls and a comparison to a predicate device.
- Data Provenance: Not applicable for a traditional test set. The "data" used for this submission are the design specifications, risk analysis, and comparison to the predicate device's existing clearance.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
- Not applicable. There is no traditional "test set" of medical cases requiring ground truth established by experts in the context of this 510(k) submission for a modification. The assessment of the modification's impact is internal to the manufacturer's design control process and reviewed by the FDA.
4. Adjudication Method for the Test Set:
- Not applicable for the same reasons as #3.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done:
- No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is typically conducted to evaluate diagnostic devices or imaging systems where human readers interpret results, often with and without AI assistance. The StimRouter Neuromodulation System is a therapeutic implantable device, and this submission concerns a change in its implantation procedure.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
- Not applicable. The StimRouter is a physical neuromodulation system, not an algorithm, and its use inherently involves human practitioners (implanting physicians and patient interaction with the programmer).
7. The Type of Ground Truth Used:
- The "ground truth" implicitly used here relies on the established safety and effectiveness of the predicate device (K190047) and the engineering and clinical assessment that the proposed modification (alternative implantation procedure) does not alter that established safety and effectiveness or introduce new risks. The risk assessment considers potential harms, but clinical outcomes data from a specific study for this modification is not presented as "ground truth."
8. The Sample Size for the Training Set:
- Not applicable. This is not an AI/ML device that requires a training set of data.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable for the same reasons as #8.
In summary: This document is an FDA 510(k) premarket notification for a modification to an existing medical device. It relies on demonstrating substantial equivalence to a predicate device, which is different from a clinical study that establishes performance against specific acceptance criteria for a novel device or AI algorithm. The focus here is on showing that the minor change (an alternative implantation procedure described in updated labeling) does not negatively impact the safety and effectiveness profile already established for the predicate device.
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(30 days)
Bioness Inc.
The L100 Go System is intended to provide ankle dorsiflexion in adults with foot drop or muscle weakness related to upper motor neuron disease/injury (e.g., stroke, damage to the spinal cord). The L100 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the foot; thus, it also may improve the adult's gait.
The L100 Go System may also:
- · Facilitate muscle re-education
- · Prevent/retard disuse atrophy
- · Maintain or increase joint range of motion
- · Increase local blood flow
The L100 Go System is designed to improve gait in adults suffering from foot drop or muscle weakness. The L100 Go System can also deliver transcutaneous stimulation to the muscles in the lower leg to facilitate muscle re-education, prevent/retard disuse atrophy, maintain or increase joint range of motion, and/or increase local blood flow.
The L100 Go system consists of the following L300 Go components/accessories with the exception of a modified lower leg cuff:
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- External Pulse Generator (EPG), which can be plugged into Lower Leg Cuff. EPG contains user interface including control and indications. EPG also contains integrated motion sensors enabling detecting gait events.
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- Lower Leg Cuff, including cradle for the EPG. This is the only L300 Go component modified for the L100 Go.
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- Clinician Application (CAPP), installed on tablet PC. CAPP is used by a trained clinician during configuration of the system for optimal fitting to the patient.
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- Power supply (charger) with two USB ports and a proprietary cable to charge the EPG.
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- Tester, which is used for trouble shooting to confirm that stimulation is being delivered.
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- Optional Mobile Application (MAPP), based on the iOS and Android SmartPhone platform enabling the patients to wirelessly control the EPG(s) and retrieve and monitor their daily activity.
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- Electrode and electrode bases which are attached to the inner side of the lower leg cuff.
The L100 Go System can be operated in one of the following modes:
- Gait Mode
- Training Mode •
- . Clinician Mode
Gait Mode is used for walking, and it can be selected by the clinician and also by the patient. Training Mode is used to train muscles when patients are not walking (for example, sitting or lying down), and it can be selected by either the clinician or the patient. Clinician Mode allows the clinician to apply enhanced training and is only available to the clinicians.
This document is a 510(k) Pre-market Notification for a modified medical device, the L100 Go System. The submission claims substantial equivalence to a legally marketed predicate device, the L300 Go System.
1. Table of Acceptance Criteria and Reported Device Performance:
The document describes modifications to a pre-existing medical device, the L300 Go System, resulting in the L100 Go System. The acceptance criteria are implicit in the claim of "substantial equivalence" to the predicate device and the successful completion of "verification testing" for the modified components. Since this is a Special 510(k) for device modifications, specific performance metrics are not explicitly presented as acceptance criteria and reported performance in a table format. Instead, the document focuses on demonstrating that the changes do not negatively impact the safety and effectiveness, and that the modified components meet their design specifications.
The provided text states:
- "The modified cuff design was subjected to verification testing to ensure no loss of mechanical strength and functionality."
- "The L100 Go System has been verified and validated successfully for its intended use through the combination of predicate device bench testing and thorough verification and validation testing of all changes."
- "Based on the result of the nonclinical testing, Bioness concludes that the device is substantially equivalent to the predicate L300 Go System."
This indicates that the acceptance criteria were that the modified cuff design would show no loss of mechanical strength and functionality compared to the predicate device, and that all changes would pass verification and validation testing to confirm safety and effectiveness for its intended use.
The reported device performance is that these tests were "successfully" completed, affirming that the L100 Go System maintains substantial equivalence to the L300 Go System despite the modifications.
2. Sample size used for the test set and the data provenance:
The document describes "nonclinical tests" and "verification and validation testing of all changes." However, it does not specify the sample size used for these tests. The data provenance is also not explicitly stated beyond being "nonclinical testing" performed by the manufacturer (Bioness Inc.). It is implied to be laboratory/bench testing rather than clinical data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not provided in the document. As the testing focuses on mechanical strength and functionality of hardware modifications, the "ground truth" would likely be established by engineering and quality control experts within Bioness, following established testing protocols, rather than medical experts for clinical performance.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
This information is not provided. As it's nonclinical verification testing, formal adjudication methods by external experts, as seen in clinical studies, are typically not applicable. The results would be assessed against pre-defined engineering and performance specifications.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
This is not applicable. The device (L100 Go System) is an external functional neuromuscular stimulator for foot drop, not an AI-powered diagnostic or assistive technology for human "readers." Therefore, an MRMC comparative effectiveness study involving AI assistance for human readers would not be relevant to this submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
This is not applicable. The L100 Go System is a physical medical device (an external functional neuromuscular stimulator), not an algorithm or software-only device. Its performance inherently involves the device interacting with a patient's body under clinician or patient control.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
For the "nonclinical tests" related to the modified cuff design, the ground truth would be based on engineering specifications and established performance standards for mechanical strength and functionality. This would involve objective measurements (e.g., tensile strength, durability, electrical output parameters) compared against pre-defined thresholds derived from the predicate device and relevant industry standards (e.g., IEC 60601 series).
8. The sample size for the training set:
This is not applicable. The L100 Go System is a modified physical medical device, not a machine learning model that requires a training set.
9. How the ground truth for the training set was established:
This is not applicable, as there is no training set for this type of device.
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(295 days)
Bioness Inc.
The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.
The StimRouter Neuromodulation System consists of two main parts - the implantable lead, and the external (to the body) accessories for the StimRouter include a clinician programmer with software (CPS), a patient programmer, disposable hydrogel electrode patch, external pulse transmitter (EPT), and an EPT stimulation tester (EPTT).
The Bioness StimRouter Neuromodulation System is intended to provide electrical stimulation via an implanted lead to a target peripheral nerve, for aid in the management of severe, intractable, chronic pain of peripheral nerve origin in adults, as an adjunct to other modes of therapy (e.g. medications). The StimRouter is not intended to treat pain in the craniofacial region.
The complete StimRouter System consists of three kits: A Lead and Lead Introducer Kit, a Clinician Kit and User Kit. The Lead Kit contains the StimRouter implantable multielectrode lead with integrated receiver, used for peripheral nerve stimulation. The Lead receives an electrical signal transmitted transcutaneously by the EPT which is mounted on an electrode patch on the skin and delivers that electrical signal down the lead's length to a target peripheral nerve. The Lead is supplied in Lead Loader that is used during intraoperative testing of the lead and to verify proper placement during implantation.
The Lead and lead Introducer Kit consists of two stimulation probes, two stimulation cables, and introducer set, a lead adapter, a Tunneling Needle and a Tunneling Needle Stylet. The included tools and components allow for insertion of the StimRouter Lead and confirmation of optimal location of the stimulation electrode contacts of the StimRouter Lead.
The Clinician Kit is used for the programming of the StimRouter patient programmer and the EPT. The components of the Clinician Kit are a tablet PC with programming software and the accessories for connecting to the Patient Programmer and the EPT.
The User Kit contains the patient-use components of the StimRouter System. The components are the Patient Programmer and the EPT. After the EPT is programmed, the StimRouter electrode interfaces with the EPT and function to delivery stimulation to the implanted lead receiver.
This document is a 510(k) Premarket Notification from Bioness Inc. for their StimRouter Neuromodulation System. It's a submission to the FDA requesting clearance to market a modified version of an already cleared device. Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are focused on demonstrating substantial equivalence to a predicate device, rather than proving clinical efficacy from scratch as one might for a novel AI device or drug.
Based on the provided text, the device is a neuromodulation system for pain management, not an AI/ML diagnostic tool. Therefore, the questions related to AI/ML specific criteria (number of experts, MRMC studies, ground truth for training/test sets, effect size of human readers with/without AI, standalone performance) are not directly applicable.
However, I can extract information related to the device's technical specifications and the testing performed to demonstrate its safety and effectiveness, which are the "acceptance criteria" in the context of a 510(k) submission for a medical device modification.
Device: StimRouter Neuromodulation System (modified version)
Type of Submission: 510(k) Premarket Notification for a modification to a previously cleared device (K142432).
Key Goal of the Study: To demonstrate substantial equivalence of the modified StimRouter Neuromodulation System to its predicate device (original StimRouter, K142432) in terms of safety and effectiveness. This is achieved by showing that the modifications do not raise new questions of safety or effectiveness and that the device performs as intended.
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly defined by the safety and performance standards expected for an implanted peripheral nerve stimulator and the comparison to the predicate device. The "reported device performance" is demonstrated through various verification and validation activities and comparison of technical characteristics.
Acceptance Criteria (Implicit from 510(k) Process) | Reported Device Performance (as demonstrated by comparison and testing) |
---|---|
Functional Equivalence to Predicate Device | Most technical characteristics are "Same" as the predicate (e.g., intended use, manufacturer, lead design, number of electrodes, electrode shape, materials, lead length, body diameter, implantation method, stimulation probe, cables, introducer set, lead adaptor, gel electrodes, EPT power source, EPT location, EPT communication, EPT pulse frequency, EPT pulse width, waveform, stimulation modality, patient programmer programs, patient selectable programs, programmer communication, software driven, multiple stim modes, GUI, StimRouter Electrodes) |
Safety of Modified Components/Parameters: | |
- Packaging (consolidation of kits, material change) | Similar; New packaging is consolidation; PETE (new material) confirmed equivalent through qualification, has better impact resistance than PETG (old material). |
- Tray Lid Adhesive | Similar; New adhesive confirmed equivalent through qualification. |
- Increased Maximum Charge per Pulse (Lead) & Maximum Charge Density (Lead) | Similar; Safety maintained because of limits on max current (30mA) and max pulse duration (500µsec). Values are lower than other similar devices and comply with safety requirements. Detailed comparison table shows values are within safe ranges of reference predicate devices (Medtronic PNS, Renew System). |
- Tunneling Needle Material (removal of nickel plating) | Similar; Safety maintained; Nickel was previously used for soldering ease, but adequate soldering without nickel was confirmed by the vendor for the subject device. Addresses nickel allergy warning. |
- Clinician's Programmer Hardware (new off-the-shelf tablet) | Similar; Physically larger but runs substantially equivalent software (recompiled). |
- Clinician Programmer Operating System (Windows Mobile 5 to Windows 10 Home) | Similar; Same code can run in Windows 10 Home. |
- Clinician Programmer GUI (adjusted to fit larger screen) | Similar; Same GUI contents. |
- Added Stimulation Frequencies (12, 15 Hz) | Similar; New frequencies are within the original stimulation range. |
- Patient Log Export Function (software enhancement) | Similar; Minor change that just adds a function. |
- Miscellaneous Clinician Software Enhancements (obsolete buffering, co-installation) | Similar; Minor enhancements to code that do not change function. |
- Ramp Down Feature (EPT) | Similar; Provides smooth transition for patient comfort. Expected to have same paresthesia effect. |
- Maximum Compliance Voltage (EPT: 90V to 100V) | Similar; Safety maintained because of limits on max current (30mA) and max EPT external temperature (41°C). Aims to treat patients with high skin impedance or requiring higher current. |
- Charge per Phase Limit (EPT: 10 µC to 15 µC due to rechargeable batteries) | Similar; Safety maintained because of limits on max current (30mA) and max pulse duration (500µsec). The previous 10 µC limit was due to non-rechargeable battery needs, which are no longer supported. |
- Miscellaneous EPT Software Enhancements (transistor disconnection, impedance) | Similar; Updates provide better detection of conditions and unnecessary termination of stimulation. |
- Miscellaneous Patient Programmer Software Enhancements (interfering EPTs, buggy RF channels) | Similar; Software updates improve reliability of connection with EPT. |
Verification & Validation Testing Compliance | Risk Analysis methods were used to assess impact of modifications and determine required V&V activities. Extensive bench tests were conducted, including: Bioburden, Sterilization & Shelf-life, Biocompatibility, Shelf Life, Shipping Validation, Package Integrity (Bubble Leak, Seal Strength), Functional V&V, Label Validation, Printing Verification, MRI Compatibility, Implant Heating, and Software V&V Testing. |
2. Sample Size Used for the Test Set and the Data Provenance:
- Sample Size: Not explicitly stated as a number of devices/patients for a clinical trial. For a 510(k) modification where substantial equivalence is demonstrated through bench testing and comparison, the "sample size" refers to the number of units tested for each specific bench test (e.g., a certain number of devices for shelf-life testing, a certain number for functional testing). These specific numbers are not provided in this summary.
- Data Provenance: The document does not specify a country of origin for any human data (as no clinical trial data is summarized). The data primarily comes from bench testing and technical comparisons against historical predicate device data and reference devices. The submission indicates that these tests were "originally developed under the design control process of the StimRouter Neuromodulation System cleared in K142432," suggesting these are in-house engineering and lab tests. The nature of the submission (Special 510(k)) indicates that new clinical data is generally not required if performance is demonstrated through other means.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:
- This is not applicable as the submission relates to a physical medical device modification, not an AI/ML algorithm requiring expert annotation for ground truth. Ground truth for device performance is established through engineering specifications, material science, and safety standards, not subjective expert assessment of images or clinical outcomes in the same way as an AI diagnostic.
4. Adjudication Method for the Test Set:
- Not applicable for a device modification validated through bench testing and technical comparison. Clinical study adjudication methods (e.g., 2+1, 3+1) are for human-in-the-loop diagnostic studies or clinical outcome studies.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- Not applicable. This is a medical device (neuromodulation system) and not an AI-assisted diagnostic tool. No MRMC study was conducted or required for this type of submission.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an AI algorithm. Its "standalone performance" is related to its physical and functional operation as a stimulator, which is evaluated through the listed bench tests.
7. The Type of Ground Truth Used:
- The "ground truth" for this submission are the performance specifications, safety limits (e.g., charge density, current limits), and accepted medical device standards (e.g., biocompatibility standards, sterilization standards, electrical safety standards).
- For the comparative analysis, the performance characteristics of the cleared predicate device (K142432) and other reference devices (Medtronic PNS, Renew System) serve as the "ground truth" or benchmark for substantial equivalence.
8. The Sample Size for the Training Set:
- Not applicable. This is not an AI/ML algorithm requiring a training set.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable.
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(90 days)
Bioness Inc.
The L360 Thigh System is intended to assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, damage to pathways to the spinal cord). The L360 Thigh System electrically stimulates muscles in the affected leg to provide knee flexion or extension; thus, it also may improve the individual's gait.
The L360 Thigh System may also:
- Facilitate muscle re-education
- Prevent/retard disuse atrophy
- Maintain or increase joint range of motion
- Increase local blood flow
- Provide early post-surgical quadricep and hamstring strengthening
- Improve post-surgical knee stability secondary to quadricep and hamstring strengthening
- Relax muscle spasms
The L360 Thigh System is intended to assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, damaqe to pathways to the spinal cord). The L360 Thigh System electrically stimulates muscles in the affected leg to provide knee flexion or extension; thus, it also may improve the individual's gait.
The L360 Thigh System consists of:
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- One or two Thigh Functional Stimulation Cuffs (Thigh Cuff) that include surface electrodes.
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- Central External Pulse Generator (EPG). The EPG delivers stimulation to their respective cuffs, and have user interface, including visual, audio, and tactile feedback. The EPG can use motion sensor based algorithm to detect heel events.
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- An optional Control Unit that allows simple wireless remote control of the EPG's while displaying real-time information regarding the system's status.
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- An optional Gait Sensor, which uses a dynamic gait tracking algorithm to detect heel events and wirelessly synchronizes stimulation.
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- A Clinician's Programming System with software, which is used for system programming by a trained clinician during configuration of the system for optimal fitting to the patient.
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- An optional Mobile Application (MAPP) enabling the patients to wirelessly control the EPG(s) and retrieve and monitor their daily activity.
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- A power supply with two USB outputs and a proprietary cable to charge the EPG(s).
This document is a 510(k) Premarket Notification for the Bioness L360 Thigh System, seeking to expand its indications for use. Based on the provided text, the acceptance criteria are primarily demonstrated through a showing of substantial equivalence to existing predicate devices, rather than through a a new clinical study with explicitly defined performance metrics the device needs to meet.
Here's an analysis of the information requested, based on the provided text:
1. A table of acceptance criteria and the reported device performance.
The document does not provide a traditional table of acceptance criteria with specific performance metrics (e.g., accuracy, sensitivity, specificity, or improvement in a clinical outcome that the device must achieve).
Instead, the acceptance criteria for this 510(k) submission are based on demonstrating substantial equivalence to two predicate devices: the Bioness L300 Go System (K190285) and the Bio-Medical Research Ltd. Kneehab XP (K110350). The performance reported is that the device "is performing as intended" and "is substantially equivalent to the predicate devices."
The submission argues that the L360 Thigh System is essentially the "Thigh Standalone configuration" of the L300 Go System, with the only difference being an expansion of indications. Therefore, the performance tests conducted on the L300 Go System are considered applicable.
Acceptance Criterion (Implicit) | Reported Device Performance (L360 Thigh System / L300 Go System) |
---|---|
Technological Characteristics Substantial Equivalence | "The L360 Thigh System, subject of this submission is exactly the same device in all aspect to the Thigh Standalone configuration of its predicate device, the L300 Go System, cleared for marketing under K190285." |
Expanded Indication Justification | "The only difference between the devices is the expansion of the indication to provide relaxation of muscle spasms and post-surgical muscle strengthening and knee stability. The proposed indication for use is supported by its substantial equivalence to that of the Predicate Device #1, the L300 Go System (K190285) and Predicate Device #2, the Kneehab XP (K110350) with regards to its use as a neuromuscular electronic stimulator (NMES), and additionally supported by scientific literature, the principle of the NMES, and the standard indication for use for Powered Muscle Stimulators classified under 21 CFR 890.5850 (product code: IPF) per FDA Guidance Document for Powered Muscle Stimulator 510(k)s issued on June 9, 1999." |
Electrical Safety | Meets IEC 60601-1, IEC 60601-2-10, and related standards. Patient Leakage Current: Normal condition: Less than 1.0µA; Single fault condition: 3.0µA. |
Electromagnetic Compatibility (EMC) | Meets IEC 60601-1-2. |
Software Verification and Validation | Completed. Meets IEC 62304. |
Mechanical Durability | Completed. |
Lifetime Test | Completed. |
Environmental Conditions | Completed. |
Biocompatibility | New testing not run as it uses the same materials as the predicate. Predicate underwent Cytotoxicity, Sensitization, Irritation testing in accordance with ISO 10993. |
Functional Verification and Validation | Completed. |
Overall Performance & Intended Use | "The conclusions drawn from the performance tests demonstrate that the device is performing as intended, and is substantially equivalent to the predicate devices." |
2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective).
The document does not describe a new clinical "test set" in the context of typical AI/ML performance evaluation (e.g., a set of patient cases used to evaluate an algorithm's diagnostic accuracy). Instead, it refers to performance tests (electrical, mechanical, functional, software V&V, EMC, biocompatibility) conducted on the L300 Go System (the predicate device). These are engineering and system-level tests, not typically clinical trials involving patient samples.
- Sample Size for Test Set: Not applicable in the context of patient data samples for algorithm performance. The "test set" refers to the device itself being subjected to various engineering and regulatory conformance tests.
- Data Provenance (Country of Origin, Retrospective/Prospective): Not applicable for the type of testing described. The "data" here are results from engineering and biocompatibility tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience).
This question is not applicable to the type of device and submission described. This is a functional neuromuscular stimulator, not an AI/ML diagnostic or image analysis device that requires expert ground truth labeling for a test set. The validation relies on engineering and biological safety tests, and a showing of substantial equivalence to predicate devices, supported by scientific literature on the principle of NMES.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set.
Not applicable. There is no clinical test set requiring expert adjudication for ground truth, as this is not an AI/ML diagnostic device.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance.
Not applicable. This submission is for a functional electrical stimulation device, not an AI-assisted diagnostic or image interpretation tool. Therefore, an MRMC study comparing human reader performance with or without AI assistance is not relevant to this device or its regulatory pathway.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done.
Not applicable. While the device has software and algorithms for stimulus delivery and gait detection, it is a hardware medical device with specific physical and electrical outputs for therapeutic purposes. Its "performance" is in stimulating muscles as intended, not in autonomously interpreting data or making diagnostic decisions without human involvement in setting up or managing the therapy. The performance tests mentioned (functional, software V&V) implicitly cover standalone algorithm functioning within the device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.).
For the specific type of device and submission (510(k) for an expanded indication based on substantial equivalence), "ground truth" as typically understood in AI/ML validation (e.g., definitive diagnosis) is not explicitly mentioned or relied upon. The ground truth for proving substantial equivalence relies on:
- Technical Specifications Comparison: Direct comparison of electrical, mechanical, and software characteristics to predicates.
- Engineering Test Results: Pass/fail criteria for electrical safety, EMC, reliability, etc., as per recognized standards (e.g., IEC 60601 series, ISO 14971, ISO 10993).
- Prior Regulatory Clearances: The fact that the predicate devices were previously cleared by the FDA establishes their safety and effectiveness characteristics as a benchmark.
- Scientific Literature and Principle of NMES: Supporting the general safety and effectiveness of Neuromuscular Electrical Stimulation for the stated indications.
8. The sample size for the training set.
Not applicable. This document describes a traditional medical device, not an AI/ML product developed using large training datasets. The "training" for such devices typically refers to the engineering design and development process, informed by established medical principles and device standards.
9. How the ground truth for the training set was established.
Not applicable. As above, there is no AI/ML training set as such. The "ground truth" for the device's design and functionality comes from established engineering principles, international standards, and existing regulatory clearances of similar predicate devices.
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(31 days)
Bioness Inc.
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or to assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g. stroke, damage to pathways to the spinal cord). The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the foot and/or knee flexion or extension: thus, it also may improve the individual's gait.
The L300 Go System may also:
- o Facilitate muscle re-education
- o Prevent/retard disuse atrophy
- o Maintain or increase joint range of motion
o Increase local blood flow
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or to assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, damage to pathways to the spinal cord). The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the foot and/or knee flexion or extension; thus, it also may improve the individual's gait.
The L300 Go system consists of the following components:
-
- External Pulse Generator (EPG), which can be plugged into lower leg Functional Stimulation Cuff (FSC) or thigh FSC or into both cuffs. EPG contain user interface including control and indications. EPG also contains integrated motion sensors enabling detecting gait events.
-
- Lower leg FSC, including cradle for the EPG.
-
- Upper leg FSC, including cradle for the EPG.
-
- Clinician Application (CAPP), based on tablet PC. CAPP will be used by a trained clinician during configuration of the system for optimal fitting to the patient.
-
- Power supply (charger) with two USB ports and a proprietary cable to charge the EPG.
-
- L300 Go Tester.
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- Optional Control Unit that allows simple control of the EPG(s) such as selecting mode of operation (gait/training) or fine-tune the stimulation intensity for each EPG individually.
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- Optional Foot Sensor, which uses a dynamic gait tracking algorithm to detect heel events and wirelessly synchronizes stimulation.
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- Optional Mobile Application (MAPP), which can be downloaded on a smartphone and offers the same control functions as the optional Control Unit, as well as enabling the patients to retrieve and monitor their daily activity. At the time of clearance of K173682, the MAPP was only an iOS-based application. In this submission, Bioness is adding an Android-based MAPP. The software features, user interface, and wireless communication protocol of the Android version are the same as the iOS version, the only difference is the operating system.
The L300 Go System can be operated in one of the following modes:
- Gait Mode
- Training Mode ●
- . Cycle Training Mode
- . Clinician Mode
Gait Mode is used for walking, and it can be selected by the clinician and also by the patient. Training Mode is used to train muscles when patients are not walking (for example, sitting or lying down), and it can be selected by either the clinician or the patient. Cycle Training Mode is used to train muscles while the patient is using a stationary exercise bicycle, and it can be selected by either the clinician or the patient. Clinician Mode allows the clinician to apply enhanced training and is only available to the clinicians.
The provided text describes a Special 510(k) submission for the Bioness L300 Go System, primarily focused on device modifications including software changes and the addition of an Android version Mobile Application. The submission asserts that these changes do not affect the intended use or fundamental scientific technology of the device.
Here's an analysis of the acceptance criteria and study information provided:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal acceptance criteria in a quantitative table for this specific Special 510(k) submission. Instead, the submission focuses on demonstrating that the modified device maintains the safety and efficacy previously established for its predicate device (K173682) through verification and validation testing of the changes.
The reported device performance, in this context, refers to the successful completion of these tests:
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
No loss of original software/firmware functionality | Software and firmware changes subject to verification testing for original functionality; successfully passed. |
Software changes for Cyclic Training Mode function correctly | Subjected to verification and validation testing; successfully passed. |
Modified External Pulse Generator (EPG) meets Environmental Ingress Protection (IP42) requirements | EPG retested and successfully passed IP42 classification. |
New Clinician's Kit packaging withstands transportation | New packaging passed all transportation tests. |
Overall safety and effectiveness is maintained post-modification | Bioness concludes substantial equivalence to predicate. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify sample sizes used for the "verification testing" or "validation testing" mentioned for software/firmware/cyclic training mode. It also does not provide information on the provenance of data (e.g., country of origin, retrospective/prospective). These details would typically be found in more comprehensive study reports, which are not included in this FDA 510(k) summary.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This document does not describe any study involving human experts establishing ground truth for a test set. The testing described appears to be engineering or performance testing against predefined technical specifications and standards.
4. Adjudication Method for the Test Set
Not applicable, as there's no mention of a ground truth established by human experts or a test set requiring adjudication in the context of this document. The testing described is primarily technical verification and validation.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study is mentioned in this document. The device is a functional neuromuscular stimulator, not an imaging or diagnostic AI tool that would typically involve human readers interpreting cases.
6. Standalone (Algorithm Only) Performance Study
While the document describes rigorous testing of the device's software and hardware (including the algorithms within the EPG and mobile applications), it doesn't present this as a "standalone" performance study in the context of a comparative effectiveness study against a human baseline or a widely accepted clinical standard for an AI diagnostic algorithm. The aim here is to confirm the device's functional integrity after modifications.
7. Type of Ground Truth Used
The "ground truth" for the tests described appears to be:
- Technical Specifications and Requirements: For software/firmware functionality and the cyclic training mode.
- Industry Standards: For environmental ingress protection (IP42) and transportation testing.
- Predicate Device Performance: The primary "ground truth" is that the modified device should perform equally safely and effectively as the previously cleared predicate device (K173682).
8. Sample Size for the Training Set
The document does not describe any "training set" in the context of machine learning or AI models being trained. The "software and firmware changes" likely refer to updates in control logic, user interface, or functional modes, which are verified and validated rather than trained on data.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as no training set for an AI model is mentioned or implied.
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(98 days)
Bioness, Inc.
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or to assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g. stroke, damage to pathways to the spinal cord). The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the flexion or extension: thus, it also may improve the individual's gait.
The L300 Go System may also:
- Facilitate muscle re-education
- · Prevent/retard disuse atrophy
- · Maintain or increase joint range of motion
- · Increase local blood flow
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, spinal cord injury) or other disability. The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the foot and/or knee flexion or extension; thus, it also may improve the individual's gait.
The L300 Go system consists of the following components:
-
- External Pulse Generator (EPG), which can be plugged into lower leg Functional Stimulation Cuff (FSC) or thigh FSC or into both cuffs. EPG contain user interface including control and indications. EPG also contains integrated motion sensors enabling detecting gait events.
-
- Lower leg FSC, including cradle for the EPG.
-
- Upper leg FSC, including cradle for the EPG.
-
- Clinician Application (CAPP), based on tablet PC. CAPP will be used by a trained clinician during configuration of the system for optimal fitting to the patient.
-
- Power supply (charger) with two USB ports and a proprietary cable to charge the EPG.
-
- L300 Go Tester.
-
- Optional Control Unit that allows simple control of the EPG(s).
-
- Optional Foot Sensor, which uses a dynamic gait tracking algorithm to detect heel events and wirelessly synchronizes stimulation.
-
- Optional Mobile Application (MAPP), based on the SmartPhone platform enabling the patients to wirelessly retrieve and monitor their daily activity. At the time of clearance of K162407, the MAPP did not include any control feature, but control features like those of the Optional Control Unit have been added to the MAPP and are part of this submission.
This document is a 510(k) summary for the Bioness L300 Go System, focusing on modifications made to a previously cleared device (K162407). It does not contain acceptance criteria for device performance or a study demonstrating the device meets such criteria in terms of clinical effectiveness. Instead, it describes non-clinical testing performed to demonstrate that the modifications to the device do not alter its substantial equivalence to the predicate device.
Here's an analysis based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not provide a table of acceptance criteria for clinical performance or reported device performance in terms of efficacy metrics (e.g., gait improvement percentages, dorsiflexion angles). It focuses on non-clinical testing to ensure that modifications to the device (e.g., changes in material, software updates) do not negatively impact its safety and functionality compared to the predicate device.
For the non-clinical tests mentioned, the "acceptance criteria" can be inferred as "successfully passed the testing," indicating that the device's performance post-modification remained within acceptable limits for the specific tests conducted.
Test Type | Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|---|
Environmental Ingress Protection (CU) | Successfully passed the testing | The modified CU successfully passed the Environmental Ingress Protection testing. |
Mechanical Vibration and Shock (EPG) | Successfully passed the testing | The modified EPG successfully passed the Mechanical Vibration and Shock testing. |
Packaging and Shipping Tests (ASTM D5276-98, Schedule A, Level III) | All tests passed | All packaging passed all tests. |
Software Verification Testing (MAPP) | No loss of original functionality | Software changes were subjected to verification testing to include regression testing to ensure no loss of original functionality. |
Software Validation Testing (New MAPP Functions) | New functions perform as intended | New functions were subjected to both verification testing (including regression testing) and validation testing. |
Electrical Safety and Electromagnetic Compatibility | Maintained compliance from predicate | Evaluated for applicability to the design modifications. (Implies continued compliance based on predicate) |
2. Sample Size Used for the Test Set and Data Provenance:
The document describes non-clinical engineering and software testing. It does not refer to a "test set" in the context of clinical data or patient samples.
- Sample Size for non-clinical tests: Not explicitly stated as a number of units, but common for such tests to involve one or a small number of physical units for destructive or environmental testing.
- Data Provenance: The testing was conducted internally by Bioness or by Minnetronix Inc. (a Bioness development vendor), indicating it is internal, likely prospective, engineering bench testing. There is no mention of country of origin regarding clinical data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts:
This information is not applicable. The document describes non-clinical hardware and software testing, not clinical studies requiring expert ground truth for patient outcomes.
4. Adjudication Method for the Test Set:
This information is not applicable. Adjudication methods (e.g., 2+1) are typically used in clinical studies for interpreting ambiguous results or establishing ground truth from expert readings. The tests described are engineering and software tests with defined pass/fail criteria.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
No MRMC study was conducted or is mentioned in this document. The submission focuses on demonstrating substantial equivalence for minor device modifications and software upgrades through non-clinical testing, not on clinical effectiveness studies.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
This concept is less applicable to a functional neuromuscular stimulator that inherently requires human interaction and application by a clinician/user. The document describes software verification and validation, including for the Mobile Application (MAPP) which has user interaction, but not a "standalone algorithm" performance in the sense of an AI diagnostic tool.
7. Type of Ground Truth Used:
For the non-clinical tests, the "ground truth" is typically defined by engineering specifications, validated test methods, and industry standards (e.g., ASTM standards for packaging, internal design requirements for software functionality). Not pathology, outcomes data, or expert consensus in a clinical sense.
8. Sample Size for the Training Set:
This information is not applicable. The text describes verification and validation of modified hardware and software, not the development of a machine learning model that would require a "training set."
9. How the Ground Truth for the Training Set Was Established:
This information is not applicable, as there is no "training set" for a machine learning model mentioned.
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(151 days)
BIONESS INC.
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, damage to pathways to the spinal cord). The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the flexion or extension: thus, it also may improve the individual's gait.
The L300 Go System may also:
- Facilitate muscle re-education
- · Prevent/retard disuse atrophy
- · Maintain or increase joint range of motion
- · Increase local blood flow
The L300 Go System is intended to provide ankle dorsiflexion in adult and pediatric individuals with foot drop and/or assist knee flexion or extension in adult individuals with muscle weakness related to upper motor neuron disease/injury (e.g., stroke, spinal cord injury) or other disability. The L300 Go System electrically stimulates muscles in the affected leg to provide ankle dorsiflexion of the foot and/or knee flexion or extension; thus, it also may improve the individual's qait.
The L300 Go System consists of:
-
- One or two Functional Stimulation Cuffs (L300 Lower Leg and Thigh), that include surface electrodes.
-
- External Pulse Generator (EPG) for the lower leg and EPG for thigh. Both EPG's deliver stimulation to their respective cuffs, and have user interface, including visual, audio, and tactile feedback. Lower EPG can use motion sensor based algorithm to detect heel events.
-
- A Control Unit that allows simple wireless remote control of the EPG's while displaying real-time information regarding the system's status.
-
- An optional Gait Sensor, which uses a dynamic gait tracking algorithm to detect heel events and wirelessly synchronizes stimulation.
-
- A Clinician's Programming System with software, which is used for system programming by a trained clinician during configuration of the system for optimal fitting to the patient.
-
- A power supply with two USB outputs and a proprietary cable to charge the EPG.
This document is a 510(k) Summary for the Bioness L300 Go System, a medical device intended to provide ankle dorsiflexion and/or assist knee flexion/extension. The primary purpose of this document is to demonstrate substantial equivalence to previously cleared predicate devices, not to present a comprehensive study proving device performance against acceptance criteria. Therefore, most of the requested information regarding study details, sample sizes, expert involvement, and ground truth establishment is not available in the provided text.
Based on the available information, here's what can be extracted:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" for the L300 Go System in terms of performance metrics like accuracy, sensitivity, or specificity. Instead, it demonstrates an equivalence to predicate devices in various technical specifications and functional aspects. The tables (Table 1.0, Table 2a, Table 2b) primarily compare the technical output specifications and basic unit characteristics of the L300 Go System with its predicate devices.
Feature / Criteria (Derived from comparison to predicates) | L300 Go System Reported Performance |
---|---|
Output Waveform | Biphasic Symmetrical / Asymmetrical |
Shape | Rectangular |
Max Output Voltage (@500Ω) | Lower leg: 50V, Thigh: 50V |
Max Output Current (@500Ω) | Lower leg: 100mA, Thigh: 100mA |
Pulse Width (Biphasic Symmetrical) | 100, 150, 200, 250, 300 µs |
Frequency | 10-45 Hz |
Net Charge per pulse (@500Ω) | 0 µC (using inverted balanced phases) |
Max Phase Charge (@500Ω) | Lower leg: 30 µC, Thigh: 30 µC |
Max Current Density (@500Ω) | Varies by cuff size (e.g., Lower leg small cuff: 1.63 mA/cm² (rms)) |
Max Power Density (@500Ω) | Varies by cuff size (e.g., Lower leg small cuff: 13.4 mW/cm²) |
Burst Mode Functionality | Yes (heel off/contact triggered, timer/complementary event terminated) |
ON Time (Training mode) | 4-20 sec |
OFF Time (Training mode) | 4-20 sec |
Compliance with Standards | IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10, FCC part 15 subpart C and B1, 21 CFR 898 (Yes) |
Wireless Communication Technology | Industry-standard Bluetooth (low energy) |
User Interface | Expanded User Interface (via Remote Control or Stimulator) |
Clinician Programmer | Tablet/PC-based Clinician Programmer |
Number of Stimulation Channels | One or two (lower leg), one (thigh) |
Tilt Sensor for Gait Trigger | Yes (similar to WalkAide) |
The document asserts that the L300 Go System "does not introduce any new issues of safety or efficacy" relative to its predicate devices, implying that its performance is equivalent in these aspects.
2. Sample size used for the test set and the data provenance
Not provided. The document outlines a substantial equivalence argument rather than a dedicated performance study with a test set.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not provided. There is no mention of a test set or ground truth established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not provided. There is no mention of an adjudication method.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This device is an external functional neuromuscular stimulator, not an AI-assisted diagnostic or imaging device that would typically involve human "readers" or an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This question generally applies to AI-driven diagnostic systems. The L300 Go System includes algorithms (e.g., motion sensor-based algorithm to detect heel events, dynamic gait tracking algorithm), but the device itself is a functional electrical stimulator, not an algorithm-only device. Its functionality inherently involves interaction with the human body to achieve a therapeutic effect. The document focuses on the technical specifications and equivalency to previously cleared devices.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
Not provided. The document focuses on technical specifications and functional equivalence rather than clinical ground truth for a diagnostic outcome.
8. The sample size for the training set
Not applicable. This device is not an AI/ML model that would be "trained" in the traditional sense on a dataset. The document discusses "software" and "firmware" but not a machine learning training process.
9. How the ground truth for the training set was established
Not applicable. See point 8.
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(175 days)
BIONESS, INC.
The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.
Not Found
This FDA Premarket Notification (510(k)) K142432 for the StimRouter Neuromodulation System does not contain the detailed clinical study information requested.
Here's why and what's missing:
-
Nature of the Document: This is a 510(k) clearance letter. It states that the device is "substantially equivalent" to legally marketed predicate devices. This regulatory pathway typically relies heavily on demonstrating similarity to existing devices through design, materials, and often, non-clinical (bench and animal) testing, rather than extensive new human clinical trials to prove efficacy against specific acceptance criteria in the same way a PMA (Pre-Market Approval) would.
-
Focus of the Letter: The letter focuses on the FDA's regulatory decision and administrative details (registration, labeling, reporting, etc.). It does not include the detailed study report or clinical data that the manufacturer would have submitted.
Therefore, I cannot extract the following information from the provided text:
- 1. A table of acceptance criteria and the reported device performance: This information would be in a clinical study report, which is not present here.
- 2. Sample sized used for the test set and the data provenance: Not available in this document.
- 3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not available.
- 4. Adjudication method for the test set: Not available.
- 5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance: This device is a neuromodulation system for pain, not an AI-powered diagnostic imaging tool. Thus, an MRMC study is not relevant and certainly not included.
- 6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Again, this is a directly implantable neuromodulation device, not an AI algorithm.
- 7. The type of ground truth used: Not applicable in the context of demonstrating substantial equivalence for a neuromodulation device in a 510(k). The "ground truth" would be the clinical outcome (pain reduction), but the document does not detail studies proving this with specific criteria.
- 8. The sample size for the training set: Not applicable as this is not an AI/machine learning device that uses training sets in the conventional sense.
- 9. How the ground truth for the training set was established: Not applicable.
What is available from the document:
- Device Name: StimRouter Neuromodulation System
- Indications for Use: Pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). Not intended to treat pain in the craniofacial region.
- Regulatory Class: Class II
- Product Code: GZF
To find the kind of detailed study information you're asking for, you would generally need to look for a clinical study report (CSR), a publication in a peer-reviewed journal, or a more detailed FDA document like a PMA review memo, which contains more in-depth data for devices requiring higher evidence. A 510(k) clearance letter itself does not provide this level of detail.
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(159 days)
BIONESS, INC.
The NESS H200® Wireless Hand Rehabilitation System is an electrical stimulation device indicated for the following uses:
Functional Electrical Stimulation (FES):
- Improvement of hand function and active range of motion in patients with hemiplegia due to stroke or upper limb paralysis due to C5 spinal cord injury
NeuroMuscular Electrical Stimulation (NMES): - Maintenance and/or increase of range of motion -
- Prevention and/or retardation of disuse atrophy l
- Increase of local blood circulation -
- Reduction of muscle spasm —
- Muscle re-education |
The Intelli-Connect is an optional accessory device used exclusively with the H200 Wireless System. The Intelli-Connect is used to trigger the H200 Wireless Orthosis through simple jaw movements.
The NESS H200 System consists of the following components:
- Functional Stimulation (FS) Orthosis with a Radio Frequency (RF) Stim Unit .
- Control Unit .
- . Intelli-Connect triggering device optional accessory, consisting of an earpiece, a charger and connecting cable
The Intelli-Connect Earpiece triggering device is fitted over the ear and detects clicks of the teeth to wirelessly trigger the stimulation unit of the H200 Wireless orthosis. Software built into the Intelli-Connect earpiece is designed to register and work exclusively with the patient's orthosis. The Earpiece is rechargeable with a lithium-polymer battery. It is FCC identified and meets part 15 of the FCC regulations. Once the earpiece is turned on, Intelli-Connect will trigger stimulation when teeth are clicked together.
The provided document is a 510(k) Summary for the Bioness NESS H200 Wireless Hand Rehabilitation System with an optional Intelli-Connect Earpiece Triggering Device. It details various performance tests conducted to demonstrate the device's compliance and substantial equivalence to a predicate device.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and the Reported Device Performance
Purpose (Acceptance Criteria) | Testing (Method to meet criteria) | Reported Performance (Results) |
---|---|---|
Verify that the Intelli-Connect complies with 60601-1 general requirements for basic safety and essential performance | Power input, leakage current, dielectric strength, mechanical strength, physical stability, excessive temperature, humidity, ingress of liquids, cleaning, mechanical abuse, stress relief | Pass |
Verify that Intelli-Connect system complies with EMC requirements of 60601-1-2 | Radiated emissions, AC mains, electrostatic discharge, immunity to surge, RF field immunity, magnetic field immunity, interruptions immunity | Pass |
Verify that the battery satisfies IEC 62133:2202 | Vibration, temperature cycling, external short circuit, free fall, crash hazard | Pass |
Verify conformance with FCC Part 15 Class B | Field strength, bandwidth, spurious emissions, AC mains emissions, antenna requirement, | Pass |
Verify conformance to biocompatibility (ISO 10993) requirements | Sensitization, cytotoxicity, irritation | Pass |
Verify software meets requirements | Hardware verification, module verification, internal peripherals, settings, accelerometers, initialization, watch dog timer, charging, battery capacity, registration, LED behavior, state machine, trigger commands | Pass |
Verify user specifications are met | Weight, charge access, insertion, donning and doffing, handling, talking, with glasses, consistent detection, roll and pitch, fit, cleaning | Pass |
2. Sample size used for the test set and the data provenance
The document does not specify the sample size for the test sets used in any of the performance verification tests (e.g., how many units were tested for electrical safety, EMC, battery, software, or user specifications). The provenance of the data (country of origin, retrospective or prospective) is also not mentioned. These tests appear to be bench or engineering tests rather than clinical studies with human participants.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided in the document. The tests described are engineering and safety standard compliance tests, not clinical performance evaluations that would typically involve expert-established ground truth.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
The document does not describe any adjudication method for the test sets. Given the nature of the tests (compliance with standards), adjudication by multiple experts is not typically applicable.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
An MRMC comparative effectiveness study was not done. The device is a physical rehabilitation system accessory (a hands-free trigger), not an AI-assisted diagnostic or interpretive tool that would involve "human readers" or AI assistance in that sense.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This concept is not directly applicable to the Intelli-Connect earpiece. The Intelli-Connect is designed to work in conjunction with the H200 Wireless System to trigger functional stimulation based on jaw movements (teeth clicks). Its standalone performance relates to its ability to reliably detect these clicks and wirelessly transmit the trigger command, which is covered by the mentioned software and user specification verification tests. There isn't an "algorithm only" performance that would be separate from its intended human-in-the-loop use (as a trigger for a patient's rehabilitation).
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the engineering and safety tests, the "ground truth" is defined by the technical specifications and requirements of the referenced standards (e.g., IEC 60601-1, FCC Part 15, IEC 62133, ISO 10993) and the user specifications defined by the manufacturer. These are objective engineering criteria rather than clinical ground truth established by experts or pathology.
8. The sample size for the training set
The document does not mention any training set. This is a medical device accessory and its performance is validated through engineering, regulatory, and user specification testing, not typically through machine learning model training.
9. How the ground truth for the training set was established
Not applicable, as there is no mention of a training set.
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