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510(k) Data Aggregation

    K Number
    K192756
    Date Cleared
    2020-02-24

    (147 days)

    Product Code
    Regulation Number
    876.5860
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Aquadex FlexFlow® System is indicated for:

    Continuous ultrafiltration therapy for temporary (up to 8 hours) or extended (longer than 8 hours in patients who require hospitalization) use in adult and pediatic patients weighing 20 kilograms or more whose fluid overload is unresponsive to medical management, including diuretics.

    All treatments must be administered by a healthcare provider, within an outpatient clinical setting, under physician prescription, both of whom having received training in extracorporeal therapies.

    Device Description

    The Aquadex FlexFlow system comprises the following components:

    • . Aquadex FlexFlow console, microprocessor-controlled
    • . Blood Circuit Set with integral hemofilter, disposable
    • . Venous access catheter

    The Aquadex FlexFlow console includes a blood pump, ultrafiltrate pump, control panel, weight scale, air detector, blood leak detector, electrical connectors for the circuit pressure sensors, and mechanical interfaces that hold the circuit in place. The console controls the rate at which the blood pump removes blood from the patient, and the clinician sets the maximum rate at which the ultrafiltrate pump extracts ultrafiltrate from the blood. Patient access is obtained either peripherally or through the central venous veins. Blood is withdrawn from a vein and passes through a withdrawal pressure sensor before entering the blood pump tubing loop. The rotating rollers propel the blood through the the air detector, then into the hemofilter before being returned to the patient. The console screen displays information to help the clinician prime, set up, and operate the system. All system alarm limits are set by the console.

    The Aquadex FlexFlow blood circuit is a preassembled, sterile (EtO), single-patient use set. There are two models of the blood circuit: A06162 and A06163. The blood circuit set A06162 consists of a filter, tubing, pressure sensors, connectors, pinch clamps, a priming spike, an ultrafiltrate connecting bag and data key. The blood circuit set A06163 has the same components, except that it also has an inline blood chamber for use in monitoring the patient's hematocrit (Hct) during therapy.

    CHF Solutions Inc. offers a dual lumen extended length catheter (dELC) for use with the Aquadex FlexFlow System. The catheter is a peripheral venous access device with stainless steel coil reinforcement. The venous access catheter was not reviewed in K192756 as it was already cleared for safe and effective use under K041791 with no changes since the original clearance affecting its safety and effectiveness.

    AI/ML Overview

    The provided text describes acceptance criteria and the study conducted to prove the device, the Aquadex FlexFlow System 2.0, meets these criteria.

    1. Table of Acceptance Criteria and Reported Device Performance

    Device: Aquadex FlexFlow System 2.0

    Acceptance CriteriaReported Device Performance
    Fluid Removal AccuracyMet the design specifications and remained accurate within ±10% when comparing the displayed and actual ultrafiltration amount. Statistically comparable to the PrismaFlex System across all test scenarios.
    Treatment Course Survival Rate100% (No patient deaths during therapy with Aquadex).
    Hospital Survival Rate71% (Eight patients died after therapy but prior to hospital discharge, none related to the device).
    Complications Associated with Treatment InitiationNo complications reported.
    Complications During TherapyInfrequent, occurring in 11 cases (12% of circuits). Most common were clot in the filter and hypotension.
    Serious Adverse Events or Device-Related Adverse EventsNo patient experienced a serious adverse event or device-related adverse event.
    Design Specifications (General)Met all acceptance criteria.
    BiocompatibilityMet ISO 10993 requirements.
    Electrical SafetyMet IEC 60601 standard.
    Electromagnetic CompatibilityMet IEC 60601-1-2 standard.
    Essential PerformanceMet IEC 60601-2-16 requirements.
    Software Verification and ValidationMet FDA's "Guidance for the Content of Premarket Submission for Software Contained in Medical Device's".
    Performance Testing (General)Met ISO 8637-1.
    Human Factors TestingMet IEC 62366-1, 62366-2 and FDA's Guidance "Applying Human Factors and Usability Engineering to Optimize Medical Device Design."

    2. Sample Size and Data Provenance for the Test Set

    The reported clinical data for the clarified indication for use (which seems to function as the "test set" for real-world performance) comes from:

    • Sample Size: 93 Aquadex blood circuits were used on 26 pediatric patients (21 years or younger) weighing 20 kilograms or more from 28 hospitalizations.
    • Data Provenance: This was a retrospective study conducted in three centers (countries not specified, but likely within the US given FDA submission). The study was performed by investigators independent of the manufacturer.

    For the bench performance testing comparing the Aquadex systems and Prismaflex, the "test set" details are not explicitly given as a patient count but involved "all three systems" being tested "at the same therapy settings" to derive a direct comparison of fluid removal accuracies. This implies a controlled laboratory environment rather than patient data for this specific comparison.

    3. Number of Experts and Qualifications for Ground Truth for the Test Set

    For the retrospective clinical study:

    • The text does not explicitly state the number of experts used to establish ground truth or their specific qualifications (e.g., radiologist with 10 years of experience).
    • However, it does mention that "All treatments must be administered by a healthcare provider, within an outpatient clinical setting, under physician prescription, both of whom having received training in extracorporeal therapies." This implies that the initial assessment and treatment decisions were made by qualified healthcare professionals and physicians. The independent investigators who analyzed the retrospective data would also be experts in their field.

    4. Adjudication Method for the Test Set

    The adjudication method is not explicitly stated in the provided text. For the retrospective clinical study data, it's implied that the clinical outcomes were observed and reported, but a formal adjudication process (like 2+1 or 3+1 for discrepancies) by a panel of experts is not described.

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

    No MRMC comparative effectiveness study was done. The device is a physical medical device (ultrafiltration system), not an AI-powered diagnostic tool that assists human readers. Therefore, the concept of "how much human readers improve with AI vs without AI assistance" does not apply here.

    6. Standalone (Algorithm Only) Performance

    Not applicable. The Aquadex FlexFlow System 2.0 is a medical device for ultrafiltration therapy, not an algorithm. Its performance is evaluated through its physical function, accuracy, and clinical outcomes, not as an "algorithm only" product. Bench testing was performed on the device itself, not a separate algorithm.

    7. Type of Ground Truth Used

    • For the bench performance testing (fluid removal accuracy), the ground truth was based on measured actual ultrafiltration amount in a controlled laboratory setting.
    • For the retrospective clinical study, the ground truth was based on clinical outcomes data (treatment course survival, hospital survival, complications, adverse events) as observed and recorded by healthcare providers during routine patient care.

    8. Sample Size for the Training Set

    The document does not mention a training set as this product is a physical medical device and not an AI/ML algorithm that requires training data. The study primarily focuses on verifying the device's performance against specifications and clinical safety/effectiveness.

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

    Not applicable, as no training set (in the context of AI/ML) is mentioned or implied.

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