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510(k) Data Aggregation
(265 days)
The eNeura Inc. SpringTMS® is indicated for the acute and prophylactic treatment of migraine headache.
The SpringTMS® is a portable, hand-held device that is designed and intended to deliver a brief single pulse of magnetic energy at 0.9 Tesla to the back of the head to induce an electrical current in a portion of the brain called the occipital cortex to stop or lessen the effects of migraine headaches. Since a single pulse of magnetic stimulation is emitted, this method of stimulation is called single pulse transcranial magnetic stimulation or sTMS. The SpringTMS is indicated for the acute treatment and prevention of migraine headache. The device is designed for patient use where treatments are self-administered and can be delivered in a variety of settings including the home or office. The device is intended for prescription use only.
The provided text describes a 510(k) premarket notification for the eNeura Inc. SpringTMS® device. This device is a transcranial magnetic stimulator indicated for the acute and prophylactic treatment of migraine headaches.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria | Reported Device Performance |
---|---|
Primary Effectiveness Endpoint: Mean reduction in headache days over a 28-day period at 12±1 weeks. | FAS: Mean reduction of 2.8 days (from a baseline mean of 9.1 days). Statistically significant (P2%) included headache (2.30%), scalp discomfort (2.30%), tingling (3.23%), lightheadedness (3.69%), discomfort from noise (2.30%), dizziness (2.77%), ringing in ears (3.23%), and worsened headache pain (2.30%). |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set:
- Safety Data Set: 217 subjects (assigned Spring TMS devices).
- Full-Analysis Data Set (FAS): 132 subjects (met protocol requirements based on headache day definition).
- Completed Cases (CC): 117 subjects (finished treatment and completed baseline and Month 3 diaries).
- Per Protocol (PP) Data Set: 95 subjects (complied with protocol instructions regarding device use).
- Data Provenance: The study was a prospective, multicenter, observational, clinical study. The country of origin is not explicitly stated in the provided text, but the applicant's address (Sunnyvale, CA, USA) suggests it was conducted in the USA.
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 is a clinical efficacy study for a medical device, not an image-based diagnostic AI. Therefore, there are no "experts" in the typical sense establishing a ground truth from images. The "ground truth" for migraine efficacy is based on patient-reported outcomes via headache diaries and questionnaires, confirmed through established criteria for migraine diagnosis and headache day definitions. The study design (observational, multi-center) implies clinical investigators were involved in patient enrollment and oversight, but their specific qualifications beyond being clinicians involved in migraine care are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Adjudication methods like 2+1 or 3+1 are typically used for establishing ground truth in image analysis where multiple readers interpret data. This is not applicable here as the primary "ground truth" for effectiveness is derived from patient self-reporting (headache diaries) and safety is assessed through adverse event reporting, which are intrinsically different from image interpretation. The study was a "prospective, non-randomized, single arm, multi-center observational study," indicating no external adjudication process for reconciling different expert interpretations.
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
No, an MRMC comparative effectiveness study was not done. This study evaluates a medical device (Transcranial Magnetic Stimulator) directly, not an AI assisting human readers in interpreting data. Therefore, the concept of "human readers improve with AI vs without AI assistance" is not relevant to this device or study design.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This refers to a medical device, not an algorithm. The device, SpringTMS®, operates as a standalone therapy administered by the patient for the treatment of migraine. It does not involve an algorithm providing diagnoses or interpretations. The study evaluates the device's performance as a standalone treatment.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The ground truth for effectiveness was established primarily through outcomes data, specifically:
- Patient-reported headache diaries: Defining "headache days" as ≥4 hours of headache pain which at any time reaches moderate or severe intensity. This is the basis for the primary effectiveness endpoint (mean reduction in headache days).
- Patient-reported medication use: For the secondary effectiveness endpoint regarding reduction in medication use.
- Patient-reported questionnaires: Like the HIT6 impact questionnaire for another secondary effectiveness endpoint.
- Adverse event reporting: For the primary safety endpoint.
8. The sample size for the training set
This study is a clinical trial for a medical device, not a machine learning model. Therefore, there is no "training set" in the context of AI/ML. The provided sample sizes (217 for safety, 132-95 for effectiveness) represent the sizes of the cohorts included in the clinical trial itself.
9. How the ground truth for the training set was established
As there is no training set for an AI/ML model, this question is not applicable. The device's "training" or development would have been based on established scientific principles of transcranial magnetic stimulation and previous research into its effect on migraine. The clinical study described here serves to validate the device's safety and effectiveness in a real-world patient population.
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(68 days)
The eNeura® sTMS mini is indicated for the acute treatment of pain associated with migraine headache with aura.
The sTMS mini is a portable, hand-held device that delivers a brief single pulse of magnetic energy at 0.9 Tesla to the back of the head to induce an electrical current in a portion of the brain, called the occipital cortex, to stop or lessen the effects of migraine headaches. Since a single pulse of magnetic stimulation is emitted, this method of stimulation is called single pulse transcranial magnetic stimulation or sTMS. The sTMS mini is indicated for the acute treatment of pain associated with migraine headache with aura. The device is designed for patient use where treatments are self-administered and can be delivered in a variety of settings including the home or office. The device is intended for prescription use only.
This document describes the 510(k) premarket notification for the eNeura® sTMS Mini, a transcranial magnetic stimulator for headache. The submission focuses on demonstrating substantial equivalence to a predicate device, SpringTMS® (K140094).
Here's an analysis of the provided text in relation to your request:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not explicitly state "acceptance criteria" in a quantitative manner for clinical efficacy. Instead, it focuses on demonstrating technological equivalence to a predicate device through non-clinical performance testing. The "results supporting substantial equivalence" serve as the de facto "reported device performance" against the implicitly accepted "criteria" of being equivalent to the predicate.
Testing Type | Test Description | Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|---|---|
Performance Bench Testing: Magnetic Pulse Characteristics | Magnetic Pulse Characteristics vs. Time | Same specification for magnetic pulse shape as predicate; within specification. | Both devices have the same specification for magnetic pulse shape and both devices tested within specification. No new issues of safety or efficacy have been raised. The measured rate of change of the magnetic field is substantially equivalent. |
Performance Bench Testing: Magnetic Pulse Field Map | Magnetic Pulse Field Map | Substantially equivalent to predicate. | No new issues of safety or efficacy have been raised. The Magnetic Pulse Field Maps for the sTMS mini and the predicate device are substantially equivalent. |
Performance Bench Testing: Location of 5 Gauss Line | Location of 5 Gauss Line | Substantially equivalent to predicate. | No new issues of safety or efficacy have been raised. The location of the 5 Gauss line for the sTMS mini and the predicate device are substantially equivalent. |
Software Verification Validation Testing | sTMS mini Software Testing | Meet requirements of Software Requirements Specification (SRS); no new safety/efficacy issues. | The sTMS mini software was tested against requirements of the Software Requirements Specification (SRS) and no new issues of safety or efficacy have been raised. The sTMS mini software requirements specify device operations that result in the delivery of a magnetic pulse that is substantially equivalent to the magnetic pulse of the predicate device. |
Electromagnetic Compatibility and Electrical Safety | Testing in accordance with IEC 60601-1-1 & -1-2 | Meet all acceptance criteria of IEC 60601-1-1 and IEC 60601-1-2. | The sTMS mini and the predicate device met all acceptance criteria. No new issues of safety or efficacy have been raised. Therefore, the sTMS mini is substantially equivalent to the predicate. |
2. Sample Size Used for the Test Set and Data Provenance:
The document describes non-clinical performance testing (bench testing) and software verification/validation. It does not mention any clinical studies, test sets involving human subjects, or data provenance (country of origin, retrospective/prospective). The assessment is based on physical and software characteristics compared to the predicate device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:
Since no clinical test set with human subjects is described, there is no mention of experts establishing ground truth. The "ground truth" for the non-clinical tests is based on established engineering specifications, safety standards (e.g., IEC 60601 series), and the characteristics of the predicate device.
4. Adjudication Method for the Test Set:
Not applicable, as no clinical test set is described.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
No, an MRMC comparative effectiveness study was not done or mentioned in this document. This submission focuses on technological equivalence, not clinical efficacy or comparative effectiveness with human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
This device is a physical medical device (Transcranial Magnetic Stimulator) and not an algorithm or AI system in the typical sense that would have "standalone performance" evaluated as an algorithm. Its performance is evaluated through physical and software testing.
7. The Type of Ground Truth Used:
For the non-clinical performance testing, the "ground truth" is based on:
- Engineering specifications for magnetic pulse characteristics (e.g., 0.9 Tesla Peak @ 180 µs, 4 mA/cm² induced at 1 cm).
- International standards for safety and electromagnetic compatibility (IEC 60601-1-1, IEC 60601-1-2).
- Software requirements specifications (SRS).
- Characteristics of the legally marketed predicate device (SpringTMS®), which serves as the benchmark for "substantial equivalence."
8. The Sample Size for the Training Set:
Not applicable. This document does not describe the development or testing of an AI algorithm or model that would require a "training set." The device is a hardware product with associated software.
9. How the Ground Truth for the Training Set Was Established:
Not applicable, as no training set for an AI algorithm is mentioned.
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