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510(k) Data Aggregation
(231 days)
InControl Medical, LLC
ApexMV is a non-implantable muscle stimulator intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of stress, urge, or mixed urinary incontinence in adult women.
ApexMV is a non-implantable muscle stimulator intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of stress, urge, or mixed urinary incontinence and/or fecal incontinence in adult women.
The ApexMV device is a non-implantable muscle stimulator intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of stress, urge, or mixed urinary incontinence and/or fecal incontinence in adult women for Over-the-Counter use. The ApexMV device is to be distributed as a kit that contains the following items:
- · 1 ApexMV device
- 1 4 pack of AA batteries
- · 1 2 oz. tube of InControl Medical Electrode Gel**
- 1 ApexMV IFU/ User Manual
- · 1 ApexMV Quick Reference Card
- 1 Screw driver
- 1 Travel Bag
- 1 Animation Video
The ApexMV device consists of a hand held control unit with bio-feedback and inflation pump attached to a customizable inflatable probe via flexible tubing. The customizable inflatable probe is inserted vaginally or rectally and manually inflated by the end user to ensure a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is also used to improve the ability of the muscles to hold a contraction for an extended period of time for the treatment of stress, urge, or mixed urinary and/or fecal incontinence in adult women. During a session, high and low frequency stimulation is delivered by the device. The higher frequency stimulation is delivered to specific muscles to encourage their contraction, strengthening the muscles and helping the end user recognize which muscles to activate during self-directed contractions. Lower frequency stimulation calms the detrusor muscle, decreasing symptoms of urgency. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls.
This document describes the regulatory submission for the ApexMV device, which is a non-implantable muscle stimulator for treating urinary and/or fecal incontinence in adult women.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" in the format of specific thresholds for performance metrics. Instead, the "acceptance criteria" are implied by the successful completion of various tests and the determination of substantial equivalence to previously cleared predicate devices. The reported "device performance" is primarily qualitative, stating that the device "successfully passed all of this testing" and is "safe and effective."
Below is a table summarizing the tests performed and the reported outcomes, which implicitly serve as the device meeting the acceptance criteria for regulatory clearance:
Acceptance Criteria (Implied by Test Completion) | Reported Device Performance (Qualitative) |
---|---|
Software Verification and Validation Testing | |
(Adherence to FDA Guidance for Software in Medical Devices for "moderate" level of concern) | Documentation was provided as recommended. |
The software met the requirements for a "moderate" level of concern. | |
Testing data found in Appendix 4 – Risk Management File. | |
Electrical Safety and Electromagnetic Compatibility (EMC) Testing | |
(Compliance with IEC 60601-1, IEC 60601-2-10, IEC 60601-1-11, and IEC 60601-1-2 standards) | The ApexMV device complies with all specified IEC standards for safety and EMC. |
Testing data found in Appendix 7 – SGS EMC and Electrical Safety. | |
Biocompatibility Testing | |
(Compliance with ISO 10993-1 for tissue-contacting parts |
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(72 days)
InControl Medical, LLC
ApexM is a non-implanted muscle stimulator designed to treat stress, urge and/or mixed urinary incontinence in women. It applies stimulation to the pelvic floor muscles and surrounding structures to improve strength and support.
ApexM is a hand-held, home-use device designed to treat female urinary incontinence. The device includes an inflatable probe. The inflatable probe is inserted into the vagina and manually inflated by the end user to ensure a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is used to improve the ability of muscles to hold a contraction for an extended period of time and is a treatment for urinary incontinence. During a session, high and low frequency stimulation is delivered by the device. The higher frequency stimulation is delivered to specific muscles to encourage their contraction, strengthening the muscles and helping the end user recognize which muscles to activate during self-directed contractions. Lower frequency stimulation calms the detrusor muscle, decreasing symptoms of urgency. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls.
This document, K150183 for the ApexM device, focuses on demonstrating substantial equivalence to predicate devices rather than proving performance against specific acceptance criteria through a dedicated study for the new device itself. The information provided is primarily a comparison between the new device (ApexM) and two predicate devices (InTone and Apex) to show that the ApexM is equally safe and effective.
Therefore, many of the requested elements for acceptance criteria and a study proving the device meets them cannot be directly extracted as if a new, standalone performance study was conducted for ApexM with specific quantitative acceptance criteria. Instead, the document relies on comparing features and prior testing of predicate devices.
Here's an attempt to answer your questions based on the provided text, while acknowledging its limitations:
1. A table of acceptance criteria and the reported device performance
Since this is a substantial equivalence submission, explicit "acceptance criteria" for the new device's performance (e.g., "device must achieve X% sensitivity") are not stated in the provided text. The "reported device performance" is essentially that its features and technical specifications are substantially equivalent to the predicates, which have presumably met their own performance and safety requirements.
We can, however, extrapolate the implicit "acceptance criteria" as being "identical or substantially equivalent to the predicate device Apex (K141158) or InTone (K110179) without introducing new safety or effectiveness concerns." The "reported device performance" is that it meets this equivalence across various characteristics.
Feature/Function | Implicit Acceptance Criterion (based on predicate) | Reported Device Performance (ApexM) |
---|---|---|
Intended Use | Treat female urinary incontinence (stress, urge, mixed, or a combination thereof) | Treat stress, urge and/or mixed urinary incontinence in women. Identical to Apex (K141158) in its application of stimulation, but broader in the types of incontinence treated compared to Apex alone. Substantially equivalent. |
Primary Function | Delivery of electrical stimulation | Delivery of electrical stimulation. Identical. |
Warnings/Precautions | Identical to Apex (K141158) | Identical to Apex. No new safety concerns. |
Contraindications | Identical to Apex (K141158) | Identical to Apex. No new safety concerns. |
Labeling Summary (User Manual) | User manual based on predicate Apex, adequate for safe and effective use. | User manual based on predicate Apex, which was validated through Human Factors/Usability testing. Substantially equivalent. |
Environmental Specifications | For indoor use only. | For indoor use only. Identical. |
Power Source | 4 AAA Alkaline battery (identical to Apex) | 4 AAA Alkaline battery. Identical to Apex, leveraging ease of use and acquisition for end user. |
Method of line current isolation | N/A (battery) | N/A (battery). Identical. |
Patient leakage current | N/A (battery) | N/A (battery). Identical. |
Number of output modes/channels | 1 mode, 1 channel. | 1 mode, 1 channel. Identical. |
Regulated current or voltage? | Regulated voltage. | Regulated voltage. Identical. |
Firmware controlled? | Yes. | Yes. Identical. |
Automatic Overload Trip? | No (identical to Apex) | No. Identical to Apex. Circuit design ensures self-limiting max stimulation, no injury. |
Automatic No-Load Trip? | No (identical to Apex) | No. Identical to Apex. Circuit design ensures self-limiting max stimulation, no injury. |
Automatic Shut Off? | Yes. | Yes. Identical. |
Indicator Display (On/Off, Low Battery) | On/Off via display illumination (Yes), Low Battery (No). Identical to Apex. | Yes (via display illumination), No. Identical to Apex. Device powers off with low battery, so no safety risk. |
Waveform, shape | Monophasic, alternating polarity, square pulse (identical to Apex) | Monophasic, alternating polarity, square pulse. Identical to Apex. Dual phase and monophasic alternating polarity both provide balanced positive/negative alternating waveforms. |
Frequency (Mixed, Stress, Urge) | 50 Hz for stress (Apex); 50 Hz mixed (InTone). New frequency 13Hz is added for urge. | 13, 50 Hz. Combination of frequencies supported by literature for stress, urge, and mixed incontinence. Substantially equivalent. |
Pulse width | 200 µs/phase. | 200 µs/phase. Identical. |
Time (On, Off) | 1 second On, 2 seconds Off (for 50Hz, identical to Apex). Additional on/off times for 13Hz. | 1 second at 50 Hz, 2 seconds no stimulation; 2 seconds at 13 Hz, 2 seconds no stimulation. Substantially equivalent, with added times for the new frequency. |
Total Session Time | 10-15 minutes (identical to Apex) | 10-15 minutes (5-10 minutes stimulation, 5 minutes self-directed). Identical to Apex. Small variances allowed. |
Max output voltage (500Ω) | 40 Vdc (identical to Apex), meets IEC60601-2-10. | 40 Vdc. Identical to Apex, meets IEC60601-2-10. |
Max output current (500Ω) | 80 mA (identical to Apex), meets IEC60601-2-10. | 80 mA. Identical to Apex, meets IEC60601-2-10. |
Maximum phase charge (500Ω) | 16 µC (identical to Apex), meets IEC60601-2-10. | 16 µC. Identical to Apex, meets IEC60601-2-10. Pulse width identical. |
Electrode surface area | 6.00 cm² ± 0.5 cm² (x 2) (identical to Apex). | 6.00 cm² ± 0.5 cm² (x 2). Identical to Apex. |
Max current density | 13.3 mA/cm² (identical to Apex), meets IEC60601-2-10. | 13.3 mA/cm². Identical to Apex, meets IEC60601-2-10. Electrode surface area is identical. |
Max average power density (500Ω) | 5.33 mW/cm² (identical to Apex), meets IEC60601-2-10. | 5.33 mW/cm². Identical to Apex, meets IEC60601-2-10. Electrode surface area, pulse width, max frequency identical. |
Biofeedback | None (Identical to Apex, removed feature). | None. Biofeedback is a removed feature on both Apex and ApexM; omission does not adversely impact safety. |
Dimensions (Insertion Unit) | Insertion Unit (overall): 12.2" x 2.5" x 4.0"; Inflatable Probe (avg. inflated): 5.5" x 2.2" x 2.5". Identical to Apex. | Insertion Unit (overall): 12.2" x 2.5" x 4.0"; Inflatable Probe (avg. inflated): 5.5" x 2.2" x 2.5". Identical. |
Control housing material | N/A (identical to Apex; no separate control unit). | N/A. Identical to Apex. No separate control unit, as ApexM is OTC and controlled by end user. |
Insertion material | Silicone, plastics. | Silicone, plastics. Identical. |
Packaging or Expiration Dating | N/A (identical to Apex). | N/A. Identical to Apex. No expiration date needed as components are stable. |
Sterilization | N/A. | N/A. Identical. |
Operational Method: Clinical Use | Home use, Over-the-counter (identical to Apex). | Home use, Over-the-counter. Identical to Apex. Over-the-counter indication does not impact safety due to user control, safety features. |
Patient Interaction: Functions Controllable | End user controls electrical stimulation levels and duration (identical to Apex). | End user controls electrical stimulation levels and duration. Identical to Apex. Stimulation controlled by end user per response, with safety features. |
Patient Interaction: Programming Capability | Electrical stimulation levels set by end user (identical to Apex). | Electrical stimulation levels set by end user. Identical to Apex. Stimulation controlled by end user per response, with safety features. |
Override | No (identical to Apex). | No. Identical to Apex. Device is single unit, powered off to stop stimulation and reset. |
Patient Interaction: Operator Requirements | Over-the-counter device. No special knowledge or training required; instruction manual provided (identical to Apex). | Over-the-counter device. No special knowledge or training required; instruction manual provided. Identical to Apex. Designed for intuitive use without physician oversight, validated by Apex Human Factors study. |
Software Level of Concern | Moderate. | Moderate. Identical. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- For ApexM specifically: No new separate clinical or human factors study was conducted for ApexM. Its "test set" and provenance are based on the studies or evaluations of its predicate devices.
- For the predicate Apex (K141158): A human factors/usability study was conducted.
- Sample size: Not explicitly stated but the study was designed for a "general population of women."
- Data provenance: Not specified in terms of country of origin but was a prospective "human factors / usability study."
- For predicate InTone (K110179) and InToneMV (K131420): Biocompatibility testing was performed on InToneMV, and electrical safety and EMC testing for InTone and Apex. These are generally lab-based tests, not human subject studies with a "test set" in the sense of clinical performance endpoints.
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)
- The document mentions "InControl Medical collaborated with the supervising physician to make further labeling enhancements" for the predicate Apex's human factors study.
- Number of experts: At least one "supervising physician" mentioned.
- Qualifications: "Supervising physician" implies medical expertise, but specific qualifications (e.g., years of experience, specialty) are not detailed.
- No other expert involvement for "ground truth" on test sets is mentioned for ApexM or its predicates in the context of device performance, as the studies are focused on usability, safety, and technical equivalence.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. The human factors/usability study for Apex was not a clinical trial requiring adjudication of outcomes by multiple experts. It assessed self-diagnosis, self-limiting usage based on contraindications, and safe use based on instructions. The results were deemed "favorable."
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 electrical muscle stimulator, not an AI-assisted diagnostic tool or imaging device that would involve human "readers" or an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a muscle stimulator used by a human user. Software verification and validation were performed for algorithms within the device (if any, as it's firmware controlled), but not a standalone "algorithm only" performance study in the AI sense. The "standalone performance" is covered by the electrical safety, EMC, and biocompatibility testing of the hardware components which demonstrated compliance with relevant standards.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For the human factors/usability study on predicate Apex: The "ground truth" was whether users could successfully self-diagnose, self-limit usage, and use the device safely as intended based on their understanding of the labeling. This implicitly relies on the medical accuracy of the diagnostic criteria presented in the labeling, which would be based on established medical knowledge and expert input in the development of those materials.
- For the clinical literature evaluation: The "ground truth" was derived from "evidence of the safety and efficacy of electrical stimulation for the treatment of female urinary incontinence" from published scientific literature, which would be based on clinical outcomes data from those studies.
8. The sample size for the training set
Not applicable. This device is not an AI/ML device that requires a training set in the conventional sense. The "training" for the device's technical specifications and safety parameters comes from engineering design, adherence to standards, and prior testing of predicate devices.
9. How the ground truth for the training set was established
Not applicable, as this is not an AI/ML device with a training set. The "ground truth" for the underlying principles of electrical stimulation and device safety were established through decades of medical and engineering science, published literature, and regulatory standards.
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(48 days)
INCONTROL MEDICAL, LLC.
InTone is intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of female urinary incontinence.
The InTone device includes three parts: an Insertion Unit, a Control Unit, and a Software Application for clinicians.
- The Insertion Unit includes an inflation pump and an inflatable probe. The inflatable probe is inserted into the vagina and the inflation pump is used by the patient to manually inflate the probe, ensuring a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Biofeedback is monitored via a pressure sensor within the Insertion Unit which records changes in pressure related to volitional muscle contraction.
- The Control Unit includes user keys to initiate and control treatment sessions, and a visual biofeedback graph to encourage muscle re-training. The Control Unit is designed to record and store results of the electrical stimulation and biofeedback sessions for clinician review at follow-up visits.
- The Software Application is utilized by the clinician to program the Control Unit and display the results of electrical stimulation and biofeedback sessions. The Software Application allows the clinician to select and lock in the appropriate electrical stimulation level necessary to stimulate pelvic floor contraction.
This document is a 510(k) premarket notification for the InTone device, seeking a determination of substantial equivalence to previously marketed predicate devices (InTone K110179 and InToneMV K134020). The document asserts that the new InTone device is substantially equivalent based on similarities in intended use, technology, engineering, performance, user interface, and prior testing conducted on the predicate devices.
Here's an analysis of the acceptance criteria and study information provided, focusing on what is stated and what is not:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not provide a formal table of "acceptance criteria" for the new InTone device in the sense of predefined thresholds for performance metrics. Instead, it presents a "Substantial Equivalence Comparison Table" (Table 7.3) that compares features and functions of the new InTone with its predicate devices (K110179 and K134020). The reported "performance" is implicitly demonstrated through this comparison, indicating that the new device operates similarly to or within the parameters of the predicate devices. When a feature is "Substantially equivalent" or "Identical," the impact on safety and performance is noted as "None," implying that the new device's performance is acceptable because it matches that of legally marketed devices.
Key performance-related comparisons include:
Feature/Function | New InTone Performance (Comparison to Predicates) | Impact on Safety and Performance |
---|---|---|
Intended Use | Substantially equivalent | None |
Primary Function | Identical to InToneMV | None |
Warnings or Precautions | Substantially equivalent | None |
Contraindications | Identical to InToneMV | None |
Labeling Summary | Substantially equivalent | None |
Environmental Specifications | Identical | None |
Power Source | Identical | None |
Method of line current isolation | Identical | None |
Patient leakage current | Identical | None |
Number of output modes | Identical | None |
Number of output channels | Identical | None |
Regulated current or voltage? | Identical | None |
Firmware controlled? | Identical | None |
Automatic Overload Trip? | Identical to InToneMV | None |
Automatic No-Load Trip? | Identical to InToneMV | None |
Automatic Shut Off? | Identical | None |
Indicator Display On/Off Status / Low Battery | Identical to InToneMV | None |
Waveform, shape | Monophasic, alternating polarity, square pulses (Substantially equivalent to dual phase, rectangular pulses) | None |
Frequency (Stress, Urge) | 50 Hz, 13 Hz (Identical to InToneMV) | None |
Pulse width | 200 µs/phase (Identical) | None |
Time (On, Off) | 1s on/2s off at 50Hz, 2s on/2s off at 13Hz (Identical to InToneMV) | None |
Total Session Time | Approx. 12 minutes (Identical to InToneMV) | None |
Max output voltage (500Ω) | 40 Vdc (Substantially equivalent to 50 Vdc) | None |
Max output current (500Ω) | 80 mA (Substantially equivalent to 100 mA) | None |
Maximum phase charge (500Ω) | 16 µC (Substantially equivalent to 20 µC) | None |
Electrode surface area | 6.00 cm² ± 0.5 cm² (x 2) (Substantially equivalent to 10.5 cm² x 2 and 2.5 cm² ± 0.5 cm² (x 2)) | None |
Max current density | 13.3 mA/cm- (Substantially equivalent to 9.5 mA/cm- and 40 mA/cm-) | None |
Max average power density (500Ω) | 5.33 mW/cm² (Substantially equivalent to 4.8 mW/cm- and 20 mW/cm-) | None |
Biofeedback | Manometric, Air pressure, 0-2 psi (Identical to InToneMV) | None |
Dimensions | Substantially equivalent | None |
Control housing material | Identical | None |
Insertion material | Identical | None |
Tubing Material | Identical to InTone | None |
Packaging or Expiration Dating | Identical to InTone | None |
Sterilization | Identical | None |
Operational Method: Clinical Use | Identical | None |
Patient Interaction: Functions Controllable | Identical | None |
Patient Interaction: Programming Capability | Identical | None |
Override | Identical | None |
Patient Interaction: Operator Requirements | Identical | None |
Software Level of Concern | Identical | None |
2. Sample size used for the test set and the data provenance:
- No specific sample size for a "test set" for the new device is provided. The document states that "New software verification and validation, electrical safety, EMC, and biocompatibility testing did not need to be performed to demonstrate the equivalent safety and effectiveness of this new version of the InTone."
- Instead, the reliance is on testing performed on the predicate devices:
- Data Provenance: The document does not explicitly state the country of origin or whether the testing data for the predicate devices was retrospective or prospective. It only mentions that the testing was "conducted on the predicate InToneMV" and "for the predicate InTone."
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 document relies on engineering and biological testing and a clinical literature review for validation, not on expert-established ground truth from a test set in the conventional sense of a clinical study assessing diagnostic performance.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- This information is not applicable/not provided. The document describes technical testing (software V&V, electrical safety, EMC, biocompatibility) and a literature review, not a clinical study involving adjudication of results.
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 MRMC comparative effectiveness study was done as described. The device is for electrical stimulation and biofeedback therapy for urinary incontinence, not an AI-assisted diagnostic tool that would involve human readers.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not applicable in the context of diagnostic algorithms. The InTone device is a therapeutic device (electrical stimulator and biofeedback) with software, not a standalone diagnostic algorithm. The software verification and validation were performed on the predicate device's software, which was considered "moderate" level of concern.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The concept of "ground truth" as typically used in diagnostic algorithm validation is not directly applicable to this submission. The validation relies on:
- Compliance with recognized standards: IEC 60601-1, IEC 60601-2-10, IEC 60601-1-2, ISO 10993-1.
- Software verification and validation: Against specifications and requirements.
- Biocompatibility testing: Chemical/biological safety evaluation.
- Clinical Literature Review: Documented evidence of safety and efficacy of electrical stimulation for female urinary incontinence in published articles and a MAUDE search for adverse events. This implicitly serves as "outcomes data" at a high level, validating the therapy type rather than specific device performance metrics against a gold standard for a new study.
8. The sample size for the training set:
- Not applicable/Not provided. The InTone device is not an AI/machine learning model that requires a training set in this context. Its function is based on established electrical stimulation and biofeedback principles.
9. How the ground truth for the training set was established:
- Not applicable/Not provided for the same reason as in point 8.
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(205 days)
INCONTROL MEDICAL, LLC
Apex is a non-implanted muscle stimulator designed to treat female stress urinary incontinence. It applies stimulation to the pelvic floor muscles to improve strength and support.
Apex is a hand-held, home-use device designed to treat female stress urinary incontinence. The device includes an inflatable probe. The inflatable probe is inserted into the vagina and manually inflated by the end user to ensure a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Muscle stimulation is used to train and strengthen the pelvic floor muscles in a controlled manner. Muscle stimulation is used to improve the ability of muscles to hold a contraction for an extended period of time and is a treatment for urinary incontinence. During a session, stimulation is delivered to specific muscles to encourage their contraction. This contraction strengthens the muscles and also helps the end user recognize which muscles to activate during self-directed contractions. The level of electrical stimulation is easily controlled by the end user using manual, push-button controls.
The provided text describes the 510(k) premarket notification for the Apex device, a non-implanted muscle stimulator for treating female stress urinary incontinence. The acceptance criteria and the study proving the device meets these criteria are primarily focused on demonstrating substantial equivalence to a predicate device (InTone K110179) and ensuring safety for over-the-counter use.
Here's a breakdown of the requested information based on the provided document:
1. A table of acceptance criteria and the reported device performance
The document does not present explicit "acceptance criteria" in a quantitative performance table (e.g., Sensitivity X%, Specificity Y%). Instead, it focuses on demonstrating substantial equivalence to a predicate device and confirming safety and intended performance through various tests for its over-the-counter use.
The "Acceptance Criteria" implicitly stem from comparability to the predicate and compliance with relevant standards and usability requirements for an OTC device. "Reported Device Performance" is presented in terms of compliance with these standards and successful completion of the studies.
Acceptance Criteria (Implicitly based on Predicate Equivalence and OTC Safety) | Reported Device Performance (Apex) |
---|---|
Intended Use Equivalence: Treat female stress urinary incontinence by applying stimulation to pelvic floor muscles. | Substantially equivalent to InTone (K110179). Both apply electrical stimulation to strengthen pelvic floor muscles. Apex specifically designed for female stress urinary incontinence. |
Primary Function Equivalence: Delivery of electrical stimulation. | Identical to InTone (K110179). |
Warnings/Precautions Equivalence & Clarity: Improve end-user understanding for OTC use. | Substantially equivalent to InTone (K110179). Reworded for Apex to improve end-user understanding for OTC use. Validated through Human Factors and Usability Testing. |
Contraindications Equivalence & Clarity: Improve end-user understanding for OTC use and ensure proper self-limitation. | Substantially equivalent to InTone (K110179). Reworded and reordered for Apex to improve end-user understanding for OTC use. Validated through collaboration with the supervising physician from the Human Factors and Usability Testing. |
Labeling Summary Clarity: Improve end-user understanding. | Substantially equivalent to InTone (K110179). User manual reworded for Apex to improve end-user understanding for OTC use. Manual validated through collaboration with the supervising physician from Human Factors and Usability Testing. Enhanced labeling includes educational consumer-focused box, detailed IFU, quick reference guide, and instructional video. |
Electrical Safety Standards Compliance: Meet IEC 60601-1 and IEC 60601-2-10 standards. | The device complies with the IEC 60601-1 and IEC 60601-2-10 standards for safety. |
Electromagnetic Compatibility (EMC) Standards Compliance: Meet IEC 60601-1-2 standard. | The device complies with the IEC 60601-1-2 standard for EMC. |
Biocompatibility: Meet ISO 10993-1 for tissue contact. | Biocompatibility evaluation conducted per ISO 10993-1. Insertion Unit is tissue contacting for |
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(57 days)
INCONTROL MEDICAL, LLC
InToneMV is intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of male and female urinary and fecal incontinence.
The InToneMV device includes three parts: an insertion unit, control unit, and a software application for clinicians. Each of these parts are summarized below:
- The insertion unit includes (1) an inflation bulb, (2) the customizable inflatable probe, and (3) the flexible tubing connecting the inflation bulb and the inflatable probe. The inflatable probe is inserted into the vagina or rectum and manually inflated by the patient to ensure a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the inflatable probe to induce a contraction of the pelvic floor muscles. Biofeedback is monitored via a pressure sensor within the insertion unit which records changes in pressure related to volitional muscle contraction.
- The control unit includes user keys to initiate and control treatment sessions, and a visual biofeedback graph to provide muscle re-training. The control unit is designed to record and store results of the electrical stimulation and biofeedback sessions for clinician review at follow-up visits.
- The software application is utilized by the clinician to program the control unit and display the results of electrical stimulation and biofeedback sessions.
The provided text describes the InToneMV device, an electrical stimulator for incontinence, and its 510(k) submission to the FDA. However, it does not contain a study that proves the device meets specific acceptance criteria in terms of performance metrics.
Instead, the submission focuses on demonstrating substantial equivalence to existing predicate devices (InTone K110179 and evadri Bladder Control Systems K050483) through a comparison of features, functions, and safety aspects. The "Testing Summary" section broadly states that "InToneMV successfully passed all testing" and "Clinical evaluations for InToneMV have been completed to support the device as safe and effective according to the intended use," but no specific performance acceptance criteria or results from these evaluations are provided.
Therefore, many of the requested details about acceptance criteria and study design are not available in the provided text.
Here's a breakdown of what can and cannot be answered based on the input:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria | Reported Device Performance |
---|---|
Not Explicitly Stated for Performance | The document states "InToneMV successfully passed all testing" and "Clinical evaluations... have been completed to support the device as safe and effective according to the intended use." However, no specific performance metrics (e.g., success rates, percentage reduction in incontinence episodes, specific biofeedback accuracy thresholds) are provided as acceptance criteria nor are their corresponding measured performance values. |
Substantial Equivalence (General) | The device is deemed "Substantially Equivalent" to predicate devices for its intended use, technology, engineering, performance, and user interface. This is the primary "acceptance criterion" articulated. |
Electrical Safety | Passed electrical safety testing. |
EMC (Electromagnetic Compatibility) | Passed EMC testing. |
Biocompatibility | Passed biocompatibility testing. |
Software Functionality | Passed software testing. |
Risk Management | Risks reduced to "as low as possible" and "risk/benefit analysis was acceptable" according to ISO 14971. |
2. Sample sized 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: Not specified. The document only mentions "Clinical evaluations... have been completed" without providing details on the number of participants.
- Data Provenance (Country of Origin): Not specified.
- Retrospective or Prospective: Not specified.
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 information is not provided. The term "ground truth" and details about expert review are not mentioned in the context of performance evaluation.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- This information is 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
- No, an MRMC comparative effectiveness study was not done. The device (InToneMV) is an electrical stimulator and biofeedback device for incontinence, not an imaging or diagnostic AI device that would typically involve "human readers" or "AI assistance" in the sense of image interpretation. The study mentioned is a "clinical evaluation" which is likely a clinical trial to assess safety and effectiveness of the therapeutic device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This question is not applicable in the context of this device. The InToneMV is a medical device for treatment, not an algorithm for diagnosis that would have standalone performance. Its function inherently involves patient interaction (insertion, self-inflation, muscle contraction) and clinician programming.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
- Not explicitly stated. Given the nature of the device for treating incontinence, "outcomes data" (e.g., reduction in incontinence episodes, improved quality of life, strength of pelvic floor muscles) would be the most likely form of ground truth for its efficacy in a clinical evaluation. However, the document does not specify how "ground truth" was established or what specific metrics were used.
8. The sample size for the training set
- This is not applicable as the device is a physical medical device, not an AI/machine learning algorithm requiring a "training set" in the computational sense.
9. How the ground truth for the training set was established
- This is not applicable for the same reason as above (not an AI/machine learning algorithm).
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(20 days)
INCONTROL MEDICAL, LLC
The InToneMV device is a non-implanted electrical stimulator indicated for use in the treatment of female urinary incontinence. It applies electrical stimulation to the pelvic floor musculature and surrounding structures. It is intended for acute and ongoing treatment of mixed urinary incontinence where the following results may improve urinary control: strengthening of pelvic floor muscles and inhibition of the detrusor muscle through reflexive mechanisms. The biofeedback feature can be used for muscle re-education purposes.
The InToneMV device includes three parts: an insertion unit, a hand-held control unit, and a PCbased software application.
- The insertion unit includes (1) an inflation bulb, (2) the inflatable probe, and (3) the flexible tubing connecting the inflation bulb and the probe. The inflatable probe is inserted into the vagina and manually inflated by the patient to ensure a customized fit. Electrical stimulation is delivered via stainless steel electrodes on the probe to induce a contraction of the pelvic floor muscles.
- The external hand-held control unit includes user keys to initiate and control treatment sessions. The control unit is designed to record and store results of the electrical stimulation and patient generated pelvic floor exercises.
- The PC-based software application is utilized by the clinician to program the hand-held control unit, store and display the results of electrical stimulation and patient generated pelvic floor exercises. The application allows the clinician to select and lock in the appropriate amount of electrical stimulation necessary to stimulate pelvic floor contraction.
The provided document is a 510(k) summary for a medical device called InToneMV. This document describes the device, its intended use, and its substantial equivalence to a predicate device (InTone K110179).
However, the document does not contain acceptance criteria or a study that proves the device meets specific acceptance criteria in terms of clinical performance or effectiveness metrics. Instead, it focuses on demonstrating substantial equivalence through modifications to an existing device and safety testing.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not provide specific performance acceptance criteria (e.g., sensitivity, specificity, accuracy, or clinical outcome measures) or reported device performance against such criteria. The submission is a Special 510(k), which typically involves modifications to an existing device where the original performance characteristics are assumed to be maintained if the modifications don't impact safety or effectiveness.
The document states: "The data collected and documented throughout this submission provides objective evidence that InToneMV performs as well as or better than the predicate device for the treatment of female urinary incontinence." This is a general claim of performance equivalence rather than a report against specific acceptance criteria for the InToneMV itself.
2. Sample sized 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 clinical test set or sample size for evaluating the InToneMV's performance. It explicitly states: "Clinical performance of InToneMV is further detailed in Section 14." and "There have been no modifications to the clinical performance." However, Section 14 is not included in the provided snippets. Given that this is a Special 510(k) for device modifications, it's highly probable that new clinical data was not collected specifically for InToneMV's clinical performance because its clinical performance is considered identical to the predicate.
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)
Not applicable, as no new clinical test set or ground truth establishment is described for the InToneMV device's clinical performance.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
Not applicable, as no new clinical test set or ground truth establishment is described for the InToneMV device's clinical performance.
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. The InToneMV is a medical device (pelvic floor muscle stimulator), not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. The InToneMV is a medical device, not an algorithm. Its performance relies on the device's electrical stimulation and biofeedback capabilities for the patient, potentially overseen by a clinician.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable, as no new clinical test set or ground truth establishment is described for the InToneMV device's clinical performance. The submission relies on the predicate device's established effectiveness.
8. The sample size for the training set
Not applicable. The InToneMV is a physical medical device, not a machine learning model that requires a training set.
9. How the ground truth for the training set was established
Not applicable.
Summary of what the document does describe regarding validation:
- Bench Testing: "Bench testing of InToneMV is further detailed in Section 13." This would relate to the physical and electrical safety and performance of the modified device components (e.g., smaller probe, flexible cord).
- Electrical Safety Tests: "IEC60601 electrical safety tests were performed on the modifications. Results identified InToneMV as electrically safe."
- Software: "The software in InToneMV is identical to the predicate device, InTone (K110179). There have been no modifications to the existing, validated software."
- Materials: "The patient contact materials used in InToneMV are identical to the predicate device, InTone. There have been no modifications to the materials."
- Design Controls and Risk Management: Modifications were completed according to internal procedures, and risks were evaluated per ISO 14971, with an acceptable risk/benefit analysis.
The core argument for the InToneMV's performance and safety is its substantial equivalence to the predicate device (InTone K110179) and the fact that modifications only apply to the insertion unit, which were validated through non-clinical testing (bench and electrical safety) and adherence to design controls. The clinical performance and effectiveness are considered to be unchanged from the predicate device.
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(397 days)
INCONTROL MEDICAL, LLC
The InControl InTone device is a non-implanted electrical stimulator indicated for use in the treatment of female urinary incontinence. It applies electrical stimulation to the pelvic floor musculature and surrounding structures. It is intended for acute and ongoing treatment of mixed urinary incontinence where the following results may improve urinary control: strengthening of pelvic floor muscles, inhibition of the detrusor muscle through reflexive mechanisms. The biofeedback feature can be used for muscle re-education purposes.
The device includes three parts; an insertion probe and a hand-held control unit. The insertion The device includes three parts, an inoortion provides more adaptable fit for intra-vaginal use. The probe includes stainless steel electrodes to deliver electro-stimulation. The hand-held control probe includes stainless steel clours and displays the results of electro-stimulation and patient and ulsplay device records, storos, and alspiary one to select and lock in the correct amount generated pervic noor excressor from to the contraction. It also stores data on contraction of current necessary to stimulate pervice noor ochination to select and lock in the correct amount of current necessary to stimulate pelvic floor contraction.
The provided document is a 510(k) summary for the InControl InTone device, a non-implantable electrical stimulator for treating female urinary incontinence. The claims are for "substantial equivalence" of the InControl InTone device to predicate devices on the market and do not detail any clinical studies. Therefore, this document does not contain information to answer the bulk of your questions regarding acceptance criteria, study sizes, ground truth establishment, or clinical performance metrics.
However, based on the provided tables comparing the InControl InTone device to its predicate devices (Otto Bock STIWELL med4, MyoTrac Infiniti, and Hollister evadri), we can infer the acceptance criteria were based on demonstrating equivalence in intended use, technology, engineering, and performance specifications.
Here's the information that can be extracted from the provided text:
1. A table of acceptance criteria and the reported device performance:
The acceptance criteria are not explicitly stated with numeric thresholds or targets for device performance. Instead, the "Comparison" column indicates whether the InControl InTone's features are "Identical," "Equivalent," or "Within range" compared to predicate devices. The "Reported Device Performance" for the InControl InTone is simply its listed specifications.
Feature/Function | Predicate Acceptance Criteria (Inferred from comparison) | InControl InTone (Reported Device Performance) | Comparison to Predicate Devices (Otto Bock, MyoTrac, Hollister) |
---|---|---|---|
Intended Use | Equivalent to predicate devices | Treatment of female urinary incontinence, electrical stimulation to pelvic floor, muscle re-education. Acute and ongoing treatment of mixed urinary incontinence. | Equivalent |
Method of line current Isolation | Battery operated | n/a (battery) | Identical (to Otto Bock, MyoTrac) |
Patient leakage current | Battery operated | n/a (battery) | Identical (to Otto Bock, MyoTrac) |
Number of output modes | 1 | 1 | Identical (to all) |
Number of output channels | 1 | 1 | Identical (to all) |
Regulated current or Voltage | Regulated current / voltage (equivalent or within range of predicates) | Regulated voltage | Equivalent |
Firmware controlled | Yes | Yes | Identical (to all) |
Automatic Overload Trip | Yes | Yes | Identical (to Otto Bock) |
Automatic No-Load Trip | Yes | Yes | Identical (to Otto Bock) |
Automatic Shut Off | Yes | Yes | Identical (to Otto Bock) |
Indicator Display On/Off Status/Low Battery | Yes | Yes | Identical (to Otto Bock, MyoTrac) |
Waveform, shape | Biphasic symmetrical rectangular / asymmetric balanced pulse / balanced biphasic | dual phase, rectangular pulses | Identical (to Otto Bock, Hollister) |
Frequency (Mixed, Stress, Urge) | Within range of predicate values | 50 Hz | Identical (to MyoTrac, Hollister specifically mentions 50Hz) / Within range |
Pulse width (Mixed, Stress, Urge) | Within range of predicate values | 200 µs/phase | Within range |
Time (On, Off, Total Session Time) | Within range of predicate values | On: 20 secs, Off: 10 secs, Total: 12 mins | Within range |
Max output voltage (500Ω) | 50 Vdc | 50 Vdc | Identical (to Otto Bock) |
Max output current (500Ω) | 100 mA | 100 mA | Identical (to Otto Bock) |
Maximum phase charge (500Ω) | 50-60 µC | 50 µC | Identical |
Electrode surface area | Equivalent to predicate values | 10.5 cm² x 2 | Equivalent |
Max current density | Equivalent to predicate values | 4.7 mA/cm² | Identical |
Maximum power density (500Ω) | Equivalent to predicate values | 14.3 µW/cm² | Equivalent |
Biofeedback | EMG, pressure, or combination | Air pressure, 0-2 psi | Equivalent (to Hollister) |
Dimensions | Equivalent to predicate sizes | 8 x 5 x 4 inches | Equivalent |
Control housing materials | Plastics | ABS plastics | Equivalent |
Insertion material | Plastics | Silicone, plastics | Equivalent |
Packaging or Expiration Dating | N/A or 1 year | 1 year for insertion unit | |
Sterilization | N/A | N/A | |
Operational Method (Clinical Use) | Clinic or Home use, under direction of physician | Clinic or Home use, under direction of physician | Identical (to all) |
Patient Interaction: Functions Controllable | Starting/stopping of sessions (auto-stop for completion) | Patient controls start/stop, device auto-stops | Equivalent |
Patient Interaction: Programming Capability | None, programmed by clinician | None, programming by clinician | Equivalent (to Otto Bock, MyoTrac) |
Override | Yes | Yes | Identical (to Otto Bock) |
Patient Interaction: Operator Requirements | No special knowledge/training, instruction manual, physician coaching | No special knowledge/training, instruction manual, physician coaching | Identical (to all) |
Software Level of Concern | (Not explicitly stated for predicates, but "Moderate" for new device) | Moderate | |
Environmental Specifications | For indoor use only | For indoor use only | Identical (to all) |
Power Source | Various (Li-Ion, AAA alkaline, AC power) | Nickel metal hydride battery | Equivalent |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not present in the provided 510(k) summary. The document describes a substantial equivalence submission based on technical features and intended use comparison to predicate devices, not clinical studies with test sets.
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 information is not present in the provided 510(k) summary. No test sets or ground truth establishment by experts are mentioned.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not present in the provided 510(k) summary. No test sets or adjudication methods are mentioned.
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
A multi-reader multi-case (MRMC) comparative effectiveness study was not done and is not mentioned in the provided document. The device is a direct patient treatment device, not an AI diagnostic tool that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as the InControl InTone is an electrical stimulator device, not an AI algorithm. Its performance is related to its physical and electrical specifications, which were assessed through "EMC, electrical, mechanical, safety (operator and patient), temperature/humidity, and software testing."
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
This information is not present in the provided 510(k) summary for any clinical performance. The "ground truth" for the device's technical performance seems to be established through engineering compliance testing against applicable standards (e.g. EMC, electrical, mechanical safety).
8. The sample size for the training set
This information is not present in the provided 510(k) summary. No training sets are mentioned.
9. How the ground truth for the training set was established
This information is not present in the provided 510(k) summary. No training sets or ground truth establishment for them are mentioned.
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