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510(k) Data Aggregation

    K Number
    K182311
    Device Name
    Cervella
    Date Cleared
    2019-03-07

    (195 days)

    Product Code
    Regulation Number
    882.5800
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Innovative Neurological Devices LLC

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

    Cervella Cranial Electrotherapy Stimulator (CES) is indicated for treatment of insomnia, depression, or anxiety.

    Device Description

    Cervella Cranial Electrotherapy Stimulator (CES) is a device that delivers small pulses of electrical current through patient's brain. The stimulator is powered by an internal rechargeable battery which provides a low-level constant current to the cranium via a pair of conductive electrodes placed bilaterally on the mastoid process. The electrodes are incorporated into earpads of stereo over-ear noise-cancelling headphones. The patient can use the audio (through a separate dedicated Bluetooth connection) and noise cancelling features of the stereo headphones during treatment (e.g. music listening). The stimulator is controlled via a software application (app) installed on the patient's smart device (e.g. smartphone). The app communicates with the device through a dedicated Bluetooth® LE connection that is independent of the optional Bluetooth connection for audio listening purposes. The patient uses the app to adjust the intensity level, frequency, and duration of the treatment. The app also allows the patient to automatically store the treatment history for review by the patient's healthcare provider.

    AI/ML Overview

    This submission lacks specific acceptance criteria and detailed study results to demonstrate device performance against those criteria. The provided document is a 510(k) summary, which focuses on establishing substantial equivalence to predicate devices rather than proving a device meets specific, pre-defined performance acceptance criteria through clinical studies.

    Here's an analysis based on the available text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not explicitly state acceptance criteria in terms of clinical or technical performance metrics (e.g., specific reduction in anxiety scores, minimum current output accuracy, etc.) and then report the device performance against those criteria. Instead, it relies on demonstrating substantial equivalence to predicate devices based on shared design, operating principles, and compliance with general safety and performance standards.

    The table presented in the "IX. PERFORMANCE DATA DEMONSTRATING SUBSTANTIAL EQUIVALENCE" and "X. SUMMARY OF SIMILARITIES AND DIFFERENCES" sections compares the Cervella device's characteristics to its predicate devices, CES Ultra and Alpha-Stim CS. This comparison serves as the de facto "performance data" that the manufacturer presented for substantial equivalence, rather than a direct measurement against pre-defined acceptance criteria for a new clinical claim.

    PropertyCervella (Reported Performance)Predicate 1 (CES Ultra)Predicate 2 (Alpha-Stim CS)Differences and Comments
    Indications for UseTreatment of insomnia, depression, or anxiety.Treatment of insomnia, depression, or anxiety.Treatment of insomnia, depression, or anxiety.None
    WaveformSymmetrical Biphasic Square WaveSymmetrical Biphasic Square WaveSymmetrical Biphasic Square WaveNone
    Current Intensity Range0µA – 500µA adjustable in 50µA increments0µA — 1500µA continually adjustable0µA — 500µA adjustable in 50µA incrementsSame range as Alpha-Stim, narrower range than CES Ultra
    Pulse Width Range5ms - 1s (varies depending on frequency selection)2ms250ms - 1sPulse width varies depending on frequency selection
    Number of electrodesTwoTwoTwoNone
    Electrode PlacementHead (Mastoid process)Head (Mastoid process or Earlobes)Head (Earlobes)Same placement as CES Ultra
    Power SourceLi-ion Battery (3.7V) (rechargeable)Alkaline Battery (9V)Alkaline Battery (3V)Cervella battery is rechargeable
    Frequency selections0.5Hz, 1.5Hz, 100Hz100Hz0.5Hz, 1.5Hz, 100HzSame frequency selection as Alpha-Stim CS
    Treatment Range10 min – 60 min in 10 min intervals30 min, 60min, or continuous10, 20, 60 minutes or continuousSame min-max range as Alpha-Stim
    Unit ControlsVia Bluetooth-enabled smart device featuring Cervella appBuilt into the deviceBuilt into the deviceWireless operation
    Treatment history loggingAutomaticNot availableNot AvailableNew feature
    Ability for patient to use audio and noise cancelling feature of headset during treatmentOptional via dedicated separate Bluetooth connectionNot availableNot AvailableNew feature
    Dimensions and weight7cm x 7cm x 2cm13.5cm x 6.4cm x 3.3cm9.8cm x 6.3cm x 2cmCervella is slightly smaller
    EnclosurePlasticPlasticPlasticNone

    2. Sample size used for the test set and data provenance:

    The document (a 510(k) summary) does not describe a clinical "test set" in the context of typical AI/ML performance evaluation (e.g., a cohort of patients whose data is used to validate an algorithm's diagnostic or therapeutic efficacy).

    The performance data cited are primarily bench testing against electrical safety and performance standards for medical devices (ES60601-1:2005, IEC 60601-1-2, IEC 60601-2-10, IEC 62133). These tests do not involve patient data or clinical outcomes. Therefore, there is no information on sample size, country of origin, or whether it was retrospective or prospective data in the clinical sense.

    3. Number of experts used to establish the ground truth for the test set and their qualifications:

    Not applicable. As noted above, there was no clinical test set requiring expert ground truth establishment for diagnostic or therapeutic accuracy. The ground truth for electrical safety and performance standards is defined by the standards themselves, not by expert consensus on clinical data.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    Not applicable, as there was no clinical test set requiring adjudication.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and the effect size of how much human readers improve with AI vs without AI assistance:

    Not applicable. The Cervella device is a Cranial Electrotherapy Stimulator (CES), a standalone therapeutic device, not an AI-assisted diagnostic or interpretive tool that would typically be evaluated in an MRMC study with human readers. The document does not describe any such study.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    The device itself is a standalone therapeutic device. Its core function – delivering electrical stimulation – is algorithm-driven in terms of current intensity, frequency, and duration programming, but it's not an "AI algorithm" in the typical sense of a diagnostic or predictive model. The performance data provided is mainly about its physical and electrical characteristics conforming to standards, not a standalone evaluation of an AI algorithm's diagnostic accuracy.

    7. The type of ground truth used:

    For the evaluation described, the "ground truth" was compliance with mandatory and voluntary medical device safety and performance standards (e.g., IEC 60601 series). These standards define the expected electrical output, safety features, and battery performance. There is no mention of expert consensus, pathology, or outcomes data as "ground truth" for the purpose of this 510(k) submission, as it focuses on substantial equivalence of physical and electrical parameters.

    8. The sample size for the training set:

    Not applicable. This device is not an AI/ML algorithm that requires a "training set" of data in the typical sense to learn patterns or make predictions. Its operation is based on predefined electrical parameters.

    9. How the ground truth for the training set was established:

    Not applicable, as there is no training set for an AI/ML algorithm.

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