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510(k) Data Aggregation

    K Number
    K203316
    Date Cleared
    2021-10-27

    (351 days)

    Product Code
    Regulation Number
    878.4780
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    KCI, a part of 3M Health Care Business Group

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

    The V.A.C.® Ulta Negative Pressure Wound Therapy System is an integrated wound management system that provides Negative Pressure Wound Therapy (V.A.C.® Therapy) with an instillation option ( Veraflo™ Therapy).

    · V.A.C.® Therapy in the absence of instillation is intended to create an environment that promotes wound healing by secondary or tertiary (delayed primary) intention by preparing the wound bed for closure, reducing edema, promoting granulation tissue formation and perfusion, and by removing exudate and infectious material.

    · Veraflo™ Therapy is indicated for patients who would benefit from vacuum assisted drainage and controlled delivery of topical wound treatment solutions and suspensions over the wound bed.

    The V.A.C.® Ulta Negative Pressure Wound Therapy System with and without is indicated for patients with chronic, acute, traumatic, sub-acute and dehisced wounds, partial-thickness burns, ulcers (such as diabetic, pressure and venous insufficiency), flaps and grafts.

    · V.A.C.® Therapy in the absence of instillation may also be used for:

    o The temporary bridging of abdominal wall openings where primary closure is not possible and/or repeat abdominal entries are necessary and for open abdominal wounds with exposed viscera including, but not limited to, abdominal compartment syndrome. The intended care setting is a closely monitored area within the acute care hospital, such as the ICU. The abdominal dressing will most often be applied in the operating theater.

    o The management of the environment of surgical incisions that continue to drain following sutured or stapled closure by maintaining a closed environment and removing exudate via the application of negative pressure wound therapy.

    Device Description

    The V.A.C. 8 Ulta Negative Pressure Wound Therapy System is a negative pressure wound therapy system with an instillation feature which allows controlled delivery and drainage of topical wound treatment solutions and suspensions. The unit is comprised of a vacuum pump and an instillation pump. The vacuum pump delivers negative therapy for the removal of wound exudate and instilled solutions when applied. The instillation pump provides controlled delivery of topical wound solutions and suspensions. Both pumps are software controlled. Instillations and negative pressure are delivered through tubing to foam dressings in the wound covered by an occlusive drape. Software monitors both negative pressure wound therapy as well as positive pressure during instillation of fluids to the wound bed. Software also provides controls for setting therapy parameters as well as help and alarm functions.

    AI/ML Overview

    The document describes the V.A.C.® Ulta Negative Pressure Wound Therapy System, which is a negative pressure wound therapy system with an instillation feature. The submission for this device is a 510(k) premarket notification.

    Here's the breakdown of the acceptance criteria and study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present acceptance criteria in a tabular format with corresponding device performance values for all features. However, it states the performance specification for the new Smart Instill™ Feature and the general performance testing conclusion.

    Feature/ParameterAcceptance CriteriaReported Device Performance
    Veraflo™ Therapy Cycle
    Smart Instill™ FeatureDressing saturation must be achieved for the instilled volume within 12 hours, without creating an overfill condition.Performance testing has documented that the Smart Instill™ Feature meets its design specification fill volumes that will saturate the applied dressing within 12 hours of initiation without underfilling or overfilling the dressed wound.
    All Therapy CyclesVerification data confirms that the specified negative pressure and instillation performance specifications have been met.Performance testing has documented that the Smart Instill™ Feature meets its design specification fill volumes that will saturate the applied dressing within 12 hours of initiation without underfilling or overfilling the dressed wound.
    Software Level of ConcernModerateModerate
    CybersecurityRisk of patient harm from device exploitability at a controlled and acceptable level. Device is trustworthy, resilient to cybersecurity threats that can lead to patient harm, suited to perform intended functions, and provides a reasonable level of availability, reliability, and correct operation.Cybersecurity assessment indicates the risk is at a controlled level and acceptable. The device is considered sufficiently trustworthy, reasonably resilient, suited for intended functions, and provides a reasonable level of availability, reliability, and correct operation.
    New Features Usability/SafetyThe new features could be safely and effectively used by all test subjects.Human factors engineering assessment with 30 subject nurses and doctors indicated that the new features could be safely and effectively used by all test subjects.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not provide details on the sample size or provenance for the "performance testing" that documented the Smart Instill™ Feature's compliance. This testing is described as non-clinical.

    For the human factors engineering assessment:

    • Sample Size for Test Set: 30 subject nurses and doctors.
    • Data Provenance: Not specified, but generally, human factors studies for medical devices are prospective and conducted in a simulated or real-world use environment. The document does not specify the country of origin.

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

    • The document does not mention the use of experts to establish "ground truth" in the conventional sense for the performance testing or the human factors study.
    • For the human factors study, 30 "subject nurses and doctors" were used as participants to assess usability and safety, but they were not establishing ground truth, rather their interactions with the device were the data. Their specific qualifications (e.g., years of experience) are not detailed beyond "nurses and doctors."

    4. Adjudication Method

    • Adjudication methods (e.g., 2+1, 3+1) are typically used in clinical studies or studies where expert consensus is needed to establish ground truth from ambiguous cases. This type of adjudication is not described or indicated for either the non-clinical performance testing or the human factors assessment mentioned in the document.

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

    • No MRMC comparative effectiveness study is mentioned. The submission is for a medical device (Negative Pressure Wound Therapy System), not an AI-assisted diagnostic tool, so this type of study would not typically apply. The document focuses on performance specifications and human factors for the device itself.

    6. Standalone Performance (Algorithm Only)

    • The Smart Instill™ Feature involves software control, and its performance was "documented." This implies a standalone evaluation of the algorithm's ability to achieve saturation within the specified time frame. However, the exact methodology for this standalone testing is not detailed (e.g., if it was tested solely in simulation or on benchtop models without human interaction to verify the algorithm's output). The "performance testing" mentioned effectively serves as a standalone evaluation of the Smart Instill™ algorithm's functionality within the device.

    7. Type of Ground Truth Used

    • For the Smart Instill™ Feature: The "ground truth" would be objective measurements of fill volume and dressing saturation achieved within the 12-hour timeframe. This would likely be established through physical measurements on test setups (e.g., measuring liquid volume and observing saturation on wound models).
    • For the human factors engineering assessment: The "ground truth" is established by observing user interactions and collecting feedback to determine if tasks can be performed safely and effectively. This is based on direct observation and qualitative/quantitative data from the participants.

    8. Sample Size for the Training Set

    • The document does not mention a "training set" as this is not an AI/machine learning model that requires a distinct training phase. It describes new software features, which are typically developed based on design specifications and then verified/validated.

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

    • Since there is no mention of a training set in the context of an AI/ML model, this question is not applicable. The device's software features are developed based on established engineering principles and clinical requirements, rather than being "trained" on a dataset with ground truth labels.
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