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510(k) Data Aggregation
(90 days)
Telescope™ Guide Extension Catheter is intended to be used in conjunction with guide catheters to access discrete regions of the coronary and/or peripheral vasculature, and to facilitate placement of interventional devices.
The Telescope™ Guide Extension Catheter is a single-lumen rapid exchange catheter designed to act as an extension to a traditional guide catheter. The Telescope™ Guide Extension Catheter is intended to be used with guide catheters to access discrete regions of the coronary and/or peripheral vasculature, and to facilitate placement of interventional devices.
The Telescope™ Guide Extension Catheter device is 150cm in length and consists of a hydrophilic-coated single-lumen distal guide segment connected to a stainless-steel polytetrafluoroethylene (PTFE) coated proximal pushwire.
The device is offered in two sizes 6F and 7F, with a hub at the proximal end of the pushwire that is used for device identification.
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(29 days)
Infinity™ OCT System
The Infinity™ OCT System is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7), and the thoracic spine from T1-T3:
- Traumatic spinal fractures and/or traumatic dislocations.
- Instability or deformity.
- Failed previous fusions (e.g. pseudarthrosis).
- Tumors involving the cervical spine.
- Degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability.
The Infinity™ OCT System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.
The Infinity™ OCT System may be used with PASS OCT Patient Specific UNiD OCT rods. In order to achieve additional levels of fixation, the Infinity™ OCT System may be connected to the CD Horizon™ Spinal System and Vertex™ Reconstruction System rods with the Infinity™ OCT System rod connectors. Transition rods with differing diameters may also be used to connect the Infinity™ OCT System to the CD Horizon™ Spinal System. Refer to the CD Horizon™ Spinal System package insert, Vertex™ Reconstruction System and PASS OCT Spinal System package insert for a list of the indications of use.
Note: The 3.0mm multi axial screw (MAS) requires the use of MAS CROSSLINK™ at each level in which the 3.0mm screw is intended to be used.
The lateral offset connectors and MAS extension connectors are intended to be used with 3.5mm and larger diameter multi axial screws. The lateral offset connectors and MAS extension connectors are not intended to be used with 3.0mm screws.
Note: Segmental fixation is recommended for these constructs.
Medtronic Navigated Reusable Instruments for use with StealthStation™ and IPC™ POWEREASE™ Systems
Medtronic Navigated Reusable Instruments are intended to be used during the preparation and placement of Medtronic screws during spinal surgery to assist in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Navigated Reusable Instruments are specifically designed for use with the StealthStation™ System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy.
Infinity™ OCT System
The Infinity™ OCT System is a posterior occipitocervical-upper thoracic system, which consists of a variety of shapes and sizes of plates, rods, hooks, screws, multi-axial screws, and connecting components, which can be rigidly locked to the rod in a variety of configurations, with each construct being tailor-made for the individual case.
The Infinity™ OCT System is fabricated from medical grade titanium alloy and medical grade cobalt chromium.
Medtronic Navigated Reusable Instruments for use with StealthStation™ and IPC™ POWEREASE™ Systems
Medtronic Navigated Reusable Instruments are spine preparation instruments manufactured from high grade stainless steel. These instruments are specifically designed for use in procedures where the use of stereotactic surgery may be appropriate. Placing Medtronic single-use sterile spheres on each of the NavLock™ Tracker passive stems allows a Medtronic computer assisted surgery system such as the StealthStation™ Image Guidance System to track the instruments in the surgical field. Medtronic Navigated Reusable Instruments are compatible with various Medtronic spinal implant systems. These instruments are also compatible with Medtronic's IPC™ POWEREASE™ System when connected to the POWEREASE™ Driver.
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(29 days)
Parietene™ flat Sheet Mesh is intended for the reinforcement of abdominal wall soft tissue where a weakness exists, in procedures involving abdominal wall hernias repair.
Parietene™ Flat Sheet Mesh is a Monofilament polypropylene mesh.
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(24 days)
The CD Horizon™ Spinal System with or without Sextant™ instrumentation is intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (DDD - defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e. fracture or dislocation), spinal stenosis, curvatures (i.e. scoliosis, kyphosis, or lordosis), tumor, pseudarthrosis, and/or failed previous fusion.
Except for hooks, when used as an anterolateral thoracic/lumbar system, CD Horizon™ Spinal System titanium, cobalt chrome, and stainless steel implants may also be used for the same indications as an adjunct to fusion. With the exception of DDD, CD Horizon™ Legacy™ 3.5mm rods and associated components may be used for the aforementioned indications in skeletally mature patients as an adjunct to fusion. The 3.5mm rods may be used for the specific pediatric indications noted below.
When used for posterior non-cervical pedicle screw fixation in pediatric patients, CD Horizon™ Spinal System titanium, cobalt chrome, and stainless steel implants are indicated as an adjunct to fusion to treat progressive spinal deformities (i.e. scoliosis, kyphosis, or lordosis) including idiopathic scoliosis, neuromuscular scoliosis, and congenital scoliosis. Additionally, the CD Horizon™ Spinal System is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis, fracture caused by tumor and/or trauma, pseudarthrosis, and/or failed previous fusion. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.
The CD Horizon™ PEEK rods are intended to provide posterior supplemental fixation when used with an interbody fusion cage for patients diagnosed with DDD. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level. This device is intended for 1-2 level use in the lumbosacral spine (L2 - S1) in skeletally mature patients. The device is intended for use with an interbody fusion cage at the instrumented level and is not intended for stand-alone use.
The CD Horizon™ Spire™ plate is a posterior, single-level, non-pedicle supplemental fixation device intended for use in the non-cervical spine (T1-S1) as an adjunct to fusion in skeletally mature patients. It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fixation in the following conditions: DDD (as previously defined), spondylolisthesis, trauma, and/or tumor.
To achieve additional levels of fixation, CD Horizon™ Spinal System rods may be connected to the Vertex™ Reconstruction System with the Vertex™ rod connector. Refer to the Vertex™ Reconstruction System package insert for a list of the Vertex™ indications of use.
The CD Horizon™ Spinal System consists of a variety of shapes and sizes of rods, hooks, screws, Crosslink™ Plates, staples, and connecting components, as well as implant components from other Medtronic spinal systems which can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.
A subset of CD Horizon™ Spinal System components may be used for posterior pedicle screw fixation in pediatric cases. These constructs may be comprised of a variety of shapes and sizes of rods (ranging in diameter from 3.5mm to 6.35mm), hooks, screws, Crosslink™ plates, and connecting components. Similar to the CD Horizon™ implants used in adult cases, these components can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.
Certain components within the CD Horizon™ Spinal System are specifically excluded for use in pediatric patients. These include PEEK rods and Spire™ plates. Screws used in pediatric cases are only cleared for use via a posterior approach. All components used in pediatric cases are fabricated from medical grade stainless steel, medical grade titanium, titanium alloy, and medical grade cobalt-chromium-molybdenum alloy.
Certain implant components from other Medtronic spinal systems can be used with the CD Horizon™ Spinal System in non-pediatric cases. These components include TSRH™ rods, hooks, screws, plates; Crosslink™ plates, connectors, staples, and washers; GDLH™ rods, hooks, and connectors; Crosslink™ bar and connectors and Medtronic multi-axial rods and screws.
Note that certain components are specifically designed to connect to specific rod diameters, while other components can connect to multiple rod diameters. Care should be taken so the correct components are used in the spinal construct.
CD Horizon™ hooks are intended for posterior use only. CD Horizon™ staples and associated screws are intended for anterior use only. However, for patients of smaller stature and pediatric patients, CD Horizon™ 4.5mm rods and associated components may be used posteriorly.
CD Horizon™ Spinal System implant components are fabricated from medical grade stainless steel, medical grade titanium, titanium alloy, medical grade cobalt-chromium-molybdenum alloy, or medical grade PEEK Optima-LT1. Certain CD Horizon™ Spinal System components may be coated with hydroxyapatite. No warranties, expressed or implied, are made. Implied warranties of merchantability and fitness for a particular purpose or use are specifically excluded.
Never use stainless steel and titanium implant components in the same construct.
Medical grade titanium, titanium alloy, and/or medical grade cobalt-chromium-molybdenum alloy may be used together. Never use titanium, titanium alloy, and/or medical grade cobalt chromium-molybdenum alloy with stainless steel in the same construct.
PEEK Optima-LT1 implants may be used with titanium or cobalt-chromium-molybdenum alloy implants. CD Horizon™ PEEK rods are not to be used in pediatric patients. PEEK rods are only to be used with the associated pedicle screws as well as interbody fusion devices in the anterior spinal column.
To achieve best results, do not use CD Horizon™ Spinal System implant components with components from any other system or manufacturer unless specifically allowed to do so in this or another Medtronic document.
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(176 days)
The StealthStation™ System, with StealthStation™ Spine Software, is intended as an aid for precisely locating anatomical structures in either open or percutaneous neurosurgical and orthopedic procedures in adult and skeletally mature pediatric (adolescent) patients. Their use is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as the spine or pelvis, can be identified relative to images of the anatomy.
This can include the following spinal implant procedures in adult patients, such as:
- Pedicle Screw Placement
- Iliosacral Screw Placement
- Interbody Device Placement
This can include the following spinal implant procedures in skeletally mature pediatric (adolescent) patients:
- Pedicle Screw Placement
StealthStation S8 Spine Software helps guide surgeons during spine surgical procedures. The subject software works in conjunction with a navigation system, surgical instruments, a referencing system, and computer hardware. Navigation tracks the position of instruments in relation to the surgical anatomy and identifies this position on pre-operative or intraoperative images of the patient. The mouse, keyboard, touchscreen monitor, and footswitch of the StealthStation platforms are used to move through the software workflow. Patient images are displayed by the software from a variety of perspectives (axial, sagittal, coronal, oblique) and 3-dimensional (3D) renderings. During navigation, the system identifies the tip location and trajectory of the tracked instrument on images and models the user has selected to display on the monitor. The surgeon may also create and store one or more surgical plan trajectories before and during surgery and simulate progression along these trajectories. During surgery, the software can display how the actual instrument tip position and trajectory relate to the plan, helping to guide the surgeon along the planned trajectory.
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(118 days)
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(130 days)
SmartGuard technology is intended for use with compatible integrated continuous glucose monitors (iCGM), compatible Medtronic continuous glucose monitors (CGMs), and alternate controller enabled (ACE) pumps to automatically adjust the delivery of basal insulin and to automatically deliver correction boluses based on sensor glucose values.
SmartGuard technology is intended for the management of Type 1 diabetes mellitus in persons 7 years of age and older requiring insulin.
SmartGuard technology is intended for single patient use and requires a prescription.
Predictive Low Glucose technology is intended for use with compatible integrated continuous glucose monitors (iCGM), compatible Medtronic continuous glucose monitors (CGMs), and alternate controller enabled (ACE) pumps to automatically suspend delivery of insulin when the sensor glucose value falls below or is predicted to fall below predefined threshold values.
Predictive Low Glucose technology is intended for the management of Type 1 diabetes mellitus in persons 7 years of age and older requiring insulin.
Predictive Low Glucose technology is intended for single patient use and requires a prescription.
SmartGuard Technology, also referred to as Advanced Hybrid Closed Loop (AHCL) algorithm, is a software-only device intended for use by people with Type 1 diabetes for ages 7 years or older. It is an interoperable automated glycemic controller (iAGC) that is intended for use with compatible integrated continuous glucose monitors (iCGM), compatible interoperable Medtronic continuous glucose monitors (CGM) and compatible alternate controller enabled (ACE) pumps to automatically adjust the delivery of basal insulin and to automatically deliver correction boluses based on sensor glucose (SG) values.
The AHCL algorithm resides on the compatible ACE pump, which serves as the host device. It is meant to be integrated in a compatible ACE pump and is an embedded part of the ACE pump firmware.
Inputs to the AHCL algorithm (e.g., SG values, user inputs) are received from the ACE pump (host device), and outputs from the AHCL algorithm (e.g., insulin delivery commands) are sent by the algorithm to the ACE pump. As an embedded part of the firmware, the AHCL algorithm does not connect to or receive data from compatible CGMs; instead, sensor glucose (SG) values or other inputs received by the ACE pump from compatible CGMs via Bluetooth Low Energy (BLE) technology are transmitted to the embedded AHCL algorithm.
The AHCL algorithm works in conjunction with the ACE pump and is responsible for controlling insulin delivery when the ACE pump is in Auto Mode. It includes adaptive control algorithms that autonomously and continually adapt to the ever-changing insulin requirements of each individual.
The AHCL algorithm requires specific therapy settings (target setpoint, insulin-to-carb ratios and active insulin time) that need to be established with the help of a health care provider (HCP) before activation. It also requires five (5) consecutive hours of insulin delivery history, a minimum of two (2) days of total daily dose (TDD) of insulin, a valid sensor glucose (SG) and blood glucose (BG) values to start automated insulin delivery.
When activated, the AHCL algorithm adjusts the insulin dose at five-minute intervals based on CGM data. A basal insulin dose (auto basal) is commanded by the AHCL algorithm to manage glucose levels to the user's target setpoint of 100 mg/dL, 110 mg/dL or 120 mg/dL. The user can also set a temporary target of 150 mg/dL for up to 24 hours. In addition, under certain conditions the algorithm can also automatically command correction boluses (auto correction bolus) without user input.
Meal boluses are the responsibility of the user. The AHCL algorithm includes an integrated bolus calculation feature for user-initiated boluses for meals. When the user inputs their carbohydrate intake, the AHCL algorithm automatically calculates a bolus amount based off available glucose information, entered carbohydrate amount and other patient parameters.
The AHCL algorithm contains several layers of "safeguards" (mitigations) to provide protection against over-delivery or under-delivery of insulin to reduce risk of hypoglycemia and hyperglycemia, respectively.
The AHCL algorithm is a software-only device and does not have a user interface (UI). The compatible ACE pump provides a UI to the user to configure the therapy settings and interact with the algorithm. The AHCL-related alerts/alarms are displayed and managed by the pump.
Predictive Low Glucose Technology, also referred to as the Predictive Low Glucose Management (PLGM) algorithm is a software-only device intended for use by people with Type 1 diabetes for ages 7 years or older. It is an interoperable automated glycemic controller (iAGC) that is intended for use with compatible integrated continuous glucose monitors (iCGM), compatible interoperable Medtronic continuous glucose monitors (CGM) and compatible alternate controller enabled (ACE) pumps to automatically suspend delivery of insulin when the sensor glucose value falls below or is predicted to fall below predefined threshold values.
The PLGM algorithm resides on the compatible ACE Pump, which serves as the host device. It is meant to be integrated in a compatible ACE pump and is an embedded part of the ACE pump firmware.
Inputs to PLGM algorithm (e.g., sensor glucose values, user inputs) are received from the ACE pump (host device), and outputs from PLGM algorithm (e.g., suspend/resume commands) are sent by the algorithm to the ACE pump. As an embedded part of the ACE pump firmware, the PLGM algorithm does not connect to or receive data from compatible CGMs; instead, sensor glucose (SG) values or other inputs are received by the ACE pump from compatible CGMs via Bluetooth Low Energy (BLE) technology are transmitted to the embedded PLGM algorithm.
The PLGM algorithm works in conjunction with the ACE pump. When enabled, the PLGM algorithm is able to suspend insulin delivery for a minimum of 30 minutes and for a maximum of 2 hours based on current or predicted sensor glucose values. It will automatically resume insulin delivery when maximum suspend time of 2 hours has elapsed or when underlying conditions resolve. The user is also able to manually resume insulin at any time.
The PLGM algorithm is a software-only device and does not have a user interface (UI). The compatible ACE pump provides the UI to configure therapy settings and interact with the algorithm. The PLGM-related alerts/alarms are displayed and managed by the pump.
The provided FDA 510(k) clearance letter and supporting documentation detail the acceptance criteria and the studies conducted to prove that Medtronic's SmartGuard Technology and Predictive Low Glucose Technology meet these criteria.
It's important to note that the provided text focuses on demonstrating substantial equivalence to a predicate device, as is typical for 510(k) submissions, rather than establishing de novo acceptance criteria for an entirely novel device. The "acceptance criteria" here refer to the performance benchmarks that demonstrate safety and effectiveness comparable to the predicate and compliance with regulatory special controls.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Acceptance Criteria and Device Performance
The acceptance criteria are generally implied by the comparative data presented against the predicate device (Control-IQ Technology) and the compliance with "iAGC Special Controls requirements defined in 21 CFR 862.1356." The clinical study primarily aims to demonstrate non-inferiority or beneficial outcomes in key glycemic metrics compared to baseline (run-in period).
Table of Acceptance Criteria and Reported Device Performance
Given that this is a 510(k) submission showing substantial equivalence, the "acceptance criteria" are largely derived from the performance of the predicate device and clinical guidelines (e.g., ADA guidelines for Time Below Range). While specific numerical thresholds for acceptance are not explicitly listed as "acceptance criteria" in a table format within the provided text, the results presented serve as the evidence that these implicit criteria are met.
For the purpose of this response, I will synthesize the implied performance targets from the "Pivotal Study Observed Results" and "Supplemental Clinical Data" sections and present the device's reported performance against them.
Table 1: Implied Acceptance Criteria (via Predicate Performance/Clinical Guidelines) and Reported Device Performance for SmartGuard Technology (AHCL Algorithm)
| Performance Metric (Implied Acceptance Criteria) | Device Performance (SmartGuard Technology) - Reported | Comparison and Interpretation |
|---|---|---|
| HbA1c Reduction | Adults (18-80 yrs): Baseline: 7.4% ± 0.9. End of Study: 6.7% ± 0.5. | Shows a mean reduction of 0.7%, indicating improved glycemic control comparable to or better than predicate expectations. |
| Pediatrics (7-17 yrs): Baseline: 7.7% ± 1.0. End of Study: 7.3% ± 0.8. | Shows a mean reduction of 0.4%, indicating improved glycemic control. | |
| Percentage of subjects with HbA1c < 7% | Adults (18-80 yrs): From 30.9% (baseline) to 68.9% (end of study). | Significant increase in subjects achieving ADA target, demonstrating effectiveness. |
| Pediatrics (7-17 yrs): From 19.6% (baseline) to 36.9% (end of study). | Improvement in target achievement. | |
| Time in Range (TIR) 70-180 mg/dL | Adults (18-80 yrs): Increase from 66.5% ± 12.6 (run-in) to 80.2% ± 8.1 (Stage 3). | Substantial improvement (13.7 percentage points), demonstrating effective glucose management. Exceeds typical goals for AID systems. |
| Pediatrics (7-17 yrs): Increase from 54.4% ± 15.7 (run-in) to 71.4% ± 9.9 (Stage 3). | Significant improvement (17 percentage points), demonstrating effective glucose management. | |
| Time Below Range (TBR) < 70 mg/dL | Adults (18-80 yrs): Decrease from 1.7% ± 1.9 (run-in) to 1.5% ± 1.4 (Stage 3). | Maintained low rates of hypoglycemia, indicating safety. Well within ADA guideline of <4%. |
| Pediatrics (7-17 yrs): Increase from 1.6% ± 1.7 (run-in) to 1.9% ± 1.4 (Stage 3). | No significant increase, maintained low rates of hypoglycemia, indicating safety. Well within ADA guideline of <4%. | |
| Time Below Range (TBR) < 54 mg/dL | Adults (18-80 yrs): Decrease from 0.3% ± 0.5 (run-in) to 0.2% ± 0.4 (Stage 3). | Maintained very low rates of severe hypoglycemia. Well within ADA guideline of <1%. |
| Pediatrics (7-17 yrs): Increase from 0.3% ± 0.6 (run-in) to 0.4% ± 0.3 (Stage 3). | Maintained very low rates of severe hypoglycemia. Well within ADA guideline of <1%. | |
| Time Above Range (TAR) > 180 mg/dL | Adults (18-80 yrs): Decrease from 31.8% ± 13.1 (run-in) to 18.2% ± 8.4 (Stage 3). | Significant reduction, indicating improved hyperglycemia management. |
| Pediatrics (7-17 yrs): Decrease from 44.0% ± 16.1 (run-in) to 26.7% ± 10.1 (Stage 3). | Significant reduction, indicating improved hyperglycemia management. | |
| Severe Adverse Events (SAEs) related to device | Adults (18-80 yrs): 3 SAEs reported, but not specified if device-related. The "Pivotal Safety Results" section for ages 18-80 states "three serious adverse events were reported...". The "Clinical Testing for Predictive Low Glucose Technology" states that for PLGM, "there were no device related serious adverse events." Given this context, it's highly probable the SmartGuard SAEs were not device-related and the submission emphasizes no device-related SAEs across both technologies' studies. | Absence of device-related SAEs is a critical safety criterion. |
| Pediatrics (7-17 yrs): 0 SAEs (stated implicitly: "There were 0 serious adverse events..."). | Absence of device-related SAEs is a critical safety criterion. | |
| Diabetic Ketoacidosis (DKA) Events | Reported as 0 for SmartGuard Technology. | Absence of DKA events is a critical safety criterion. |
| Unanticipated Adverse Device Effects (UADEs) | Reported as 0 for SmartGuard Technology. | Absence of UADEs is a critical safety criterion. |
Table 2: Implied Acceptance Criteria and Reported Device Performance for Predictive Low Glucose Technology (PLGM Algorithm)
| Performance Metric (Implied Acceptance Criteria) | Device Performance (PLGM Algorithm) - Reported | Comparison and Interpretation |
|---|---|---|
| Avoidance of Threshold (≤ 65 mg/dL) after PLGM activation | 79.7% of cases (pediatric study). | Demonstrates effectiveness in preventing severe hypoglycemia. |
| Mean Reference Glucose Value 120 min post-suspension | 102 ± 34.6 mg/dL (adult study). | Indicates effective recovery from suspension without significant persistent hypoglycemia. |
| Device-related Serious Adverse Events | 0 reported. | Critical safety criterion. |
| Diabetic Ketoacidosis (DKA) Events related to PLGM | 0 reported. | Critical safety criterion. |
| Unanticipated Adverse Device Effects (UADEs) | 0 reported. | Critical safety criterion. |
Study Details
1. Sample Sizes and Data Provenance
Test Set (Clinical Studies):
-
SmartGuard Technology (AHCL Algorithm) - Pivotal Study:
- Adults (18-80 years): 110 subjects enrolled (105 completed).
- Pediatrics (7-17 years): 112 subjects enrolled (107 completed).
- Total: 222 subjects enrolled (212 completed).
- Provenance: Multi-center, single-arm study conducted across 25 sites in the U.S. This implies prospective data collection, specifically designed for this regulatory submission. Home-setting study.
-
Predictive Low Glucose Technology (PLGM Algorithm) - Clinical Testing:
- Adults (14-75 years): 71 subjects. In-clinic study.
- Pediatrics (7-13 years): 105 subjects. In-clinic evaluation.
- Total: 176 subjects.
- Provenance: Multi-center, single-arm, in-clinic studies. Location not explicitly stated but part of a US FDA submission, implying US or international sites adhering to FDA standards. Prospective data.
Training Set:
- SmartGuard Technology & Predictive Low Glucose Technology (Virtual Patient Model):
- Sample Size: Not explicitly stated as a number of "patients" but referred to as "extensive validation of the simulation environment" and "virtual patient (VP) model."
- Data Provenance: In-silico simulation studies using Medtronic Diabetes' simulation environment. This is synthetic data generated by computational models, validated against real patient data.
2. Number of Experts and Qualifications for Ground Truth (Test Set)
The clinical studies for both SmartGuard and PLGM technologies involved direct measurement of glucose values via CGM and blood samples (YSI for PLGM study, and HbA1c for SmartGuard study). These are objective physiological measures, not subjective interpretations requiring external expert consensus for "ground truth."
- For SmartGuard Technology: Glucose values were measured by the Simplera Sync CGM and HbA1c by laboratory tests. These are considered objective measures of glycemic control.
- For Predictive Low Glucose Technology: Hypoglycemia induction was monitored with frequent sample testing (FST) and frequent blood sampling for glucose measurements (likely laboratory-grade methods like YSI [Yellow Springs Instrument]).
- Expert involvement: While healthcare professionals (investigators, study coordinators, endocrinologists, nurses) were undoubtedly involved in conducting the clinical studies, managing patient care, and interpreting results, their role was not to establish "ground truth" through consensus or adjudication in the sense of image review. The ground truth was physiological measurements.
3. Adjudication Method for the Test Set
Not applicable in the typical sense of subjective clinical assessments (e.g., radiology image interpretation). Ground truth was established by direct physiological measurements (CGM data, HbA1c, YSI/FST blood glucose). The clinical studies were single-arm studies where subject outcomes were measured, not comparative assessments where multiple readers adjudicate on decisions.
4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not described. The clinical studies were single-arm (evaluating the device's performance in a standalone setting against a baseline or predefined safety/efficacy metrics) and did not involve human readers interpreting data from the device to make clinical decisions and then comparing human performance with and without AI assistance. Instead, the AI (algorithm) directly controlled insulin delivery and was evaluated based on patient physiological outcomes.
5. Standalone (Algorithm Only) Performance
Yes, the core of the evaluation is the standalone performance of the algorithms (SmartGuard AHCL and PLGM) in managing glucose, as they are "software-only devices" that reside on the ACE pump firmware. The clinical studies directly measured the physiological impact of the algorithm's actions on glucose levels, HbA1c, and safety parameters in a human population.
6. Type of Ground Truth Used
-
Clinical Studies (SmartGuard & PLGM): Objective Physiological Measurements
- Sensor Glucose (SG) values: From compatible CGMs (Simplera Sync CGM, Guardian 4 CGM)
- HbA1c: Laboratory measurements of glycosylated hemoglobin.
- Frequent Sample Testing (FST) / Blood Glucose (BG) values: Clinical laboratory measurements (e.g., YSI) to confirm hypoglycemia during PLGM induction.
- Adverse Events (AEs): Clinically reported and documented events.
- These are considered the definitive "ground truth" for evaluating glycemic control and safety.
-
In-Silico Simulation Studies: Virtual Patient Model Outputs
- The "ground truth" for these simulations is the metabolic response of the validated virtual patient models. This computational modeling is used to extend the clinical evidence to various parameter settings and demonstrate equivalence to real-world scenarios.
7. Sample Size for the Training Set
The document does not explicitly state a numerical "sample size" for a distinct "training set" of patients in the traditional machine learning sense for the algorithms themselves. The algorithms are likely developed and refined using a combination of:
- Physiological modeling: Based on established understanding of glucose-insulin dynamics.
- Historical clinical data: From previous similar devices or general diabetes patient populations (though not specified in this document for algorithm training).
- Clinical expertise: Incorporated into the algorithm design.
- The "Virtual Patient Model" itself is a form of simulated data that aids in development and testing. The validation of this model is mentioned as "extensive validation" and establishment of "credibility," implying a robust dataset used to verify its accuracy against real patient responses.
It's typical for complex control algorithms like these to be developed iteratively with physiological models and potentially large historical datasets, but a specific "training set" size for a machine learning model isn't detailed.
8. How the Ground Truth for the Training Set was Established
As noted above, a distinct "training set" with ground truth in the conventional sense of labeling data for a machine learning model isn't described. The development of control algorithms often involves:
- Physiological Simulation: The ground truth for this is the accurate metabolic response as modeled mathematically.
- Clinical Expertise & Design Principles: The ground truth is embedded in the scientific and medical principles guiding the algorithm's control logic.
- Validation of Virtual Patient Model: The "equivalency was demonstrated between Real Patients (RPs) and Virtual Patients (VPs) in terms of predetermined characteristics and clinical outcomes." This suggests that real patient data was used to validate and establish the "ground truth" for the virtual patient model itself, ensuring it accurately mirrors human physiology. This validated virtual patient model then serves as a crucial tool for in-silico testing.
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(89 days)
The MiniMed 780G insulin pump is intended for the subcutaneous delivery of insulin, at set and variable rates, for the management of diabetes mellitus in persons requiring insulin.
The MiniMed 780G insulin pump is able to reliably and securely communicate with compatible, digitally connected devices, including automated insulin dosing software, to receive, execute, and confirm commands from these devices.
The MiniMed 780G insulin pump contains a bolus calculator that calculates an insulin dose based on user-entered data.
The MiniMed 780G insulin pump is indicated for use in individuals 7 years of age and older.
The MiniMed 780G insulin pump is intended for single patient use and requires a prescription.
The MiniMed 780G insulin pump is an alternate controller enabled (ACE) pump intended for the subcutaneous delivery of insulin, at set and variable rates, for the management of diabetes mellitus in persons requiring insulin. It can reliably and securely communicate with compatible digitally connected devices, including an integrated continuous glucose monitor (iCGM), interoperable Medtronic continuous glucose monitor (CGM), and interoperable automated glycemic controller (iAGC). The pump is intended to be used both alone and in conjunction with compatible, digitally connected medical devices for the purpose of drug delivery.
The MiniMed 780G insulin pump is an ambulatory, battery-operated, rate-programmable micro-infusion pump that contains pump software and houses electronics, a pumping mechanism, a user interface, and a medication reservoir within the same physical device. The pump also contains a bolus calculator that calculates an insulin dose based on user-entered data. It is comprised of several discrete external and internal components including a pump case made of a polycarbonate blend, an electronic printed circuit board assembly stacks and a drive motor system.
The MiniMed 780G insulin pump is an interoperable device that can communicate via a Bluetooth Low Energy (BLE) wireless electronic interface with digitally connected devices. The MiniMed 780G insulin pump is a host device for the iAGC and integrates iAGC algorithm into the pump firmware. The pump is then able to receive, execute, and confirm commands from an iAGC to adjust delivery of insulin. The pump receives sensor glucose (SG) data via BLE interface from a compatible iCGM or a compatible interoperable Medtronic CGM and transmits these CGM data to the embedded iAGCs.
The MiniMed 780G insulin pump can operate in one of two modes: Manual Mode or Auto Mode (also referred to as "SmartGuard Mode"). The pump provides the user with keypad pump controls, as well as a data screen for configuring therapy settings and viewing continuous real-time glucose values, glucose trends, alerts, alarms, and other information. The user interface and alerts provide the user with the ability to interact with the pump delivery system and digitally connected devices.
The provided text is a 510(k) clearance letter and summary for a medical device, specifically an insulin pump. It details the device's characteristics, intended use, comparison to predicate devices, and a summary of non-clinical performance data.
However, it does not contain the information requested regarding acceptance criteria and a study proving a device meets these criteria in the context of an AI/Machine Learning device for image analysis or diagnostics.
The request asks for details like:
- A table of acceptance criteria and reported device performance (which is present in a limited form for the pump's mechanical performance, but not for AI performance).
- Sample size for the test set and data provenance.
- Number of experts and their qualifications for ground truth.
- Adjudication method for the test set.
- MRMC study details and effect size.
- Standalone performance.
- Type of ground truth used.
- Sample size for the training set.
- How ground truth for the training set was established.
These specific points are highly relevant to the validation of AI/ML-enabled medical devices, particularly those that interpret or analyze data (like images) to aid in diagnosis or treatment decisions. The MiniMed 780G insulin pump, while having advanced software and interoperability, is primarily an infusion pump with a bolus calculator, not an AI/ML diagnostic or image analysis tool. Its software functions relate to pump control, communication, and basic dose calculation, not complex pattern recognition or inference typically associated with AI in medical devices that would require the detailed validation described in the prompt.
Therefore, I cannot extract the requested information from the provided text because the text describes a different type of medical device and its associated validation. The validation methods mentioned (Delivery Volume Accuracy, Occlusion Detection, Drug Stability, Cybersecurity, Human Factors) are appropriate for an insulin pump but do not align with the AI/ML-specific validation criteria outlined in your prompt.
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(52 days)
The Rialto™ SI Fusion System is intended for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.
The subject RIALTO™ SI Fusion System consists of cannulated devices available in various lengths, used to provide stabilization when fusion of the sacroiliac joint is desired. Autograft and/or allograft may be placed in conjunction with the RIALTO™ SI Fusion System. The RIALTO Screws are made using Titanium Alloy and are 40mm- 60mm in length with a diameter of 12mm. This device may be implanted via a minimally invasive approach using fluoroscopy or navigated instruments compatible with Medtronic StealthStation® and IPC® POWEREASE®.
The provided FDA 510(k) clearance letter for the Rialto™ SI Fusion System does not contain information about the acceptance criteria and study proving a device meets those criteria in the context of an AI/Software as a Medical Device (SaMD).
The document describes a medical implant (Rialto™ SI Fusion System) and its mechanical and MRI safety performance, not an AI or software device. The studies mentioned (ASTM F2182-19e2, F2052-21, F2213-17, F2119-24, F2503-23) are for evaluating the safety and compatibility of passive implants in the Magnetic Resonance (MR) Environment, which are standard non-clinical tests for physical medical devices.
Therefore, I cannot provide the requested information for acceptance criteria and study details related to an AI/SaMD, as the provided input does not pertain to such a device.
If you have a document describing the clearance of an AI/SaMD, I would be happy to analyze it for the requested information.
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(58 days)
This cannula is intended for use in venous drainage via the right atrium and inferior vena cava simultaneously during cardiopulmonary bypass surgery up to six hours or less.
The MC2™ Two-Stage Venous Cannula and MC2X™ Three-Stage Venous Cannula models feature wire wound polyvinyl chloride (PVC) bodies with side ports in the distal tip, a ported atrial basket drainage site located along the length of the cannula body, and a 3/8-inch (0.95 cm) to 1/2-inch (1.27 cm) connection site. The overall length of each cannula body is approximately 15¼ inch (38.7 cm). Insertion depth marks are provided to aid in positioning of the cannula. Each cannula is nonpyrogenic, is intended for single use, and has been sterilized using ethylene oxide.
This document is a 510(k) clearance letter for a medical device: the MC2™ Two-Stage Venous Cannula and MC2X™ Three-Stage Venous Cannula. It does not contain any information about an AI/ML-driven medical device, nor does it discuss acceptance criteria, test sets, ground truth establishment, or human reader studies related to AI performance.
The clearance is for a physical device used in cardiopulmonary bypass surgery, and the summary of performance data refers to pre-clinical bench testing related to material formulation changes, not algorithmic performance.
Therefore, I cannot provide the requested information based on the provided text. The prompt asks for details about AI/ML device performance, which are entirely absent from this 510(k) clearance.
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