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510(k) Data Aggregation

    K Number
    K220254
    Manufacturer
    Date Cleared
    2022-11-30

    (303 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Neurosoft Ltd.

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

    The Neuron-Spectrum-AM system with Neuron-Spectrum.NET software is intended for use as a digital neurophysiological system for recording, processing, and displaying biopotential signals such as Electroencephalography (EEG) and Polysomnography (PSG) derived from Electroencephalography (EEG) by the means of a dedicated software module and dedicated electrodes.

    The device is portable and can register up to 21 EEG channels, 4 polygraphic channels, and 1 direct current channel.

    The device does not provide alarms, does not provide automated event marking and does not provide to the user any diagnostic conclusion about the patient's condition. They are in patient care institutions, diagnostics centers, neurosurgical hospitals, experimental laboratories. The device can also be used as a home use device under supervision of qualified personnel. The patient group includes all ages and sexes.

    Device Description

    The Neuron-Spectrum-AM with Neuron-Spectrum.NET Software (Subject device) is an ambulatory wireless digital neurophysiological device capable of recording, processing, and displaying electroencephalography (EEG), video EEG, long-term monitoring (LTM), and polysomnography (PSG) biopotential signals.

    As listed in Table 1, The NS-AM device comprises an Electronic Unit, a Battery Adaptor, an External Rechargeable Battery Bank, a Carrying Pouch and the Neuron-Spectrum.NET desktop application software. The Neuron-Spectrum.NET Software application was cleared in the Predicate's 510(k) submission (K133995).

    The Subject device supports up to 21 EEG channels, 4 wide-band polygraphic channels, 1 breath channel, and 1 direct current channel for a total of 27 analog input channels.

    The Electronic Unit acquires, records and transmits biopotential signals such electroencephalography (EEG) and polysomnography (PSG). The built-in 2.4GHz Wi-Fi radio allows real-time transfer of the collected biopotential signals to the computer running the Neuron-Spectrum.NET software. The biopotential signals are also recorded onto a removable SD memory card as back up for later post analysis.

    The Electronic Unit includes a front panel ON/OFF power button, a light sensor and a User Interface (UI). The UI consist of a liquid crystal display and three menu navigation buttons. Figure 4 shows the UI main functions. The Electronic Unit can be powered by replaceable internal AA batteries or by the External Rechargeable Battery Bank.

    The Electronic Unit and the External Rechargeable Battery Bank reside side-by-side inside the Carrying Pouch. The pouch is strapped and worn over the patient clothing while in use.

    The Neuron-Spectrum.NET software is a computer application that receives, records, processes, and displays the biopotential signals collected by the electronic unit on the PC display. The main operations provided by the Neuron-Spectrum.NET software are:

    • EEG Acquisition
    • · EEG Review, Editing, Storing, Exporting.
    • EEG Analysis
    • Creation of Exam Reports
    • · Program Setup

    The electronic unit measures (141 H x 96 W x 36 D) mm and weighs about 270 grams. The External Rechargeable Battery Bank unit measures (165 H x 106 W x 25 D) mm and weighs about 570 grams. The combined weight for the electronic unit, the battery adaptor and the External Rechargeable Battery Bank is approximately 880 grams.

    AI/ML Overview

    The provided FDA 510(k) summary (K220254) for the Neurosoft Ltd. Neuron-Spectrum-AM with Neuron-Spectrum.NET Software describes the device and its claimed substantial equivalence to a predicate device (K133995). Given the information, here's a breakdown of the requested details:

    1. Table of Acceptance Criteria and Reported Device Performance

    This 510(k) summary does not explicitly state specific, quantifiable acceptance criteria (e.g., "sensitivity must be > X%") for the device's diagnostic performance, nor does it report specific performance metrics like sensitivity, specificity, accuracy, etc., for the device's clinical efficacy.

    Instead, the acceptance criteria are implicitly met through demonstrating substantial equivalence to a predicate device by showing that it "is as safe, as effective, and performs as well as or better than the Neuron-Spectrum-4/P with Neuron-Spectrum.NET Predicate device".

    The "reported device performance" is focused on passing various non-clinical engineering and software tests to demonstrate this substantial equivalence.

    Acceptance Criteria Category (Implicit)Reported Device Performance (as demonstrated by non-clinical testing)
    Device Safety & Effectiveness (Overall)"The documentation and test results provided... demonstrate that the Neuron-Spectrum-AM with Neuron-Spectrum.NET Software device is as safe, as effective, and performs as well as or better than the Neuron-Spectrum-4/P with Neuron-Spectrum.NET Predicate device."
    BiocompatibilityAll patient-contacting materials (Housing, External Rechargeable Battery Bank, Carrying Pouch) were found to be Biocompatible.
    Electrical SafetyPassed and complies with applicable standards (e.g., IEC 60601-1, IEC 60601-2-26, IEC 60601-2-40, IEC 60601-1-11).
    Electromagnetic Compatibility (EMC)Passed and complies with applicable standards (e.g., IEC 60601-1-2).
    Wireless Coexistence & RFID ImmunityPassed these tests, ensuring proper functioning in environments with other wireless devices.
    Bench Testing (Signal acquisition quality compared to predicate)The summary states that "bench testing concluded that the Subject device meets and complies with the ... bench testing requirements." While specific metrics are not explicitly stated as acceptance criteria, the comparison table implicitly indicates that they were found to be similar or equivalent to the predicate for critical parameters:
    • Input noise EEG: Within 0.5-200 Hz not more than 2 µV (not more than 0.3 µV)
    • Input impedance EEG: Not less than 400 MΩ
    • CMRR: Not less than 100 dB
    • Noise:
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    K Number
    K190703
    Manufacturer
    Date Cleared
    2021-05-22

    (796 days)

    Product Code
    Regulation Number
    882.1870
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Neurosoft Ltd

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

    Neuro-IOM system with Neuro-IOM.NET software is a medical device intended for intraoperative neurophysiologic monitoring: the device provides information to assess a patient's neurophysiological status.

    The system allows to monitor the functional integrity and/or mapping of central and peripheral nervous system including motor and sensory pathways.

    It is provided in III different configurations:

    I. 32/B

    II. 32/S

    III. 16/S

    The system ensures the following IOM modalities: free-run EMG (electromyography), direct nerve stimulation including pedicle screw test, SSEP (somatosensory evoked potentials), MEP (motor evoked potentials), EEG (electroencephalography), AEP (auditory evoked potentials), VEP (visual evoked potentials), direct cortical stimulation. Also the train-of-four (TOF) stimulation is performed.

    The system is not intended to measure the vital signs. It records the data to be interpreted by the neuromonitoring specialist.

    Device Description

    Neuro-IOM system with Neuro-IOM.NET software is a medical device intended for intraoperative neurophysiologic monitoring: the device provides information to assess a patient's neurophysiological status.

    The system allows to monitor the functional integrity and/or mapping of central and peripheral nervous system including motor and sensory pathways. It is provided in III different configurations:

    I.32/B 32/8 II. III. ાર્ભદ્ર

    The system ensures the following IOM modalities: free-run EMG (electromyography), direct nerve stimulation including pedicle screw test, SSEP (somatosensory evoked potentials), MEP (motor evoked potentials), EEG (electroencephalography), AEP (auditory evoked potentials), VEP (visual evoked potentials, direct cortical stimulation. Also, the train-of-four (TOF) stimulation is performed.

    The system is not intended to measure the vital signs. It records the data to be interpreted by the neuromonitoring specialist.

    The systems can be used in operating rooms, intensive care units of different health care facilities (including clinics, hospitals, health centers, ambulance centers, etc.), specialized medical facilities (including prevention centers, medicine centers for emergency, military and medical expertise centers), research and educational medical and biological facilities where the neuromonitoring is required, only by qualified operators who have received training on these devices.

    AI/ML Overview

    The provided text is an FDA 510(k) summary for the Neuro-IOM system. It details the device's technical specifications and compares them to a predicate device (Xltek Protektor 32) to demonstrate substantial equivalence, rather than providing the results of a specific clinical study with defined acceptance criteria and human reader performance.

    Therefore, many of the requested details about acceptance criteria, clinical study design, sample sizes, expert ground truth, and MRMC studies are not present in this document because they are not typically required for a 510(k) clearance based on substantial equivalence for this type of device. The focus is on demonstrating that the new device is as safe and effective as a legally marketed predicate through non-clinical testing and comparison of specifications.

    However, I can extract the information that is available and note what is not provided.


    Acceptance Criteria and Device Performance:

    The document does not present specific "acceptance criteria" for a clinical performance study in the typical sense of metrics like sensitivity, specificity, accuracy, or AUC. Instead, the "acceptance criteria" are implied by the demonstration of substantial equivalence to the predicate device, primarily through comparison of technical specifications and non-clinical performance testing (biocompatibility, electrical safety, EMC, performance tests, and software verification/validation).

    The "reported device performance" is demonstrated by showing that the Neuro-IOM system's technical attributes are either identical or sufficiently similar to the predicate device, or where differences exist, they do not adversely affect safety and effectiveness.

    1. Table of Acceptance Criteria and Reported Device Performance

    As noted, there isn't a direct table of clinical acceptance criteria and performance metrics. Instead, the document provides detailed comparison tables between the subject device (Neuro-IOM system) and the predicate device (Xltek Protektor 32) across various attributes. The acceptance is implied if the differences are found to not adversely affect safety and effectiveness.

    Here's a summary of the technical performance comparison, which serves as the basis for the "acceptance" of substantial equivalence:

    Attribute / CharacteristicNeuro-IOM 16S, 32S, 32B (Submitted Product)Xltek Protektor 32 (Predicate Product)Why the differences do not adversely affect the safety and effectiveness
    Intended UseIntraoperative neurophysiologic monitoring to assess patient's neurophysiological status; monitors functional integrity/mapping of central and peripheral nervous system (motor and sensory pathways). Modalities: free-run EMG, direct nerve stimulation (pedicle screw test), SSEP, MEP, EEG, AEP, VEP, direct cortical stimulation, TOF. Not for vital signs. Records data for neuromonitoring specialist interpretation.Intraoperative neurological monitoring using EEG, EP, EMG, and TcMEP stimulation techniques to help assess a patient's neurological status during surgery. EPWorks software allows manual configuration of parameters and creation of protocols for EEG, EP, EMG, and TcMEP waveforms.Same (Similar overall purpose and modalities)
    Intended UserTrained personnel onlyTrained personnel onlySame
    Device Hardware SetupConnected to PC, not standaloneConnected to PC, not standaloneSame
    Amplifiers - Channels16/3216/32Same
    Amplifiers - Input Impedance>1000 MOhm>100 MOhmHigher impedance for Neuro-IOM improves signal quality; no adverse impact on safety/effectiveness.
    Amplifiers - Common Mode Rejection (CMRR)>90 dB>93 dBSlightly different, but both are high values. No adverse impact on safety/effectiveness (implied).
    Amplifiers - Low Frequency Filters0.2 Hz - 2000 Hz0.1 - 500 HzNeuro-IOM has higher cutoff; effectively cuts off low-frequency oscillations. No adverse impact on safety/effectiveness.
    Amplifiers - High Frequency Filters10 Hz - 4 KHz30 Hz - 15 KHzNeuro-IOM range is sufficient for proper signal recording and eliminates high-frequency interference. Difference negligible to impact safety/effectiveness.
    Amplifiers - Notch Filter50/60 Hz50/60 HzSame
    Amplifiers - Sample Rate50 KHz60 KHzDifference negligible to impact safety/effectiveness.
    Amplifiers - Sensitivity0.05 µV/division to 20 mV/division0.1 µV/division to 5 mV/divisionWider range in Neuro-IOM is favorable, allowing display of lower- and higher-amplitude signals. No adverse impact on safety/effectiveness.
    Amplifiers - Noise Level
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    K Number
    K133995
    Manufacturer
    Date Cleared
    2015-06-19

    (540 days)

    Product Code
    Regulation Number
    882.1400
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    NEUROSOFT LTD

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

    The digital systems Neuron-Spectrum-1, Neuron-Spectrum-2, Neuron-Spectrum-3, Neuron-Spectrum-4 and Neuron-Spectrum- 4/P with Neuron-Spectrum.NET software are intended for use as digital neurophysiological systems intended for recording, processing and display biopotential signals such as Electroencephalography (EEG) and long-latency Evoked Potential (EP). Polysomnography (PSG) derives from Electroencephalography (EEG) by the means of a dedicated software module and dedicated electrodes.

    The devices are portable and can register up to 8 (Neuron-Spectrum-1), 16 (Neuron-Spectrum-2), 19 (Neuron-Spectrum-3), 21 (Neuron-Spectrum-4, Neuron-Spectrum-4/P) EEG channels, 1 (Neuron-Spectrum-1, Neuron-Spectrum-2, Neuron-Spectrum-3 and Neuron-Spectrum-4) or up to 4 polygraphic channels (Neuron-Spectrum-4/P: ECG, EOG), 1 breath channel and 2 direct current channels (Neuron-Spectrum-4/P).

    Neuron-Spectrum.NET includes the Evoked potentials averaging function and Quantitative electroencephalography (qEEG) , including specific parameters such as Rhythmicity, FFT power ratio and amplitude metrics.

    The devices do not provide alarms, do not provide automated event marking and do not provide to the user any diagnostic conclusion about the patient's condition. They are intended for use in the patient care institutions, diagnostics centers, neurosurgical hospitals experimental laboratories and sleep laboratories.The patient group includes all ages and sexes.

    Device Description

    The digital systems Neuron-Spectrum-1, Neuron-Spectrum-2, Neuron-Spectrum-3, Neuron-Spectrum-4 and Neuron-Spectrum- 4/P with Neuron-Spectrum.NET software are intended for use as digital neurophysiological systems intended for recording, processing and display biopotential signals such as Electroencephalography (EEG) and long-latency Evoked Potential (EP). Polysomnography (PSG) derives from Electroencephalography (EEG) by the means of a dedicated software module and dedicated electrodes.

    The devices are portable and can register up to 8 (Neuron-Spectrum-1), 16 (Neuron-Spectrum-2), 19 (Neuron-Spectrum-3), 21 (Neuron-Spectrum-4, Neuron-Spectrum-4/P) EEG channels, 1 (Neuron-Spectrum-1, Neuron-Spectrum-2, Neuron-Spectrum-3 and Neuron-Spectrum-4) or up to 4 polygraphic channels (Neuron-Spectrum-4/P: ECG, EOG), 1 breath channel and 2 direct current channels (Neuron-Spectrum-4/P).

    Neuron-Spectrum.NET includes the Evoked potentials averaging function and Quantitative electroencephalography (qEEG) , including specific parameters such as Rhythmicity, FFT power ratio and amplitude metrics.

    The devices do not provide alarms, do not provide automated event marking and do not provide to the user any diagnostic conclusion about the patient's condition. They are intended for use in the patient care institutions, diagnostics centers, neurosurgical hospitals experimental laboratories and sleep laboratories-The patient group includes all ages and sexes

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the Neurosoft Neuron-Spectrum series of devices (Neuron-Spectrum-1, -2, -3, -4, and -4/P) with Neuron-Spectrum.NET software. The primary purpose of the submission is to demonstrate substantial equivalence to previously cleared predicate devices, rather than to establish new acceptance criteria through a clinical study. Therefore, the document does not contain a typical "acceptance criteria" table with specific performance metrics (e.g., sensitivity, specificity, AUC) and reported device performance against those criteria as would be expected for an AI/ML device seeking de novo authorization or a PMA.

    Instead, the submission focuses on comparing the technological characteristics of the subject device to predicate devices to argue for substantial equivalence. The "acceptance criteria" can be inferred to be that the device performs functionally and safely at least as well as the predicate devices, as demonstrated through technical comparisons and compliance with relevant safety and performance standards.

    Here's an attempt to structure the information based on the provided text, acknowledging the limitations due to the nature of a 510(k) submission primarily focused on substantial equivalence:

    Inferred Acceptance Criteria and Device Performance (Based on Substantial Equivalence to Predicate Devices)

    Criterion CategoryInferred Acceptance Criterion (based on predicate)Device Performance (as stated or implied)
    SafetyCompliance with medical device safety standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-26, IEC 60601-1-1, IEC 62304).The device is in compliance with IEC 60601-1:1988+A1:1991+A2:1995, IEC 60601-1-1:2000, IEC 60601-2-26:2002, IEC 60601-1-2:2007, IEC 60601-1-6-2006 (for subject device), and related predicate standards. "The Neuron-Spectrum-1,2,3,4, 4/P with Neuron-Spectrum.NET is in compliance with both the standards IEC 60601-1-2 and IEC 60601-1 and is safe as the predicate device."
    Effectiveness/ FunctionalityPerformance of core functions for acquiring, processing, and displaying biopotential signals (EEG, EP, PSG) comparable to predicate devices.The device records, processes, and displays biopotential signals like EEG, EP, and PSG. The document provides detailed comparisons of hardware attributes (number of channels, sampling rate, filters, noise, input impedance, signal types recorded) and software functions (EEG review, archiving, quantitative EEG parameters like Rhythmicity, FFT power ratio, amplitude metrics) to predicate devices, asserting that minor differences do not adversely affect safety and effectiveness. "All the necessary performance tests in support of substantial equivalence determination were conducted and documented in section 18 'Performance testing'. The tests demonstrate that the Neuron-Spectrum-1,2,3,4,4/P with Neuron-Spectrum.NET is effective and performs as well as the predicate device."
    No Diagnostic ConclusionThe device does not provide automated diagnostic conclusions about the patient's condition."The devices do not provide alarms, do not provide automated event marking and do not provide to the user any diagnostic conclusion about the patient's condition." This is explicitly stated for both the subject device and some predicate devices.
    Intended Use Environment/UserIntended for use by trained medical staff in patient care institutions, diagnostics centers, neurosurgical hospitals experimental laboratories, and sleep laboratories. Patient group includes all ages and sexes.Consistent with the intended use of predicate devices, targeting trained medical professionals in similar clinical and research environments for all patient demographics. E.g., for Cervello: "The devices are intended to be used by physicians, technicians and other medical professions that are trained in EEG and/or PSG." And for Persyst 12: "This device is intended to be used by qualified medical practitioners who will exercise professional judgment in using the information."

    Study Details:

    The provided document describes a 510(k) premarket notification, which relies on demonstrating substantial equivalence to a legally marketed predicate device, rather than a clinical study establishing new performance claims. Therefore, the details requested about sample sizes, ground truth establishment, expert adjudication, and comparative effectiveness studies are not typically found in this type of submission for this class of device.

    Here's what can be inferred or stated based on the document's content:

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

      • Test Set Description: The document does not describe a clinical test set of patient data used to evaluate the device's performance against specific acceptance criteria. The evaluation is primarily based on technical specification comparisons and compliance with recognized standards (e.g., IEC tests for electrical safety and electromagnetic compatibility).
      • Data Provenance: Not applicable as a traditional clinical test set was not used. The "performance data" refers to validation tests on the device itself (hardware and software) and compliance with standards. The document mentions "Validation tests (Section 16.3), the Software Requirements Specifications (Section 16.4)" but these sections are not provided in the extract.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable. As no clinical test set with ground truth was described for independent device evaluation (beyond the intrinsic safety and performance of the device's components and software features), no experts were involved in establishing ground truth for such a test. The evaluation is against predicate device specifications and regulatory standards.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable as no clinical test set requiring expert adjudication for ground truth was used.
    4. 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 study was done. This device is an Electroencephalograph system for recording, processing, and displaying biopotential signals. It "does not provide alarms, do not provide automated event marking and do not provide to the user any diagnostic conclusion about the patient's condition." Therefore, it does not involve AI for interpretation or diagnostic assistance to human readers, and thus such a study would not be relevant.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • No standalone algorithm performance study was done. The device's software (Neuron-Spectrum.NET) performs functions such as signal acquisition, review, editing, storing, and analysis (including quantitative EEG parameters like Rhythmicity, FFT power ratio, and amplitude metrics). However, the document explicitly states that the device "does not provide to the user any diagnostic conclusion about the patient's condition." Its functions are presented as tools for trained medical professionals, implying a human-in-the-loop workflow, where the human interprets the displayed signals and analysis. The document does not describe autonomous algorithmic diagnostic output.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Not applicable for a clinical test set. The "ground truth" for this submission would relate to whether the device's technical specifications and functional performance meet the engineering and safety standards, and are comparable to predicate devices. This involves engineering measurements and comparisons rather than clinical ground truth diagnoses.
    7. The sample size for the training set:

      • Not applicable. The document does not describe a machine learning algorithm that underwent a training phase with a specific dataset.
    8. How the ground truth for the training set was established:

      • Not applicable, as no training set for a machine learning algorithm is described.
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