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510(k) Data Aggregation

    K Number
    K192732
    Date Cleared
    2020-03-26

    (181 days)

    Product Code
    Regulation Number
    870.1025
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Preventice Technologies, Inc.

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

    The BodyGuardian System detects and monitors cardiac arrhythmias in ambulatory patients, when prescribed by a physician or other qualified healthcare professional. Not for use with patients requiring attended, in-hospital monitoring for life threatening arrhythmias.

    The Preventice BodyGuardian Remote Monitoring System is intended for use with adult and pediatric patients in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug in devices such as ECG sensors, weight scales, blood pressure meters and pulse oximeters, and parameters such as ECG, heart rate, body weight, temperature, respiration rate, blood pressure, and SpO2.

    The Preventice BodyGuardian Remote Monitoring System does not provide any diagnosis.

    Device Description

    Arrhythmia Detector and Alarm; Patient Physiological Monitor (with arrhythmia detection)

    The predicate device's ECG Unit is a small, ambulatory cardiac monitor that records and transmits ECG data. The subject device's ECG Unit is also a small, ambulatory cardiac monitor that records and transmits ECG data.

    Both products, the predicate and subject devices, provide a data hub function that connects to commercially available devices such as weight scales, blood pressure monitors, pulse oximeters, ECG Units and other plug-in devices.

    For both devices, the predicate and subject devices, data is transmitted to an external device or server, depending model. If not a server, this device sends the data to a remote computer server that allows healthcare professionals to access and review the data.

    AI/ML Overview

    This document is a 510(k) summary for the BodyGuardian Remote Monitoring System (K192732). It focuses on demonstrating substantial equivalence to a predicate device (BodyGuardian Remote Monitoring System, K151188) rather than providing detailed acceptance criteria and performance data from a new clinical study.

    Here's an analysis based on the provided text, addressing your points where possible, and noting where information is explicitly stated as not present (e.g., clinical testing was not performed):

    Key Takeaway: The submission relies on non-clinical testing and comparison to a predicate device, asserting that the technology is not new and therefore a clinical study was not necessary. This means many of your requested details about acceptance criteria directly tied to a clinical performance study are not available in this document.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not provide a table of quantitative acceptance criteria for clinical performance (e.g., sensitivity, specificity for arrhythmia detection) because no clinical study was conducted for this submission. The "acceptance criteria" discussed are implicitly related to demonstrating substantial equivalence through non-clinical means.

    The non-clinical "performance testing" mentioned includes:

    • EMC and electrical safety testing
    • Electrical and mechanical safety testing
    • System safety testing
    • Software verification and validation
    • Performance testing (general statement, no specific metrics provided)
    • Predicate device comparison tests
    • Usability Testing
    • Biocompatibility for patient contact materials

    The document states, "We conclude that the results of testing show the Preventice BG RMS to be substantially equivalent to the predicate device." This implies the performance observed during these non-clinical tests met the unstated internal acceptance criteria for substantial equivalence.


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

    • Test Set Sample Size: Not applicable for clinical performance, as "a clinical study was not considered necessary."
    • Data Provenance: Not applicable for clinical performance. The non-clinical tests would have been performed in a lab setting by the manufacturer.

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

    • Not applicable as no clinical study with a test set requiring expert ground truth establishment for arrhythmia detection was performed.

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

    • Not applicable for the same reason as above.

    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:

    • No MRMC or comparative effectiveness study involving human readers and AI assistance was conducted or described. The device's primary function is described as detecting and monitoring, rather than assisting human readers in interpreting images or patterns.

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

    • The document implies the device has an algorithmic component for "detects and monitors cardiac arrhythmias." However, no specific standalone performance metrics (e.g., sensitivity, specificity, accuracy) for this algorithm are provided, nor is a dedicated "standalone study" described in the context of clinical performance. The focus is on the device as a whole system.

    7. The type of ground truth used:

    • For the non-clinical "performance testing," the ground truth would typically be established based on engineering specifications, known signal inputs, and reference standards for electrical, mechanical, and software verification. For biocompatibility, it would be based on ISO standards. For usability, it would involve direct observation and user feedback against defined usability goals. No clinical ground truth (e.g., expert consensus, pathology, outcome data) for arrhythmia diagnosis is mentioned.

    8. The sample size for the training set:

    • Not applicable, as no mention of a training set for an AI/ML algorithm (in the context of clinical performance) is made. The device is referred to using existing technology ("This technology is not new").

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

    • Not applicable for the same reason as above.

    Summary of what the document does state regarding validation:

    The validation for this 510(k) submission primarily relies on:

    • Bench Testing: EMC, electrical/mechanical safety, system safety, software V&V, general performance testing, and predicate device comparison tests.
    • Biocompatibility: Testing to ensure patient contact materials are safe.
    • Quality Assurance Measures: FMEA, Design FMEAs, Performance Requirements Testing (including Final System Verification and Validation Testing), ISO 60601 Testing.
    • Usability Testing: Performed, including a pediatric usability study to show "no new hazards or risk associated with pediatric use."
    • Comparison to Predicate Device (BodyGuardian Remote Monitoring System, K151188): The core argument for substantial equivalence is that the new device has "the same technological characteristics" and "the same intended uses" as the predicate device. "There are no fundamental differences between their technological characteristics."
    • Waiver of Clinical Testing: Explicitly states, "This technology is not new, therefore a clinical study was not considered necessary prior to release. Additionally, there was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. The substantial equivalence of the device is supported by the non-clinical testing."
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    K Number
    K151188
    Manufacturer
    Date Cleared
    2015-09-17

    (136 days)

    Product Code
    Regulation Number
    870.1025
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    PREVENTICE

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

    The BodyGuardian System detects and monitors cardiac arrhythmias in ambulatory patients, when prescribed by a physician or other qualified healthcare professional. Not for use with patients requiring attended, In-hospital monitoring for life threatening arrhythmias.

    The Preventice BodyGuardian Remote Monitoring System is intended for use with adult patients in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters. The Preventice BodyGuardian Remote Monitoring System does not provide any diagnosis.

    Device Description

    The BodyGuardian System detects and monitors cardiac arrhythmias in ambulatory patients, when prescribed by a physician or other qualified healthcare professional. Not for use with patients requiring attended, In-hospital monitoring for life threatening arrhythmias.

    The Preventice BodyGuardian Remote Monitoring System is intended for use with adult patients in clinical and non-clinical settings to collect and transmit health parameters to healthcare professionals for monitoring and evaluation. Health parameters are collected from a variety of commercially available, external plug in devices such as ECG sensors, Weight Scales, Blood Pressure Meters and Pulse Oximeters. The Preventice BodyGuardian Remote Monitoring System does not provide any diagnosis.

    AI/ML Overview

    Here’s an analysis of the provided information regarding the BodyGuardian Remote Monitoring System, focusing on acceptance criteria and study details:

    1. A table of acceptance criteria and the reported device performance

    The provided document does not explicitly state quantitative acceptance criteria or device performance in the typical format of sensitivity, specificity, accuracy, etc., for arrhythmia detection. Instead, it relies on a comparison to predicate devices and results of non-clinical bench testing.

    Therefore, the "acceptance criteria" can be inferred as demonstration of substantial equivalence to predicate devices through various non-clinical tests, ensuring safety and effectiveness.

    Acceptance Criteria (Inferred)Reported Device Performance
    Functional Equivalence to Predicate Devices: The device should perform an equivalent function as the predicate devices in detecting and monitoring cardiac arrhythmias and transmitting health parameters.The BodyGuardian System is stated to have the "same technological characteristics as the predicate devices in that all devices are intended to detect, transmit, and report digital data using similar computerized technology." It also has the "same intended uses as the predicate devices in that all devices are intended for ambulatory monitoring."
    Electrical and Mechanical Safety Testing: The device must meet established safety standards.EMC and electrical safety testing, electrical and mechanical safety testing, and system safety testing were conducted.
    Software Verification and Validation: The software components must be verified and validated.Software verification and validation were performed.
    Performance Testing: The device's overall performance must be acceptable.Performance testing was conducted.
    Predicate Device Comparison Tests: Direct comparison testing against predicate devices.Predicate device comparison tests were conducted.
    Usability Testing: The device must be user-friendly and safe for its intended users.Usability Testing was conducted.
    Wireless Transmission Data Quality and Coexistence: The wireless communication must be reliable and not interfere with other devices.Wireless transmission data quality and wireless coexistence testing were conducted.
    Biocompatibility for Patient Contact Materials: Materials in contact with the patient must be biocompatible.Biocompatibility testing for patient contact materials (Makrolon Versaflex) was performed.
    Quality Assurance Measures: Development process must follow quality standards (e.g., FMEA).Failure Mode Effects Analysis/Hazard Analysis (FMEA) and Design FMEAs for mechanical and RF designs were applied. Performance Requirements Testing including Final System Verification and Validation Testing, ISO 60601 Testing, 3rd Edition were completed.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document explicitly states: "Clinical Testing: This technology is not new, therefore a clinical study was not considered necessary prior to release. Additionally, there was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. The substantial equivalence of the device is supported by the non-clinical testing."

    Therefore, there was no clinical test set (and thus no sample size, data provenance) used to demonstrate the device's performance for arrhythmia detection in this submission. The evaluation was based solely on non-clinical (bench) testing and comparison to predicate devices.

    3. 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 was used to establish ground truth for this submission.

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

    Not applicable, as no clinical test set was used.

    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. No clinical studies, including MRMC studies, were performed or required for this submission. The device is a "Remote Monitoring System" that collects and transmits data; it "does not provide any diagnosis." There is no mention of AI assistance for human readers.

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

    The document does not describe a standalone performance study for an algorithm related to arrhythmia detection. The device is described as a system that "detects and monitors cardiac arrhythmias" and collects data from "ECG sensors," but the validation focuses on the system's overall function and equivalence to predicates, not the independent performance of an arrhythmia detection algorithm against ground truth. Since it states the device "does not provide any diagnosis," it suggests the detection is a flag for healthcare professionals to review, rather than a diagnostic output.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    Not applicable, as no clinical data or ground truth was established for performance evaluation in this submission. The ground truth for the non-clinical testing would have been defined by the test protocols (e.g., simulated signals for electrical safety, known material properties for biocompatibility).

    8. The sample size for the training set

    Not applicable, as no clinical data or machine learning models requiring a training set are described in this submission.

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

    Not applicable, as no training set was used.

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    K Number
    K121197
    Manufacturer
    Date Cleared
    2012-08-10

    (113 days)

    Product Code
    Regulation Number
    870.1025
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    PREVENTICE, INC.

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

    The BodyGuardian System detects and monitors non-lethal cardiac arrhythmias in ambulatory patients, when prescribed by a physician or other qualified healthcare professional. The BodyGuardian System continuously records, stores and periodically transmits the following physiological data to a remote computer server for up to 30 days at a time:
    • ECG
    • Heart rate (including HR variability and HR reliability)
    • Respiration rate
    • Activity

    Device Description

    The BodyGuardian System is an ambulatory cardiac monitoring system prescribed by healthcare providers. It monitors and records a patient's electrocardiographic (ECG) data, heart rate, respiration rate and activity level. The complete system consists of components that collect data, send the data to a remote Preventice computer server, store the data in secure databases, and present the data for review by healthcare professionals.

    AI/ML Overview

    The provided documentation presents a 510(k) summary for the BodyGuardian System. While it lists non-clinical testing performed, it explicitly states "Clinical Testing: Not applicable." Therefore, the document does not contain information about acceptance criteria or a study proving the device meets those criteria based on clinical performance.

    However, based on the provided text, here's what can be extracted regarding the device and its testing:

    1. A table of acceptance criteria and the reported device performance

    The document does not specify quantitative acceptance criteria or detailed reported device performance in terms of clinical accuracy (e.g., sensitivity, specificity for arrhythmia detection) as no clinical testing was deemed applicable.

    However, the "Non-Clinical Testing" section implies performance was evaluated against internal benchmarks or standards during the following:

    Acceptance Criteria (Implied)Reported Device Performance (Implied from non-clinical testing)
    Compliance with EMC and electrical safety standardsPassed EMC and electrical safety testing
    Accurate ECG performanceECG performance testing conducted
    Accurate activity level measurementActivity level measurement validated
    Accurate respiration rate measurementRespiration rate measurement validated
    Software functions correctly and reliablySoftware verification and validation completed
    Biocompatibility of materialsBiocompatibility testing conducted

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    Not applicable, as no clinical test set was used for performance evaluation according to the document. The non-clinical testing would have used internal test samples, but details on their size or provenance are not provided.

    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 clinical test set with expert-established ground truth was used for performance evaluation.

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

    Not applicable, as no clinical test set was used.

    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 document states "Clinical Testing: Not applicable," which means no MRMC study, human-in-the-loop performance, or AI assistance was evaluated in a clinical context.

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

    The document implies standalone testing of components like "ECG performance," "Activity level measurement," and "Respiration rate measurement" during non-clinical testing. However, this is not a comprehensive "standalone" evaluation of the arrhythmia detection algorithm in a clinical context, as clinical testing was not applicable. Details of these individual test methodologies and results are not provided.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the non-clinical tests, the ground truth would have been established through controlled electrical signals, mechanical simulations, reference devices, or chemical analysis, depending on the specific test (e.g., calibrated ECG simulators for ECG performance, known activity levels for activity validation). However, the document does not specify these details.

    8. The sample size for the training set

    Not applicable. The document does not describe the development or training of an AI/ML algorithm that would require a training set in the context of clinical performance. The "software verification and validation" would have involved internal testing against coding standards and functional requirements, but not a "training set" in the machine learning sense.

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

    Not applicable, as no training set (for AI/ML algorithm) is mentioned or implied.

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