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510(k) Data Aggregation

    K Number
    DEN230046
    Date Cleared
    2024-08-01

    (398 days)

    Product Code
    Regulation Number
    866.6085
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Personal Genome Diagnostics, Inc.

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

    PGDx elio plasma focus Dx is a qualitative next generation sequencing-based in vitro diagnostic device that uses targeted high throughput hybridization-based capture technology for detection of single nucleotide variants (SNVs), insertions and deletions (indels), copy number amplifications (CNAs), and translocations in human genomic circulating cell-free DNA (cfDNA) on the Illumina NextSeq 550Dx instrument. PGDx elio plasma focus Dx utilizes cfDNA from plasma of peripheral whole blood collected in Streek Cell-Free DNA blood collection tubes (BCTs). PGDx elio plasma focus Dx is a tumor mutation profiling test intended to provide information on mutations to be used by qualified health care professionals in accordance with professional. guidelines in oncology for cancer patients with solid malignant neoplasms. The test is for use with patients previously diagnosed with cancer and in conjunction with other laboratory and clinical findings. A negative result from a plasma specimen does not assure that the patient's tumor is negative for genomic findings. Genomic findings are not prescriptive or conclusive for use of any specific therapeutic product.

    Device Description

    The PGDx elio plasma focus Dx assay is a hybrid-capture, next generation sequencing (NGS)based in vitro diagnostic assay (IVD) for the qualitative reporting of sequence mutations (SNVs and indels) in 33 genes, translocations in 3 genes, and amplifications in 5 genes. The assay consists of library preparation and sample indexing reagents. PGDx elio platform software, and a server inclusive of all essential data analysis software. The input of the test is cfDNA extracted from blood collected in the Streck Cell-Free DNA BCT using the OIAGEN OIAamp DSP Circulating NA Kit. The blood collection and DNA extraction materials are required but not supplied with the PGDx elio plasma focus Dx assay. Extracted cfDNA is used to prepare an indexed, targeted DNA library suitable for NGS on an Illumina NextSeq 550Dx instrument qualified by PGDx. Data analysis occurs on a dedicated server running the PGDx elio plasma focus Dx software that performs demultiplexing, alignment, variant calling, and filtering to generate reports containing detected and reportable alterations.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally framed around Positive Percent Agreement (PPA) and Negative Percent Agreement (NPA) compared to orthogonal methods, as well as satisfactory performance in areas like Limit of Detection (LoD), Limit of Blank (LoB), and reproducibility.

    Acceptance Criteria CategorySpecific CriteriaReported Device PerformanceComments
    Accuracy (PCCPTerms)Accuracy point estimates of ≥ 90% PPA and ≥ 95% NPA for SNVs and indels when considering variants at or above LoD of the PGDx elio plasma focus Dx only. Accuracy point estimates of ≥ 60% PPA and ≥ 95% NPA for all SNVs and indels irrespective of variant level.Variants ≥ LoD of Orthogonal Method:
    • SNVs/indels with Clinical Significance in Plasma: 97.6% - 100% PPA, 99.9% NPA
    • SNVs/indels with Clinical Significance in Tissue: 95.7% PPA, 99.99% NPA
    • SNVs/indels with Potential Clinical Significance: 94.3% PPA, 99.99% NPA
      All Variants (Primary Analysis):
    • SNVs/indels with Clinical Significance in Plasma: 63.8% - 100% PPA, 99.6% - 100% NPA
    • SNVs/indels with Clinical Significance in Tissue: 60.5% PPA, 99.99% NPA
    • SNVs/indels with Potential Clinical Significance: 53.4% PPA, 99.99% NPA | Device meets and often exceeds these criteria for variants at or above LoD. Lower PPA for "all variants" is acknowledged and attributed to variants below LoD. |
      | Accuracy (PCCPTerms) | Accuracy point estimates of ≥ 80% PPA and ≥ 95% NPA for copy number amplifications and translocations when considering variants at or above LoD of the PGDx elio plasma focus Dx only. Accuracy point estimates of > 60% PPA and > 95% NPA for all copy number amplifications and translocations irrespective of variant level. | Variants ≥ LoD of Orthogonal Method:
    • Amplifications (CCND1, CD274, ERBB2, FGFR2, MET): 65.6% - 100% PPA, 99.4% - 99.8% NPA
    • Translocations (ALK, NTRK1, RET): 75% - 92.3% PPA, 99.63% - 100% NPA
      All Variants (Primary Analysis):
    • Amplifications: 57.9% - 100% PPA, 99.3% - 99.8% NPA
    • Translocations: 50% - 92.9% PPA, 99.63% - 100% NPA | Device meets and often exceeds these criteria for variants at or above LoD of the orthogonal method. |
      | False Positive Rate (FPR) | 95% PPA for mutation positive samples with alteration at 1-1.5x LoD and > 95% NPA for mutation negative samples for precision evaluation (PCCP terms) | Interlaboratory Reproducibility (at 1-1.5x LoD):
    • Clinical Blends (Plasma): 97.2% PPA
    • Cell Line Blends: 90.3% PPA
      End-to-end Precision (at >1x LoD):
    • SNVs: 97.4% APA
    • Indels: 100.0% APA
    • Aggregate variants: 97.8% APA
    • All structural variants: 100% APA
      Lot-to-Lot Precision:
    • SNVs: 90.5% PPA
    • Deletions: 86.6% PPA
    • Amplifications & Translocations: 100% PPA | PPA for 1-1.5x LoD is generally >95% for clinical samples but slightly lower for cell-line blends in interlaboratory. End-to-end and lot-to-lot also demonstrate high agreement. |
      | Interfering Substances | Assay results robust in presence of interfering substances. | Across 11 potential interferents (16 conditions), concordance of variant calls was ≥92.6% PPA and ≥99.9% NPA. Overall success rate ≥ 85.7%, with 2 failures attributed to operator error. | Performance demonstrated as robust. |
      | Hybrid Capture Probe Specificity | Probes uniquely map to intended targets, with off-target hits showing low mapping quality. Minimal risk of false positives from mis-mapping. | 97.1% of probes uniquely mapped. Zero of simulated off-target reads mapped to on-target positions. | Demonstrated high specificity. |
      | DNA Input Robustness | Performance maintained across reasonable DNA input variations. | PPAs >96% and NPAs ≥99.9% across input levels for clinical plasma samples (5ng - 50ng LP, 150ng - 600ng CAP). Overall success rate >47.5%, with failures at very low input (5ng LP) impacting cell lines. | Robust performance around the recommended 25ng input. Acknowledged reduced performance at very low inputs. |
      | Assay Guard Banding | Robustness to variations in assay protocol (volume/time for reagents). | PPAs >94% and NPAs >99.9% for all test conditions, except -25% ligation master mix (PPA 88.6%). Supplemental study improved -15% ligation to 93.2% PPA. | Generally robust, with one identified sensitivity point (Ligation Master Mix volume) leading to a precaution in labeling. |
      | Whole Blood Stability | Performance maintained after storage in BCTs under varying conditions. | PPAs 100% and NPAs ≥99.9% across storage conditions (Room Temp, Summer, Winter for 8 days). Overall success rates >86.7%, with failures attributed to low cfDNA yield from patient. | Blood stable for 7 days in Streck cfDNA BCTs. |
      | Plasma Stability | Performance maintained after storage of isolated plasma. | PPAs 95.0% - 100% and NPAs ≥99.9% across storage conditions (25 hours at 2-8°C, 46 days at -80°C, 1 year at -80°C). Overall success rates >92%. | Plasma stable for up to 1 year at -80°C. |
      | cfDNA Stability | Performance maintained after storage of isolated cfDNA. | Modal PPA ≥ 93% and modal NPA ≥ 99% for 3.5 months at -20°C. PPAs 93.1% - 97.1% for up to >250 days. | cfDNA stable for extended periods at -20°C. |
      | Sample Carryover and Cross-Contamination | No evidence of carryover or cross-contamination. | No evidence of contamination in 100% of mutation-negative samples within and between sequencing runs. | Demonstrated to be contamination-free. |
      | Lot Interchangeability | Performance maintained after exchanging reagents between unique lots. | PPA > 91% and NPA ≥ 99.9% across all aggregated variant types. | Reagents from different lots are interchangeable. |
      | Lane Combination | Performance maintained when using filling material for partial batches. | 100% PPA and ≥ 99.99% NPA for all variants at all lane ratio test conditions. | Device performs consistently even with partial batch filling. |
      | BCT Incomplete Mixing & Underfilled Tube | Performance maintained with variations in mixing and filling of BCTs. | PPAs 100% and NPAs >99% for all conditions except 5mL underfilled tube (73.3% success rate). | Performance maintained for proper usage, but a limitation for underfilled tubes is noted. |
      | BCT Lot-to-Lot Reproducibility | Consistent performance across different BCT lots. | APA between and within lots >93% and ANA ≥99%. | Consistent performance across BCT lots. |
      | BCT Concordance | Concordance between Streck cfDNA BCTs and BD Vacutainer K2 EDTA BCTs. | PPA 95.8% and NPA 99.9% for aggregated variant types. | High concordance between BCT types. |

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

    • Test Set (Accuracy Study):
      • Clinical Plasma Specimens: 931 samples across 35 solid tumor types (e.g., NSCLC, Colorectal, Breast, etc.).
      • Contrived Samples: 48 samples (34 spiked cell lines, 13 spiked cell line blends, 1 clinical plasma blend).
      • Total Samples Assessed: 979 (785 passed QC for both PGDx elio plasma focus Dx and at least one orthogonal method).
      • Data Provenance: The text does not explicitly state the country of origin for the clinical samples. It mentions "clinical plasma specimens," implying human-derived samples. It appears to be retrospective as samples were compared to "orthogonal methods" which are likely established assays already used for patient variant detection. The "Orthogonal Method" results served as the reference standard.
      • LoB Study (Test Set):
        • Cohort 1: 29 normal plasma specimens (tested in duplicate)
        • Cohort 2: 38 normal plasma specimens (tested singularly)
        • Total unique donors: 67
        • Data Provenance: Healthy donors (no cancer diagnosis). Retrospective.
      • LoD Study (Test Set):
        • 11 cell line blends (dilution series, 10 replicates at 5 levels)
        • Clinical plasma blends (20 unique pools, 10 replicates, 2 reagent lots)
        • Data Provenance: Contrived and clinical plasma samples.

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

    The ground truth for the test set (accuracy study) was established by orthogonal methods, not directly by human experts reviewing the PGDx elio plasma focus Dx results. The orthogonal methods themselves would have undergone their own validation processes, which may or may not have involved expert review for their initial validation. The text does not specify the number of experts or their qualifications who established the ground truth for these orthogonal methods.

    4. Adjudication Method for the Test Set

    The primary method for establishing ground truth was comparison to orthogonal methods.

    • Concordance Assessment: Reference status was assigned to each variant based on the orthogonal method.
    • The comparisons were made between the PGDx elio plasma focus Dx output and the orthogonal methods. There is no mention of an "adjudication panel" or specific adjudication method (e.g., 2+1, 3+1) being used to resolve discrepancies between the PGDx elio plasma focus Dx and the orthogonal methods, or between multiple orthogonal methods (though one instance mentions a second orthogonal method was used when a discrepancy occurred for NTRKI translocation).

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The performance evaluation focuses on the analytical performance of the device itself (standalone) against orthogonal methods, not on how human readers' performance might improve with or without AI assistance from this specific device.

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

    Yes, a standalone study was done. The entire "Analytical Performance" section (VI.A) describes the performance of the PGDx elio plasma focus Dx assay, which is a "next generation sequencing based tumor profiling assay" with automated data analysis software. The evaluation metrics (PPA, NPA, LoD, LoB, reproducibility) are all measures of the assay's ability to detect genetic variants autonomously. There is no mention of human-in-the-loop performance in any of the analytical or clinical validation sections.

    7. The Type of Ground Truth Used

    The primary type of ground truth used was:

    • Orthogonal Methods: For the accuracy study, variants detected by established and validated independent assays served as the reference.
    • Known Mutations in Cell Lines/Blends: For LoD and reproducibility studies, where contrived samples (cell line DNA spiked into plasma) were used, the "expected variants" in these materials were the ground truth.
    • Absence of Mutations in Healthy Donors: For LoB studies, a "mutation negative" status based on pre-screening with an externally validated orthogonal method or sequencing of matched buffy coat (to exclude CHIP and germline variants) was used as ground truth.
    • Modal Status: For precision/reproducibility studies across replicates, the majority call (modal status) served as a form of internal reference to assess consistency.

    8. The Sample Size for the Training Set

    The document does not explicitly describe a separate "training set" for the PGDx elio plasma focus Dx algorithm. Phrases like "Metrics were first established and optimized using well-characterized cell lines with known variants. Once initial thresholds were established, clinical samples were run through the assay to measure device performance prior to assay lock and the commencement of analytical performance testing" imply an internal development and optimization phase. However, a distinct, quantified "training set" with specific sample sizes for algorithm development (in the machine learning sense) is not provided. The study design focuses on the analytical validation (test set) of the final locked assay.

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

    As noted above, a formal "training set" is not explicitly defined. However, the initial establishment and optimization of metrics involved:

    • Well-characterized cell lines with known variants: This implies that for initial parameter tuning and threshold setting, variants in these cell lines were used as ground truth, likely established through extensive prior characterization (e.g., Sanger sequencing, other NGS methods, etc.).
    • Clinical samples for initial performance measurement: These samples would have had ground truth established by orthogonal methods, similar to the main accuracy study.
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    K Number
    K192063
    Date Cleared
    2020-04-24

    (267 days)

    Product Code
    Regulation Number
    866.6080
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Personal Genome Diagnostics

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

    The PGDx elio™ tissue complete assay is a qualitative in vitro diagnostic device that uses targeted next generation sequencing of DNA isolated from formalin-fixed, paraffin-embedded tumor tissue from patients with solid malignant neoplasms to detect tumor gene alterations in a broad multi-gene panel.

    PGDx elio tissue complete is intended to provide tumor mutation profiling information on somatic alterations (SNVs, small insertions and deletions, one amplification and four translocations), microsatellite instability (MSI) and tumor mutation burden (TMB) for use by qualified healthcare professionals in accordance with professional guidelines in oncology for previously diagnosed cancer patients, and is not conclusive or prescriptive for labeled use of any specific therapeutic product.

    Device Description

    PGDx elio tissue complete is an in vitro diagnostic assay that uses NGS to detect turnor gene alterations in genomic DNA isolated from formalin-fixed, paraffin-embedded (FFPE) tumor tissue from a variety of tumor types, using a targeted panel (505 genes). The assay takes less than 7 days from DNA to report and provides information on single nucleotide variants (SNVs) in a range of GC content and genomic contexts, insertion/ deletions (indels), 1 amplification as well as 4 translocations. It also identifies microsatellite instability based on select mononucleotide tracts and signatures of sequence mutations. The PGDx elio tissue complete assay utilizes a ~1.3 Mb region of interest (ROI) to calculate tumor mutation burden (TMB).

    AI/ML Overview

    The provided text describes the analytical validation studies for the PGDx elio tissue complete assay, a qualitative in vitro diagnostic device for tumor profiling.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

    1. Table of Acceptance Criteria & Reported Device Performance

    The acceptance criteria are generally established as target performance metrics (e.g., call rates, concordance rates, %CV, false positive rates). The reported device performance is the outcome of the analytical studies.

    Performance Metric CategorySpecific Metric (Acceptance Criteria Implicitly Defined by Study Design/Results)Reported Device Performance
    SpecificityFalse Positive Rate (SNVs and Indels)99.9%
    TMB Mean Absolute Percent Error (MAPE) vs. 100 ng1.8% to 11.8%
    Contamination ControlAbsence of false positives in negative samples from carryover/cross-contaminationNo positive variant results observed in known negative samples.
    Exogenous InterferenceConcordance (PPA) with interfering substances vs. baseline> 97.2%
    Concordance (NPA) with interfering substances vs. baseline> 99.9%
    TMB MAPE with interfering substances0% to 6.0%
    Overall Sample Acceptance RateFirst Pass Rate81.8% (2352/2874)
    Overall Pass Rate (allowing single repeat)92.9% (2671/2874)
    Accuracy (Concordance to Orthogonal Methods)PPA/NPA for various variant types (SNVs, indels, amplifications, translocations)See Table 1.10 for detailed SNV/Indel PPAs (range 80.8% - 100%) and NPAs (all 99.9% or 100%)
    ERBB2 Amplifications: PPA 75.0% (all cases), 87.0% (excluding borderline); NPA 96.7% (all cases), 95.9% (excluding borderline)
    ALK Translocations: PPA 92.9%; NPA 98.2%
    RET Translocations: PPA 55.6%; NPA 100%
    TMB: Spearman correlation coefficient 0.903 vs WES
    MSI: Overall PPA 98.8% (excluding failures), 94.0% (accounting for failures); NPA 99.3% (excluding failures), 77.6% (accounting for failures)
    Interlaboratory ReproducibilityFirst Pass Rate90.3% (455/504)
    Overall Pass Rate98.2% (495/504)
    Overall Positive Call Rate (All Variants)86.2%
    APA (all variants)> 92%
    ANA (all variants)> 99%
    TMB %CV3.5%
    Lot to Lot PrecisionAPA (Variants with Evidence of Clinical Significance)96.1% to 98.7%
    ANA (Variants with Evidence of Clinical Significance)99.8% to 99.9%
    TMB %CV40 tumor types.
    • Accuracy: 582 samples with PGDx elio tissue complete data and orthogonal data. Specifically:
      • SNVs/Indels: 582 samples.
      • ERBB2 Amplifications (FISH comparison): 147 cases (all); 120 cases (excluding borderline).
      • ALK Translocations (FISH comparison): 71 cases. Additional in silico simulation on 10 clinical samples (410 observations).
      • RET Translocations (FISH comparison): 27 cases. 3 RET translocation-positive cell lines also tested.
      • TMB: 118 cases across 8 tumor types.
      • MSI: 283 samples across 18 tumor types.
      • Wild Type Calls: 112 specimens.
    • Interlaboratory Reproducibility: 13 FFPE tissue specimens and 1 cell line (14 samples total), tested in duplicate by 2 operators on 12 sequencing runs across 3 non-consecutive days at 3 independent laboratory sites (504 total replicates).
    • Lot to Lot Precision: 5 test cases in triplicate across 3 unique kit lots (45 observations).

    Data Provenance: The document does not explicitly state the country of origin for the clinical samples. However, it mentions "clinical FFPE specimens," implying real-world patient data. The studies are described in a factual manner, suggesting they are retrospective analyses of collected samples for analytical validation purposes.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    The document does not specify the number or qualifications of experts involved in establishing the ground truth for the test set.

    Instead, the ground truth for performance evaluation (accuracy) is established by:

    • Orthogonal methods:
      • "2 NGS targeted panels" and "PCR" (for SNVs and Indels).
      • "ERBB2 FISH," "ALK FISH," "RET FISH" (for amplifications and translocations).
      • "matched tumor-normal whole exome sequencing results" (for TMB).
      • "MSI PCR" (for MSI).
    • Validated assays/literature: For the 3 RET translocation-positive cell lines.

    4. Adjudication Method for the Test Set

    The document does not describe any expert adjudication process for resolving discrepancies or establishing ground truth for the test set. The ground truth is primarily based on the results from the orthogonal methods. For the in silico studies, the ground truth is derived from down-sampling "clinical samples."

    5. MRMC Comparative Effectiveness Study

    No multi-reader multi-case (MRMC) comparative effectiveness study was mentioned or performed. This device is a molecular diagnostic assay, not an imaging AI tool, and thus comparative effectiveness with human readers improving with AI assistance is not applicable in this context.

    6. Standalone Performance

    Yes, the entire document describes studies of the standalone (algorithm only, without human-in-the-loop performance) of the PGDx elio tissue complete assay. The goal is to demonstrate the analytical performance of the automated workflow, from sample preparation to data analysis and variant calling, against established ground truth methods.

    7. Type of Ground Truth Used

    The primary type of ground truth used is orthogonal methods, specifically:

    • Other NGS targeted panels: For SNVs and indels.
    • PCR: For certain SNVs/indels and MSI.
    • FISH (Fluorescence In-Situ Hybridization): For gene amplifications (ERBB2) and translocations (ALK, RET).
    • Whole Exome Sequencing (WES): For Tumor Mutation Burden (TMB).
    • Cell line characterization/literature: For known variants in control cell lines.

    This is a form of reference standard ground truth, where the device's performance is compared against established, validated measurement techniques.

    8. Sample Size for the Training Set

    The document details analytical validation (testing) and reproducibility studies. It does not provide information about a "training set" size. As a molecular diagnostic assay, its development likely involves internal data for algorithm development and optimization, but specific training set sizes are not mentioned in this regulatory submission, which focuses on validation data.

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

    Since the document does not discuss a specific "training set" or its size, it also does not describe how ground truth for such a set was established. The focus is on the performance of the final, locked-down algorithm against independent test data with ground truth established by orthogonal methods.

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