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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.

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.

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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