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510(k) Data Aggregation
(149 days)
TELCARE, INC.
Telcare Blood Glucose Monitoring System: The Telcare Blood Glucose Monitoring system is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips, forearm, or palm. It is intended for lay use by persons with diabetes to aid in diabetes management. It is indicated for use at home (over the counter [OTC]) and should be used only by a single patient and should not be shared. Testing is done outside the body (in vitro diagnostic use). The Telcare Blood Glucose Monitoring System consists of the Telcare Blood Glucose Meter, Telcare Blood Glucose Test Strips, and Telcare Glucose Control Solutions. The Telcare Blood Glucose Monitoring system is not indicated for the diagnosis or screening of diabetes or for neonatal use. Palm and forearm testing should be done only during steady-state times when glucose is not changing rapidly. The Telcare Blood Glucose Meter uses cellular data transmission to send test results to Telcare's remote database, Telserve, and to receive messages from Telserve. The Telcare Blood Glucose Monitoring System is not intended to provide automated treatment guidance or decisions, nor is it to be used as a substitute for professional healthcare judgment.
Telcare Blood Glucose Test Strips: The Telcare Blood Glucose Test Strips are to be used with the Telcare Blood Glucose Meter for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips, palm, or forearm. These test strips are intended for lay use by persons with diabetes and should only be used by a single patient. They are not indicated for the diagnosis or screening of diabetes or for neonatal use. Palm and forearm testing should be done only during steady-state times when glucose is not changing rapidly.
Telcare Glucose Control Solutions: The purpose of the control solution test is to validate the performance of the Telcare Blood Glucose Monitoring System by using a test solution with a known amount of glucose. A control test that falls within the acceptable range indicates the user's technique is appropriate and the test strip and meter are functioning properly.
Telserve Data Management System - Home Use: The Telserve Data Management System - Home Use (Telserve - Home) is an accessory to blood glucose monitoring systems for the review and evaluation of blood glucose test results to aid in diabetes management. Telserve collects data from blood glucose meters such as the Telcare BGM. Telserve - Home is not intended to provide automated treatment guidance or decisions, nor is it to be used as a substitute for professional healthcare judgment.
Telserve Data Management System - Professional Use: The Telserve Data Management System - Professional Use (Telserve - Pro) is an accessory to blood glucose monitoring systems for the review and evaluation of blood glucose test results to aid in diabetes management. Telserve collects data from blood glucose meters such as the Telcare BGM.
The Telcare Blood Glucose Monitoring System consists of the Telcare Blood Glucose Meter (BGM), Telcare Blood Glucose Test Strips, and Telcare Glucose Control Solutions. The Telcare BGM, when used with the Telcare Test Strips, quantitatively measures glucose in capillary whole blood. The Telcare Control Solutions verify the performance of the Telcare Test Strips. An embedded cellular module within the Telcare BGM enables wireless communication between the meter and Telcare's remote database, called the Telserve Data Management System (Telserve).
The Telserve Data Management System serves as an accessory to blood glucose meters to assist in the review and evaluation of blood glucose test results and related information to aid in diabetes management. The software system consists of two different levels of functionality: 1) Telserve Data Management System - Home Use and 2) Telserve Data Management System - Professional Use.
The Telcare Blood Glucose Monitoring System consists of a Blood Glucose Meter (BGM), Test Strips, Control Solutions, and the Telserve Data Management System (Home Use and Professional Use). The acceptance criteria and supporting studies are described below:
1. Table of Acceptance Criteria and Reported Device Performance:
The provided 510(k) summary does not explicitly state numerical acceptance criteria for the quantitative performance of the Telcare Blood Glucose Monitoring System (e.g., accuracy percentages for glucose levels). Instead, it lists various non-clinical and clinical tests performed, with a general statement that "All testing demonstrated safety and effectiveness of the Telcare Blood Glucose Monitoring system and substantial equivalence to the predicate." and "The results show Telcare BGM System and Telserve showed substantial equivalence to the predicate devices."
Therefore, for the purpose of this response, the "acceptance criteria" are inferred to be the successful completion of the listed tests and the demonstration of substantial equivalence to predicate devices. The "reported device performance" is the claim of achieved substantial equivalence.
Acceptance Criteria (Inferred from testing performed) | Reported Device Performance (Claimed in the 510(k) Summary) |
---|---|
Non-Clinical (Telcare BGM System) | |
Minimum Sample Volume met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Linearity met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Detection Limit met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Precision met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Hematocrit effects within acceptable limits | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Altitude effects within acceptable limits | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Humidity/Temperature effects within acceptable limits | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Interfering Substances effects within acceptable limits | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Control Solution Qualification met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
EMC, Electrical Safety, and FCC standards met | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Software verification and validation completed (Telcare BGM) | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Non-Clinical (Telserve Data Management System) | |
Software verification and validation completed (Telserve) | Demonstrated safety and effectiveness; substantial equivalence to predicate. |
Clinical (Telcare BGM System) | |
Ease of use of Telcare BGM (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Ease of understanding Telcare BGM user manual (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Accuracy and user performance with fresh fingertip, palm, and forearm testing | Demonstrated substantial equivalence to predicate devices. |
User control solution testing success | Demonstrated substantial equivalence to predicate devices. |
Ease of use of Telcare BGM Test Strip Insertion Process (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Ease of understanding Telcare BGM Test Strip Insertion instructions (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Clinical (Telserve Data Management System) | |
Ease of use of Telserve-Home and user manual (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Ease of obtaining login credentials for Telserve-Home (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
Ease of use of Telserve-Pro, obtaining login credentials, and user manual (User Performance Study) | Demonstrated substantial equivalence to predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance:
The provided 510(k) summary does not specify the exact sample sizes for the test sets in the clinical studies. It only mentions that "A User Performance Study was conducted..." and "An Accuracy and User Performance Study was conducted..." without detailing the number of participants or samples.
The data provenance (e.g., country of origin of the data, retrospective or prospective) is also not explicitly stated. However, given that this is a 510(k) submission to the FDA, it is highly likely that the studies were conducted in the United States, and typically, such performance studies for medical devices are prospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
The 510(k) summary does not provide information on the number or qualifications of experts used to establish ground truth for the clinical studies, particularly for the "Accuracy and User Performance Study." For blood glucose monitoring systems, ground truth for accuracy is typically established by laboratory reference methods (e.g., YSI analyzer) performed by trained laboratory personnel, rather than "experts" in the sense of clinicians providing a diagnosis.
4. Adjudication Method for the Test Set:
The 510(k) summary does not describe any adjudication method for the test set in the clinical studies. This is generally not applicable to studies for blood glucose meters where the output is a quantitative measurement compared against a reference method.
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:
A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The device is a blood glucose monitoring system, not an AI-assisted diagnostic imaging or interpretation tool where human readers assess cases. The "Telserve" component is a data management system, not an AI for interpretation or diagnosis, and the studies described are user performance and accuracy for the meter itself.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done:
A "standalone" study in the sense of an algorithm-only performance for a diagnostic AI was not performed because this device is a blood glucose monitoring system, which provides direct measurements. The "Telserve Data Management System" is software for data handling, not an analytical algorithm for standalone diagnostic performance beyond displaying the meter's results. The accuracy studies for the BGM are inherently standalone for the device's measurement capability.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.):
For the "Accuracy and User Performance Study" conducted for the Telcare BGM, the ground truth for glucose measurements would typically be established using a laboratory reference method (e.g., a YSI glucose analyzer) on venous blood samples, which is considered the gold standard for clinical chemistry. The 510(k) summary does not explicitly state the reference method used but this is standard practice for glucose meter accuracy studies.
8. The Sample Size for the Training Set:
The provided 510(k) summary does not mention any "training set" or "training data" as would be relevant for machine learning or AI algorithm development. The device described, particularly the Blood Glucose Monitoring System, is a traditional electrochemical biosensor device. The Telserve Data Management System is software for data management, not an AI system that undergoes a separate training phase.
9. How the Ground Truth for the Training Set Was Established:
This question is not applicable as there is no mention of a "training set" in the context of AI or machine learning for this device in the provided summary. The device's components (meter, strips, control solutions) are tested for their inherent performance and accuracy against established analytical methods and user performance metrics, not through a machine learning training paradigm.
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