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510(k) Data Aggregation
(127 days)
The ScottCare Corporation
The TeleRehab® Aermos Cardiopulmonary Rehabilitation System is intended to acquire and condition the ECG signal from a patient so that it can be transmitted wirelessly from a radiofrequency transmitter to a workstation in a hospital or a clinical setting where the data is displayed and analyzed. This device also measures heart rate and provides visual and audible alarms if the patient's heart rate goes out of a prescribed range. This device is for use with ambulatory adult patients who need monitoring while undergoing cardiovascular and/or pulmonary rehabilitation. The physiological data from monitoring and other patient information (such as patient demographics, exercise protocol and medical information) is stored in a database for tracking and reporting of the patients' progress through rehabilitation.
The TeleRehab® Aermos Cardiopulmonary Rehabilitation System ("Aermos") provides the ECG monitoring functionality required for performing rehabilitation of cardiovascular and/or pulmonary patients. Patients' ECG may be monitored using the Aermos system during exercise under clinical supervision. During monitoring, Aermos provides both visual and audible alarms if the patient's heart rate goes out of a prescribed range. The heart rate alarm indication is one of multiple inputs a clinician may use to modify and adjust rehabilitation activities such as decreasing the patient's level of physical exertion or halting the exercise entirely.
Aermos also provides the ability to plan a patient's rehabilitation program and document the patient's progress through the creation of various types of reports. The report types supported in Aermos include individual treatment plan reports, daily exercise session reports and various patient information reports. Additionally, the Aermos system provides the ability to transfer various report types to the hospital Electronic Medical Records system.
The main components of Aermos are Argus ECG transmitters, the Aermos Workstation and associated networking equipment.
This FDA 510(k) clearance letter pertains to the TeleRehab Aermos Cardiopulmonary Rehabilitation System, which is a device for monitoring ECG signals and heart rate during patient rehabilitation. The provided documentation (the 510(k) Summary) details non-clinical bench testing for performance and safety but explicitly states that clinical testing was not applicable.
Therefore, based on the provided document, the following information regarding acceptance criteria and a study that proves the device meets those criteria, specifically concerning an AI/algorithm-driven component with clinical performance metrics, cannot be fully extracted or is explicitly stated as not performed:
Here's an analysis of the provided information relative to your request:
Acceptance Criteria and Device Performance (Based on Non-Clinical Bench Testing)
Since no clinical study was performed, the "reported device performance" would pertain to the results of non-clinical bench testing against established performance standards. The document does not provide specific quantitative acceptance criteria or reported numerical performance results for the device. Instead, it states that the device's specifications were "verified through internal verification testing" and its usability "evaluated through internal validation testing," and that it complies with various international standards.
Acceptance Criteria Category | Acceptance Criteria (General, Inferred from Standards Compliance) | Reported Device Performance |
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ECG Signal Acquisition | Compliance with IEC 60601-2-27 (electrocardiographic monitoring equipment) for frequency response and dynamic range. | Verified through compliance with IEC 60601-2-27. Specific values (e.g., 0.05 - 100 Hz, ±5.0 mV) are stated as specifications but detailed test results against specific acceptance criteria for these are not provided in this summary. |
Heart Rate Measurement | Accurate heart rate calculation. | Part of ECG signal processing; compliance with IEC 60601-2-27 implies performance. Exact accuracy metrics not reported. |
Alarm Functionality | Visual and audible alarms for out-of-range heart rate; compliance with IEC 60601-1-8 (alarm systems). | Compliance with IEC 60601-1-8 for alarm systems. |
Wireless Transmission | Reliable and safe wireless data transmission (WiFi); compliance with ANSI C63.27 and IEC 60601-1-2. | Verified through compliance with ANSI C63.27 and IEC 60601-1-2, and applicable FDA guidance/consensus documents for RF wireless and cybersecurity. |
Software Functionality | Software verification, validation, and adherence to FDA guidance for device software functions (Enhanced Documentation level). | Software V&V conducted at unit, integration, system levels, documentation as per FDA guidance (June 2023). |
Cybersecurity | Compliance with FDA guidance on cybersecurity in medical devices. | Complete risk-based cybersecurity assessment and testing performed per FDA guidance (Sept. 2023). |
Cleaning & Disinfection | Verification and validation of cleaning and disinfection processes. | Internal and external testing performed as per FDA guidance (March 2015). |
General Safety & Performance | Compliance with IEC 60601-1 (general safety), IEC 60601-1-6 (usability), ISO 14971 (risk management), etc. | Compliance with a comprehensive list of IEC, ANSI/AAMI, and ISO standards is reported. |
Study Details (Based on the provided 510(k) Summary)
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A table of acceptance criteria and the reported device performance:
- See the table above. Specific quantitative acceptance criteria beyond "compliance with standard" are not provided in this regulatory summary.
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Sample size used for the test set and the data provenance:
- The document explicitly states "Clinical Testing: Not applicable."
- For the non-clinical bench testing, specific sample sizes (e.g., number of devices tested, number of test cases) are not detailed in this 510(k) summary.
- Data provenance for non-clinical testing would typically be internal laboratory data generated during device development and verification. There is no mention of geographical origin or retrospective/prospective nature as this was not clinical data.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable, as no clinical study with human interpretation/ground truth was performed. The "ground truth" for bench testing would be defined by validated test equipment and reference standards.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable, as there was no study involving human readers or interpretation requiring adjudication.
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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, as clinical testing was "Not applicable." The device is a physiological signal monitor, not an AI-assisted diagnostic tool that interprets images or signals requiring human reader comparison.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The core functionality of the device (ECG acquisition, heart rate measurement, alarms) is algorithmic. The performance of these algorithms would have been assessed during the non-clinical bench testing, which is essentially "standalone algorithm" testing against known inputs and expected outputs. Specific quantitative results (e.g., algorithm accuracy for heart rate) are not provided in this summary beyond "compliance with IEC 60601-2-27" and "ANSI/AAMI EC57: 2012, Testing and Reporting Performance Results of Cardiac Rhythm and ST-Segment Measure Algorithms."
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For non-clinical bench testing, the "ground truth" is typically established by:
- Reference standards and calibrated test equipment: For electrical performance, signal acquisition accuracy, frequency response, etc.
- Simulated physiological signals: For testing heart rate calculation and alarm thresholds.
- Design specifications and established engineering principles: For software functionality and cybersecurity.
- For non-clinical bench testing, the "ground truth" is typically established by:
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The sample size for the training set:
- Not applicable. The device is a monitoring system and not primarily driven by a deep learning or machine learning algorithm that requires a "training set" in the sense of a large dataset for model development. The algorithms for heart rate calculation, etc., are likely traditional signal processing algorithms.
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How the ground truth for the training set was established:
- Not applicable, as there was no training set for a machine learning model.
Summary of Device Nature and Regulatory Pathway:
The TeleRehab Aermos Cardiopulmonary Rehabilitation System is a Class II device (Product Codes DRG, DRT) which functions as a physiological signal transmitter and receiver. It monitors ECG and heart rate and provides alarms. Its 510(k) clearance relied on demonstrating substantial equivalence to predicate devices primarily through non-clinical bench testing against recognized industry standards (e.g., IEC 60601 series, ANSI/AAMI, ISO standards) and adherence to FDA guidance documents (e.g., for software, cybersecurity, reprocessing). The explicit statement "Clinical Testing: Not applicable" indicates that the nature of the device and its intended use, combined with the comprehensive non-clinical data, satisfied the FDA's requirements for demonstrating safety and effectiveness without the need for a human-subject clinical study. This is common for devices that are evolutionary improvements on existing technologies with well-understood performance parameters.
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