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510(k) Data Aggregation

    K Number
    K151839
    Manufacturer
    Date Cleared
    2016-09-09

    (431 days)

    Product Code
    Regulation Number
    870.2300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    AMC Health VitalCaregiving System

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

    The AMC Health VitalCaregiving System II ("VitalCaregiving System II") is intended to be used in conjunction with biometric measuring devices, mobile applications and questionnaires to collect and store data, and for clinician scheduled monitoring at home and in non-acute medical facilities. The VitalCaregiving System II securely sends data from a patient monitoring device to a central electronic log of patient information, from which notifications/alerts and reports can be generated and data can be securely viewed by authorized caregivers and patients. Clinicians would then determine how and when to respond to the alerts/notifications and biometric data. For use by adults 18 years and older who do not have an acute care or emergency health care condition.

    • Data can be sent via intranet networks, the internet, landline and cellular telephones and other mobile devices.
      • The software also supports communication between patients and caregivers or researchers, such as bidirectional audio and video e-visits, telephone and mobile text messaging.

    The VitalCaregiving System II is not intended for use in emergency situations or by a patient in an acute care medical facility and is not for active patient monitoring.

    Device Description

    The AMC Health VitalCaregiving System II ("VitalCaregiving System II") is a software only device. VitalCaregiving System II enables clinicians and patients to conduct bidirectional audio-video conversations and collects patient-reported outcomes and self-care activities via assessment questionnaires. Biometric measurements using third party devices can be taken by the patient while being observed over videoconference by a clinician who is located remotely, or measurements can be made by the patient at any time, without being observed by a clinician. Clinicians can also use VitalCaregiving System II to exchange messages with patients by text or telephone.

    The system is indicated when health professionals wish to directly interact with patients via video, voice and/or text, and/or view reports of medical parameters collected from patients with non-acute conditions using remote biometric measuring devices and questionnaires. The AMC system is not intended for use in emergency situations.

    AI/ML Overview

    The provided document is a 510(k) summary for the AMC Health VitalCaregiving System II. It primarily focuses on demonstrating substantial equivalence to predicate devices rather than detailing specific acceptance criteria and a dedicated study proving performance against those criteria. As such, much of the requested information about a specific study proving the device meets acceptance criteria is not present.

    However, I can extract information related to how performance was generally validated.

    Here's the breakdown of available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics like sensitivity, specificity, accuracy, etc. Instead, it states that the device's performance was evaluated by confirming its conformance with specifications through "software verification and validation testing."

    The "Performance" section (page 11) states:
    "The Vital Caregiving System II is a software only device and the validation and verification testing were performed under the company’s Design Control Process. This device meets all necessary software verification requirements in 21 CFR 820.3(z) and (aa) and 820.30(f) and (g), as described in "General Principles of Software Validation; Final Guidance for Industry and FDA Staff." The testing has confirmed the device's conformance with specifications."

    Essentially, the acceptance criterion implicitly is "conformance with specifications" and the reported performance is "testing has confirmed conformance." There are no quantitative metrics or specific performance thresholds provided in this document.

    The "Comparison Table" (page 5) compares the subject device with predicate devices across various functional characteristics. While not a performance metric table, it demonstrates that the subject device either matches or extends the capabilities of the predicates, implying that its performance in these functional areas is at least equivalent.

    Feature/CharacteristicAcceptance Criteria (Implied)Reported Device Performance
    For all functionalitiesConformance with specifications (software verification requirements in 21 CFR 820.3(z), (aa), 820.30(f), (g), and "General Principles of Software Validation; Final Guidance for Industry and FDA Staff")"The testing has confirmed the device's conformance with specifications."
    Intended UseSame as predicate devices"The Vital Caregiving System II has the same intended use as the predicate devices."
    Technological Characteristics & FunctionalityComparable or enhanced compared to predicate devices"The technology and performance characteristics for the Vital Caregiving System II are also the same as the predicate." (Refers to comparison table on page 5)
    Compatibility with Third-Party Devices (example for a few categories)Successful collection and verification of physiological measurements from listed devicesListed a variety of third-party devices from which the VitalCaregiving System II successfully obtains and verifies physiological measurements (e.g., blood pressure, pulse, weight, oxygen saturation, glucose, temperature)
    Successful collection of non-physiological measurements from listed devicesListed a variety of third-party devices from which the VitalCaregiving System II successfully obtains non-physiological measurements (e.g., medication dispensed, PERS unit activated)

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

    This information is not provided in the document. The document refers to "software verification and validation testing" but does not specify the sample size of any data used for these tests, nor its provenance (country of origin, retrospective/prospective).

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

    This information is not provided in the document. The document refers to "conformance with specifications" but does not detail how "ground truth" might have been established for any data used in testing.

    4. Adjudication method for the test set

    This information is not provided in the document.

    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 MRMC comparative effectiveness study was not done or at least not reported in this document. The device is a "software-only device" for data storage, collection, and transmission, and also facilitates communication and e-visits. It is not an AI-assisted diagnostic or interpretive tool where "human readers improve with AI vs without AI assistance" would be a relevant metric.

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

    The document describes the "VitalCaregiving System II" as a "software only device." The performance reported is that "The testing has confirmed the device's conformance with specifications." This implicitly describes the standalone performance of the software in terms of its ability to collect, store, transmit, and display data as per its design. However, there are no specific standalone performance metrics (e.g., accuracy of data transmission, latency) provided.

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

    The document does not explicitly state the "type of ground truth" used for testing. Given that it's a data collection and transmission system, the "ground truth" would likely relate to the accurate capture, storage, and transmission of biometric data from connected devices, and the correct functioning of communication features. This would typically be validated against expected output values or successful communication logs, rather than clinical 'ground truth' in the diagnostic sense.

    8. The sample size for the training set

    This information is not provided in the document. As this is a 510(k) for a data management and communication system built upon established technology, it's unlikely to involve a "training set" in the machine learning context. The validation focuses on software engineering principles and functional testing.

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

    This information is not provided in the document. (Refer to point 8).

    In summary, the provided document is a regulatory submission focused on substantial equivalence and compliance with software validation requirements. It does not contain the detailed clinical or performance study information typically associated with AI/ML diagnostic devices, which would require specific acceptance criteria, test sets, and reader studies. The "study" mentioned generally refers to internal "software verification and validation testing" demonstrating adherence to design specifications and regulatory guidelines for software.

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