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510(k) Data Aggregation

    K Number
    K220582
    Manufacturer
    Date Cleared
    2022-08-22

    (174 days)

    Product Code
    Regulation Number
    892.5050
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ClearCalc Model RADCA V2

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

    ClearCalc is intended to assist radiation treatment planners in determining if their treatment planning calculations are accurate using an independent Monitor Unit (MU) and dose calculation algorithm.

    Device Description

    The ClearCalc Model RADCA V2 device is software that uses treatment data, image data, and structure set data obtained from supported Treatment Planning System and Application Programming interfaces to perform a dose and/or monitor unit (MU) calculation on the incoming treatment planning parameters. It is designed to assist radiation treatment planners in determining if their treatment planning calculations are accurate using an independent Monitor Unit (MU) and dose calculation algorithm.

    AI/ML Overview

    The provided text describes ClearCalc Model RADCA V2 and its substantial equivalence to predicate devices. However, the document does NOT contain a detailed study proving the device meets specific acceptance criteria in the manner of a clinical trial or a performance study with detailed statistical results. Instead, it states that "Verification tests were performed to ensure that the software works as intended and pass/fail criteria were used to verify requirements. Validation testing was performed to ensure that the software was behaving as intended, and results from ClearCalc were validated against accepted results for known planning parameters from clinically-utilized treatment planning systems."

    Therefore, I can provide the acceptance criteria as stated for the ClearCalc Model RADCA V2's primary dose calculation algorithms and the monte carlo calculations, but comprehensive study details such as sample size, data provenance, expert ground truth, adjudication methods, or separate training/test sets are not available in the provided text.

    Here's a summary of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Calculation AlgorithmAcceptance CriteriaReported Device Performance
    FSPB (Photon Plans)Passing criteria consistent with Predicate Device ClearCalc Model RADCAPassed in all test cases
    TG-71 (Electron Plans)Passing criteria consistent with Predicate Device ClearCalc Model RADCAPassed in all test cases
    TG-43 (Brachytherapy Plans)Passing criteria consistent with Predicate Device ClearCalc Model RADCAPassed in all test cases
    Monte Carlo CalculationsGamma analysis passing rate of >93% with +/-3% relative dose agreement and 3mm Distance To Agreement (DTA)Passed in all test cases

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

    • Sample Size: Not explicitly stated. The text mentions "all test cases" without quantifying the number of cases.
    • Data Provenance: Not explicitly stated. The text refers to "known planning parameters from clinically-utilized treatment planning systems," suggesting the data would be representative of clinical use but does not specify country of origin or if it's retrospective or prospective.

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

    • Number of Experts: Not specified.
    • Qualifications of Experts: The ground truth was established from "accepted results for known planning parameters from clinically-utilized treatment planning systems." This implies that the ground truth is derived from established clinical practices and systems, which are typically validated by qualified medical physicists and radiation oncologists, but specific expert involvement in this validation is not detailed.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

    • Adjudication Method: Not specified. The validation relies on comparison to "accepted results."

    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:

    • MRMC Study: No. The device is a "Secondary Check Quality Assurance Software" designed to assist radiation treatment planners by providing independent calculation. It does not involve human readers making diagnoses or interpretations that would be augmented by AI in a MRMC study context.

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

    • Standalone Performance: Yes, the described verification and validation tests assess the algorithm's performance against "accepted results" from clinical systems, which is a standalone evaluation.

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

    • Ground Truth Type: "Accepted results for known planning parameters from clinically-utilized treatment planning systems." This implies a form of established, clinically validated ground truth based on the outputs of other (predicate/reference) treatment planning systems the device is checking.

    8. The sample size for the training set:

    • Training Set Sample Size: Not specified. The text focuses on verification and validation testing, not on the training of the underlying algorithms.

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

    • Training Set Ground Truth: Not specified. As the document focuses on validation rather than algorithm training, this information is not provided.
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    K Number
    K193640
    Device Name
    ClearCalc
    Manufacturer
    Date Cleared
    2020-04-09

    (104 days)

    Product Code
    Regulation Number
    892.5050
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ClearCalc

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

    ClearCalc is intended to assist radiation treatment planners in determining if their treatment planning calculations are accurate using an independent Monitor Unit (MU) and dose calculation algorithm.

    Device Description

    The ClearCalc device (model RADCA) is software intended to assist users in determining if their treatment planning calculations are accurate using an independent Monitor Unit (MU) and dose calculation. The treatment plans are obtained from supported Treatment Planning System and Application Programming interfaces. It is designed to run on the Windows Operating System. ClearCalc performs calculations on the treatment plan data obtained from supported Treatment Planning System and Application Programming interfaces. A Treatment Planning System is software used by trained medical professionals to install and simulate radiation therapy treatments for malignant or benign diseases.

    AI/ML Overview

    The provided document describes the Radformation ClearCalc device (K193640), a software intended to assist radiation treatment planners in determining the accuracy of their treatment planning calculations.

    Here's an analysis of the acceptance criteria and the study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state quantitative acceptance criteria or a direct comparison of ClearCalc's performance against such criteria in a tabular format. Instead, it focuses on demonstrating substantial equivalence to a predicate device, RadCalc (K090531), through a comparison of technological characteristics and functionalities.

    The "Performance Data" section (5.7) states:
    "As with the Predicate Device, no clinical trials were performed for ClearCalc. Verification tests were performed to ensure that the software works as intended and pass/fail criteria were used to verify requirements."

    This indicates that internal verification tests were conducted, likely against pre-defined pass/fail criteria for the software's functionality and accuracy in calculating Monitor Units (MU) and dose. However, the specific metrics, thresholds, and numerical results of these tests are not provided in this document.

    The "Substantial Equivalence ClearCalc vs. RadCalc" table (Table 3) highlights functional similarities and minor differences, which implicitly form the basis of the performance evaluation for regulatory submission.

    ParameterAcceptance Criteria (Implicit from Predicate Comparison)Reported Device Performance (ClearCalc)
    Photon MU and Dose Calculation- Utilize an independent calculation algorithm to recalculate MU/Dose on a per-field basis.
    • Provide accurate MU/Dose calculations for external beam radiation therapy.
    • Account for patient geometry and heterogeneity corrections. | - Utilizes a Finite-Size Pencil Beam (FSPB) algorithm to calculate MU/Dose on a per-field basis.
    • Utilizes the full 3D geometry of the patient for heterogeneity corrections and simulating scatter conditions.
    • Calculates dose from fields in a plan and displays results for per-field MU and provides a difference metric for evaluation in tabular format.
    • Allows evaluation of global point doses, as well as per-field doses.
      (No specific accuracy numbers or pass/fail thresholds are provided in this document, but implied to be sufficient based on "works as intended" and comparison to predicate.) |
      | Electron MU and Dose Calculation | - Utilize an independent calculation algorithm to recalculate MU/Dose on a per-field basis.
    • Provide accurate MU/Dose calculations for electron external beam radiation therapy.
    • Account for custom cutouts and compute cutout factors. | - Utilizes a library of custom cutouts and computes cutout factors using a sector integration method.
    • Calculates dose based on electron field parameters and cutout geometry, and displays results for per-field MU and dose and provides a difference metric for evaluation in tabular format.
      (No specific accuracy numbers or pass/fail thresholds are provided, implied to be sufficient.) |
      | Brachytherapy Dose Calculation | - Utilize an independent calculation algorithm to recalculate dose from radioactive sources.
    • Adhere to a recognized protocol (e.g., AAPM TG-43) for brachytherapy dose calculations.
    • Provide dose calculations to arbitrary points and difference metrics. | - Utilizes the AAPM TG-43 protocol for its brachytherapy dose calculations.
    • Calculates dose to arbitrary calculation point locations and presents difference metrics comparing the TPS dose vs. ClearCalc dose in a tabular format.
      (No specific accuracy numbers or pass/fail thresholds are provided, implied to be sufficient.) |
      | Overall Functionality | - Software works as intended without errors.
    • Provides reliable independent verification of treatment planning calculations. | - "Verification tests were performed to ensure that the software works as intended and pass/fail criteria were used to verify requirements." (No specific details on test outcomes or criteria provided).
    • "Verification and Validation testing and Hazard Analysis demonstrate that ClearCalc is as safe and effective as the Predicate Device."
      (Implied successful performance under internal testing). |

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

    The document does not specify the sample size used for the test set or the data provenance (e.g., country of origin, retrospective/prospective). It only mentions "Verification tests were performed to ensure that the software works as intended".

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

    The document does not mention using experts to establish ground truth for a test set. The performance evaluation seems to be based on internal verification against expected computational outcomes, rather than expert-derived ground truth from patient cases.

    4. Adjudication Method

    The document does not mention any adjudication method, as no expert review or consensus process for ground truth establishment is described.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    An MRMC comparative effectiveness study was not performed or described in the document. The device is a "standalone" software tool for verifying treatment plans, and its primary function is independent calculation, not assisting human readers in interpreting images or making diagnostic/treatment decisions that would typically be evaluated with MRMC studies.

    6. Standalone Performance Study

    A standalone performance study of the algorithm (i.e., algorithm only without human-in-the-loop performance) was performed implicitly through "Verification tests." The document states, "Verification tests were performed to ensure that the software works as intended and pass/fail criteria were used to verify requirements." However, concrete details, metrics, and quantitative results of this standalone performance are not provided. The entire submission focuses on demonstrating substantial equivalence, implying that its standalone performance would be comparable to the predicate device's independently calculated MU/dose values.

    7. Type of Ground Truth Used

    The type of ground truth used appears to be calculated ground truth or computationally derived truth. The ClearCalc software performs calculations based on established physics principles (Finite-Size Pencil Beam algorithm, AAPM TG-43 protocol) to verify the output of a primary Treatment Planning System (TPS). The "ground truth" for the verification tests would logically be the expected accurate MU/dose values as determined by these internal algorithms and validated against known calculation methodologies, rather than pathology, outcomes data, or expert consensus from clinical cases.

    8. Sample Size for the Training Set

    The document does not mention a training set sample size. This suggests that the ClearCalc software likely relies on deterministic algorithms (e.g., Finite-Size Pencil Beam, AAPM TG-43) which are coded based on physical models and parameters, rather than being "trained" on a dataset in the manner of machine learning algorithms.

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

    Since a training set is not mentioned, the method for establishing its ground truth is not applicable/not provided. The device's functionality is based on direct implementation of physics models and calculations.

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