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510(k) Data Aggregation

    K Number
    K180684
    Manufacturer
    Date Cleared
    2018-04-19

    (35 days)

    Product Code
    Regulation Number
    864.7750
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    CoaguChek XS Plus System

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

    The CoaguChek XS Plus system is intended for use by professional healthcare providers for quantitative prothrombin time testing for the monitoring of warfarin therapy. The system uses fresh capillary or non-anticoagulated venous whole blood.

    Device Description

    No technological, material, performance, or design changes to the CoaguChek XS Plus System have been implemented since its clearance on K071041. Thus, the device description for the CoaguChek XS Plus System remains the same as that presented and cleared in K071041. This submission deals only with the performance of Super Sani-Cloth wipes for the effective cleaning and disinfection of the CoaguChek XS Plus System housing and components.

    AI/ML Overview

    The provided document describes a Special 510(k) submission for extending cleaning and disinfection claims for the CoaguChek XS Plus System to include "Super Sani-Cloth" wipes.

    Here's an analysis of the acceptance criteria and study for the device based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    Super Sani-Cloth wipes are effective for cleaning and disinfection of the device.The corresponding test results on the device components demonstrate that the Super Sani-Cloth wipes are effective for the cleaning and disinfection of the device.
    The device must meet performance requirements for its intended use after being subjected to cleaning and disinfection with Super Sani-Cloth.Robustness and effectiveness cleaning and disinfecting testing on the CoaguChek XS Plus System for Super Sani-Cloths demonstrated that the device meets the performance requirements for its intended use. Overall, the data demonstrate that the CoaguChek XS Plus System operates in the same manner when cleaning and disinfecting occurs with the Super Sani-Cloth wipes.
    Neither meter accuracy nor meter functionality should be impacted by the cleaning and disinfection procedure over the device's lifetime. (Implicit: the device should continue to accurately measure prothrombin time and function correctly.)Acceptance criteria were met when testing with venous blood the CoaguChek XS Plus meters that had been subjected to 10,950 Cleaning and Disinfection (C&D) cycles representing three-years lifetime of the meter based on a testing frequency of 10 tests per day. Neither meter accuracy nor meter functionality were impacted by the cleaning and disinfection procedure.

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

    • Sample Size: The document mentions that the CoaguChek XS Plus meters were subjected to 10,950 Cleaning and Disinfection (C&D) cycles. This number represents the simulated lifetime (three years at 10 tests/day) of the cleaning/disinfection robustness. The number of actual meters tested (i.e., the sample size of the devices themselves) is not explicitly stated. However, it implies testing was performed on at least one or more devices to generate this data.
    • Data Provenance: Not specified, but the context is an FDA submission from Roche Diagnostics, implying internal testing conducted by the manufacturer. The document does not mention the country of origin of the data or whether it was retrospective or prospective. It is implied to be prospective testing carried out for this submission.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts:

    • Not Applicable. This study is focused on the robustness of the device itself to a cleaning and disinfection process, not on diagnostic performance where expert interpretation of results would be required to establish ground truth. The 'ground truth' here is the continued accurate function and performance of the instrument.

    4. Adjudication Method for the Test Set:

    • None. Adjudication methods like 2+1 or 3+1 are used in studies involving human interpretation or subjective assessments. This study evaluates the objective performance (accuracy and functionality) of a medical device after a specific treatment (cleaning/disinfection).

    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:

    • Not Applicable. This is not an AI-assisted diagnostic device, nor is it a study involving human readers.

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

    • Yes, in the sense that the device's performance was evaluated standalone. The study assessed the inherent accuracy and functionality of the CoaguChek XS Plus System after cleaning with Super Sani-Cloth wipes. There's no human-in-the-loop variable being tested here; it's about the device's physical and operational integrity.

    7. The Type of Ground Truth Used:

    • The ground truth used is the inherent accurate measurement capability and continued functionality of the CoaguChek XS Plus System before and after repeated cleaning and disinfection cycles. This is established by comparing the device's performance (specifically, meter accuracy) using venous blood measurements against established standards or baseline performance, and verifying that its functionality (e.g., ability to power on, display results, etc.) remains intact.

    8. The Sample Size for the Training Set:

    • Not Applicable. There is no "training set" for this type of robustness study. The study involves demonstrating that the already cleared device, K071041, maintains its performance after being subjected to a specific cleaning agent. It's not a machine learning or AI algorithm that requires training data.

    9. How the Ground Truth for the Training Set was Established:

    • Not Applicable. As there is no training set, there is no ground truth established for one.
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    K Number
    K071041
    Manufacturer
    Date Cleared
    2007-05-11

    (29 days)

    Product Code
    Regulation Number
    864.7750
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    COAGUCHEK XS PLUS SYSTEM

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

    The CoaguChek XS Plus System is intended for use by professional healthcare providers for quantitative prothrombin time testing for the monitoring of warfarin therapy. The system uses fresh capillary or non-anticoagulated venous whole blood.

    Device Description

    The CoaguChek XS Plus system is a portable coagulation monitoring system to monitor prothrombin time (PT) in patients receiving oral anticoagulant therapy. The system uses the amperometric detection of thrombin in the blood sample. A test strip is used to determine a PT value from 10 uL of whole blood. Onboard quality control is available on every test strip and the system also features an optional external quality control material (CoaguChek XS PT Control).

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the CoaguChek XS Plus System, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not explicitly state "acceptance criteria" as a separate, quantified set of thresholds for each performance metric. Instead, it presents performance characteristics (e.g., accuracy, precision) of the new CoaguChek XS Plus System and compares them directly to the predicate device (CoaguChek XS System) to demonstrate substantial equivalence. The implication is that the performance of the new device is comparable to, or as good as, the predicate device.

    Performance MetricAcceptance Criteria (Implied: Comparable to Predicate)CoaguChek XS Plus System PerformancePredicate Device (CoaguChek XS) Performance
    Accuracy (Venous Blood vs. Lab Reference)Comparable to PredicateN = 811
    Slope = 1.090
    Intercept = -0.2
    Correlation = 0.974N = 710
    Slope = 1.034
    Intercept = -0.02
    Correlation = 0.974
    Accuracy (Capillary Blood vs. Lab Reference)Comparable to PredicateN = 822
    Slope = 1.075
    Intercept = -0.1
    Correlation = 0.972N = 700
    Slope = 1.006
    Intercept = 0.032
    Correlation = 0.971
    Whole Blood Precision (Venous)Comparable to PredicateN = 399
    Mean INR = 2.32
    SD = 0.046
    CV = 2.00N = 357
    Mean INR = 2.59
    SD = 0.06
    CV = 2.42
    Whole Blood Precision (Capillary)Comparable to PredicateN = 399
    Mean INR = 2.26
    SD = 0.077
    CV = 3.39N = 344
    Mean INR = 2.59
    SD = 0.11
    CV = 4.35
    Control Precision (Level 1)Comparable to PredicateN = 538
    Mean INR = 1.18
    SD = 0.04
    CV = 3.37N = 54
    Mean INR = 1.20
    SD = 0.01
    CV = 1.1
    Control Precision (Level 2)Comparable to PredicateN = 535
    Mean INR = 2.95
    SD = 0.12
    CV = 4.10N = 54
    Mean INR = 2.49
    SD = 0.06
    CV = 2.3
    Hematocrit RangeNot significantly affect test results for 25-55%Does not significantly affect test results for 25-55%Same
    BilirubinNo significant effect up to 30 mg/dLNo significant effect up to 30 mg/dLSame
    Triglyceride (Lipemic samples)No significant effect up to 500 mg/dLNo significant effect up to 500 mg/dLSame
    HemolysisNo significant effect up to 1000 mg/dLNo significant effect up to 1000 mg/dLSame
    HeparinUnaffected up to 0.8 U/mLUnaffected up to 0.8 U/mLSame
    Low Molecular Weight HeparinInsensitive up to 2 IU anti-factor Xa activity/mLInsensitive up to 2 IU anti-factor Xa activity/mLSame
    Measuring Range0.8 to 8.0 INR0.8 to 8.0 INRSame

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

    • Accuracy (Venous Blood): N = 811
    • Accuracy (Capillary Blood): N = 822
    • Whole Blood Precision (Venous): N = 399
    • Whole Blood Precision (Capillary): N = 399
    • Control Precision (Level 1): N = 538
    • Control Precision (Level 2): N = 535

    Data Provenance: The document does not explicitly state the country of origin or if the data was retrospective or prospective. Given the nature of a 510(k) submission for a medical device that measures PT, these are typically prospective clinical studies conducted in a controlled environment to evaluate immediate device performance.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    The document refers to "lab reference" for accuracy studies. This implies that standard laboratory methods for Prothrombin Time testing were used as the gold standard. However, it does not specify the number or qualifications of experts involved in performing these reference tests or establishing the ground truth. It's likely that certified medical laboratory technologists or similar professionals performed these reference tests.

    4. Adjudication Method for the Test Set

    Not applicable. This device measures a quantitative value (INR). Adjudication methods like 2+1 or 3+1 are typically used for qualitative or subjective assessments where multiple readers might interpret findings, for example, in image-based diagnostics. For quantitative measurements compared to a lab reference, such adjudication is not generally needed.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC comparative effectiveness study was not done. The CoaguChek XS Plus System is a device designed for quantitative measurement of prothrombin time, not for subjective interpretation by multiple readers like an imaging device. Therefore, the concept of human readers improving with or without AI assistance is not directly applicable in this context.

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

    Yes, the studies reported are standalone performance studies of the device. The "System Performance Characteristics" section reports the accuracy and precision of the CoaguChek XS Plus System itself, comparing its measurements to a "lab reference" or evaluating its internal consistency. This is the device's inherent performance without human interpretation influencing the final reported value beyond the act of operating the device and performing the test.

    7. The Type of Ground Truth Used

    The ground truth used for accuracy studies was a "lab reference." This indicates that the device's PT/INR measurements were compared against results obtained from established, likely hospital- or clinical laboratory-based reference methods for Prothrombin Time determination. This would typically involve trained technicians using calibrated laboratory instruments.

    8. The Sample Size for the Training Set

    The document does not provide information about a "training set" or its sample size. This is typical for a 510(k) submission for a device like the CoaguChek XS Plus, which is primarily an analytical measurement device. The device's underlying technology (electrochemical detection of thrombin activity) is well-established, and its "software" is focused on measurement processing and user interface features, rather than learning from a large dataset in the way a machine learning algorithm would. The "measurement software" is stated to be identical to the predicate, suggesting it's not a new algorithm "trained" on data.

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

    As no training set is mentioned or applicable in the context of this device's development as described, there is no information on how its ground truth would have been established. If any internal development iterations involved data, it would likely be against reference lab methods to ensure the electrochemical principle and measurement algorithms were correctly implemented.

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