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510(k) Data Aggregation

    K Number
    K201476
    Date Cleared
    2020-08-28

    (86 days)

    Product Code
    Regulation Number
    862.1358
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    DreaMed Advisor Pro

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

    DreaMed Advisor Pro is a decision-support software intended for assisting healthcare professionals in the management of patients with Type 1 diabetes who:

    · use insulin pumps as their insulin delivery therapy;

    · monitor their glucose levels using continuous glucose monitoring (CGM) and/or Self-Monitoring Blood Glucose (SMBG) meter;

    • are above the age of 6; and

    · use rapid acting U-100 insulin analogs in their pump

    DreaMed Advisor Pro is indicated for use by healthcare professionals when analyzing CGM, SMBG and pump data to generate recommendations for optimizing a patient's insulin pump settings for basal rate, Carbohydrate Ratio (CR), and Correction Factor (CF); without considering the full clinical status of a particular patient. DreaMed Advisor Pro does not replace clinical judgement.

    Device Description

    DreaMed Advisor Pro is a software device that is designed to provide insulin therapy adjustment recommendations to physicians to assist in the management of diabetes for patients with Type 1 diabetes using an insulin pump, a continuous glucose monitoring (CGM) system and self-management blood glucose meter (SMBG).

    The DreaMed Advisor Pro gathers and analyzes information inputted through qualified Diabetes Management Systems (DMS), which collects biological input information from various diabetes devices. Diabetes device information required and used by DreaMed Advisor Pro includes glucose readings (either CGM sensor readings and/or capillary blood glucose measurements), insulin dosing logs, and meal data during daily routine care.

    Following data collection and analysis, the DreaMed Advisor Pro generates results containing summary data and recommendations for adjustments to the patient's insulin therapy parameters, including basal insulin delivery rate(s), insulin to carbohydrate ratio and correction factor (insulin sensitivity). DreaMed Advisor Pro may also advise behavioral changes. Results are sent to a qualified Diabetes Management Systems, which displays results to physicians and a report provided by DreaMed Diabetes. The physician can approve, reject or change the recommendations and issue the updated treatment plan to the patient.

    AI/ML Overview

    The provided text is a 510(k) summary for the DreaMed Advisor Pro, which is a software device intended to assist healthcare professionals in managing Type 1 diabetes. It primarily describes the device, its intended use, and argues for its substantial equivalence to a previously cleared version of the same device (K191370).

    However, the document does not contain the detailed information requested about acceptance criteria, specific study results, sample sizes for test and training sets, expert qualifications, adjudication methods, or MRMC comparative effectiveness studies. It simply asserts that the updated DreaMed Advisor Pro is "as safe and effective" as the previously cleared one, with the only change being an expansion of the age range to include patients over 65.

    Therefore, I cannot populate the table and answer all the questions based on the provided text. I will indicate where the information is missing.


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Metric, Threshold)Reported Device Performance
    Not provided in the document. The document asserts substantial equivalence to a predicate device rather than detailing specific performance criteria or the results of a new study proving these.Not provided in the document. No specific performance metrics or thresholds are given, nor are results of a study designed to meet such criteria.

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

    • Sample size for test set: Not provided in the document.
    • Data provenance: Not provided in the document. No specific study data is presented, so the origin (country, retrospective/prospective) of any potential test data is not mentioned.

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

    Not provided in the document. Since no specific test set study is detailed, there's no information on ground truth establishment or expert involvement.


    4. Adjudication method for the test set

    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

    Not provided in the document. The submission focuses on substantial equivalence to a previous version of the same AI device, not on comparing human readers with and without the AI.


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

    The document describes the device as "decision-support software intended for assisting healthcare professionals," and states that "DreaMed Advisor Pro does not replace clinical judgement." This implies human-in-the-loop operation. No standalone (algorithm-only) performance is described or implied to have been studied for this 510(k) submission.


    7. The type of ground truth used

    Not provided in the document. No specific ground truth methodology is mentioned as a study proving performance is not detailed in this submission.


    8. The sample size for the training set

    Not provided in the document.


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

    Not provided in the document.

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    K Number
    K191370
    Date Cleared
    2019-07-18

    (57 days)

    Product Code
    Regulation Number
    862.1358
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    DreaMed Advisor Pro

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

    DreaMed Advisor Pro is a decision-support software intended for assisting healthcare professionals in the management of patients with Type 1 diabetes who:
    • use insulin pumps as their insulin delivery therapy;
    • monitor their glucose levels using CGM and/or self-management blood glucose meter;
    • are above the age of 6 and under 65 years old; and
    • use rapid acting U-100 insulin analogs in their pump.
    DreaMed Advisor Pro is indicated for use by healthcare professionals when analyzing continuous glucose monitoring (CGM), self-monitoring blood glucose (SMBG) and pump data to generate recommendations for optimizing a patient's insulin pump settings for basal rate, carbohydrate ratio (CR), and correction factor (CF); without considering the full clinical status of a particular patient. DreaMed Advisor Pro does not replace clinical judgement.

    Device Description

    DreaMed Advisor Pro is a software device that is designed to provide insulin therapy adjustment recommendations to physicians to assist in the management of diabetes for patients with Type 1 diabetes using an insulin pump, a continuous glucose monitoring (CGM) system and self-management blood glucose meter (SMBG).
    The DreaMed Advisor Pro gathers and analyzes information inputted through qualified Diabetes Management Systems (DMS), which collects biological input information from various diabetes devices. Diabetes device information required and used by DreaMed Advisor Pro includes glucose readings (either CGM sensor readings and/or capillary blood glucose measurements), insulin dosing logs, and meal data during daily routine care.
    Following data collection and analysis, the DreaMed Advisor Pro generates results containing summary data and recommendations for adjustments to the patient's insulin therapy parameters, including basal insulin delivery rate(s), insulin to carbohydrate ratio and correction factor (insulin sensitivity). DreaMed Advisor Pro may also advise behavioral changes. Results are sent to a qualified Diabetes Management Systems, which displays results to physicians and a report provided by DreaMed Diabetes. The physician can approve, reject or change the recommendations and issue the updated treatment plan to the patient.

    AI/ML Overview

    The DreaMed Advisor Pro is a decision-support software for healthcare professionals managing Type 1 diabetes patients. It generates recommendations for optimizing insulin pump settings based on continuous glucose monitoring (CGM), self-monitoring blood glucose (SMBG), and pump data.

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

    1. Table of Acceptance Criteria and Reported Device Performance

    The document doesn't explicitly state "acceptance criteria" in a quantitative performance table but discusses equivalence to a predicate device and clinical validity compared to expert recommendations.

    Feature / CharacteristicAcceptance Criteria (Implied / Compared to Predicate)Reported Device Performance and Assessment
    Agreement with Predicate Device (Retrospective Test)- High level of agreement with DEN170043 when comparing recommendations over similar datasets.- Retrospective tests showed a "high level of agreement" with the predicate device (DEN170043) for recommendations on similar data sets. - When sufficient data was available with simulated-SMBG, DreaMed Advisor Pro made similar recommendations to the predicate. - When insufficient data, DreaMed Advisor Pro did not recommend changes, mirroring the predicate's behavior without enough CGM data.
    Clinical Validity vs. Experts (SMBG data alone)- Recommendations in basal, CR, and CF plan (regarding direction of change) should be significantly as good as experts.- An additional retrospective clinical study found that DreaMed Advisor Pro's recommendations (when based on SMBG data alone) were "significantly as good as the recommendations of expert in the basal, CR and in the CF plan with regards to the direction of change." - This suggests the Advisor Pro's recommendations are similar to those from experienced healthcare professionals.
    Minimum Data Points for Analysis (Subject Device)- Minimum of 12 valid days.- Achieved: Minimum of 12 valid days required. A valid day consists of: - Minimum glucose data: At least 67% of CGM sensor readings per day (e.g., 192 samples for 5-minute interval sensor, 64 samples for 15-minute interval sensor), OR - At least 4 BG measurements a day separated by at least 160 minutes. - Minimum insulin pump data: At least 1 basal rate record and 1 bolus record. - Insulin pump settings at analysis within acceptable ranges: Basal rate (0.025-3 u/h), CR (3-70gr/u), CF (10-280gr/u), Bolus calculator targets (≤ 150 mg/dl).
    Input Data Specifications (Accuracy)- CGM sensors with regulatory approval demonstrating accuracy below MARD of 15%.- Achieved: Uses CGM with regulatory approval showing accuracy below MARD of 15%.
    Non-clinical tests (Design Validation, Human Factors, Software)- Performs according to stated intended use. - Human Factors validation documented per FDA Guidance. - All software test results fall within pre-determined specifications and acceptance criteria. - Special controls implemented and validated.- Achieved: Design validation testing and human factors study results confirmed performance per intended use. - Human Factors validation documented according to FDA Guidance (February 3, 2016). - Software evaluation included functional testing; all results within pre-determined specification parameters and acceptance criteria. - Special controls implemented and validated per DreaMed's software test plan.

    2. Sample Size and Data Provenance for the Test Set

    • Sample Size for Clinical Study: 15 patients.
    • Data Provenance: Retrospective clinical study. The document does not explicitly state the country of origin of the data.

    3. Number of Experts and Qualifications

    • Number of Experts: 17 experts.
    • Qualifications of Experts: They are described as "Healthcare Professional who work at leading centers with a wealth of experience in the field of diabetes and who are especially familiar with diabetes technology devices." No specific number of years of experience or physician titles (e.g., radiologist) are provided, as this is for diabetes management.

    4. Adjudication Method

    • Adjudication Method: The clinical study compared recommendations to examine the "level of agreement between one expert to his colleague (total of 136 pairs) versus the level of agreement between DreaMed Advisor Pro recommendations and experts (total of 17 pairs)." This implies a comparison against individual expert opinions, rather than a formal consensus-based adjudication method like 2+1 or 3+1. Each expert's recommendation was likely treated as a reference point for comparison.

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

    • The document describes a comparative study where the device's recommendations were compared against experts. It's a "retrospective clinical study" involving 17 experts reviewing data for 15 patients. While it involves multiple readers (experts) and multiple cases (patients), it focuses on the agreement between the AI and human experts, and experts among themselves, rather than a direct MRMC study to quantify how much human readers improve with AI assistance vs. without AI assistance. The study concluded that the Advisor Pro's recommendations were "significantly as good as the recommendations of expert," implying equivalence, but not necessarily an "improvement effect size" in a human-in-the-loop scenario.

    6. Standalone Performance

    • Yes, a standalone performance assessment was done. The "Additional retrospective clinical study" evaluated the DreaMed Advisor Pro's recommendations based on SMBG data alone and compared these recommendations directly to those of human experts. This demonstrates the algorithm's performance in generating recommendations without real-time human input or modification.

    7. Type of Ground Truth Used

    • Ground Truth: Expert consensus (or rather, expert recommendations serving as a reference) was used. The study compared the device's recommendations against the recommendations made by the 17 human experts.

    8. Sample Size for the Training Set

    • The document does not explicitly state the sample size used for the training set. It focuses on the validation of the device.

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

    • The document does not describe how the ground truth for any potential training set was established. The clinical study mentioned is a validation study comparing the device's output to expert recommendations, not a description of the training data or its ground truth establishment.
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    K Number
    DEN170043
    Date Cleared
    2018-06-12

    (299 days)

    Product Code
    Regulation Number
    862.1358
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    DreaMed Advisor Pro

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

    DreaMed Advisor Pro is a decision-support software intended for assisting healthcare professionals in the management of patients with Type 1 diabetes who:

    • use insulin pumps as their insulin delivery therapy: .
    • . monitor their glucose levels using either of the following:
      • CGM, or O
      • CGM and self-management blood glucose meter O
    • . are above the age of 6 and under 65 years old; and
    • . use rapid acting U-100 insulin analogs in their pump

    DreaMed Advisor Pro is indicated for use by healthcare professionals when analyzing continuous glucose monitoring (CGM), self-monitoring blood glucose (SMBG) and pump data to generate recommendations for optimizing a patient's insulin pump settings for basal rate, carbohydrate ratio (CR), and correction factor (CF); without considering the full clinical status of a particular patient. DreaMed Advisor Pro does not replace clinical judgment.

    Device Description

    DreaMed Advisor Pro is a software device that is designed to provide insulin therapy adjustment recommendations to physicians to assist in the management of diabetes for patients with Type 1 diabetes using an insulin pump and a continuous glucose monitoring (CGM) system.

    The DreaMed Advisor Pro gathers and analyzes information inputted through qualified 3rd party Diabetes Management Systems (DMS), which collects biological input information from various diabetes devices. Diabetes device information required and used by DreaMed Advisor Pro includes glucose readings (CGM sensor readings with the option for capillary blood glucose measurements), insulin dosing logs, and meal data during daily routine care.

    Following data collection and analysis, the DreaMed Advisor Pro generates results containing summary data and recommendations for adjustments to the patient's insulin therapy parameters, including: basal insulin delivery rate(s), insulin to carbohydrate ratio, and correction factor (insulin sensitivity)(b) (4) DreaMed Advisor Pro may also advise behavioral changes. Results are sent to a qualified 3th party Diabetes Management Systems, which displays results to physicians and a report provided by DreaMed Diabetes. The physician can approve, reject or change the recommendations and issue the updated treatment plan to the patient.

    AI/ML Overview

    Acceptance Criteria and Study for DreaMed Advisor Pro

    The DreaMed Advisor Pro is a software device that provides insulin therapy adjustment recommendations to physicians for managing Type 1 diabetes in patients using insulin pumps and Continuous Glucose Monitoring (CGM) systems. The device was evaluated for automatic Class III designation.

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document does not explicitly present a table of quantitative acceptance criteria and corresponding reported device performance with numerical thresholds for metrics like accuracy, precision, or sensitivity/specificity for the device's recommendations compared to a gold standard. Instead, the "Performance Characteristics" section details two clinical studies that aim to demonstrate clinical validity and safety. The acceptance of the device seems to be based on the safety and a general alignment of its recommendations with expert opinion, rather than meeting specific quantitative performance metrics against a defined ground truth for individual recommendations.

    However, based on the findings from the clinical studies described, we can infer the qualitative performance and the safety-focused acceptance:

    Acceptance Criteria (Inferred from clinical studies and regulatory decision)Reported Device Performance (as described in the document)
    Safety and Non-Inferiority (Clinical Outcome): Recommendations do not lead to serious adverse events and do not worsen glycemic control compared to expert physician guidance.- "No serious adverse events occurred in either group of the study."
    • Percentage of CGM time within 70-180 mg/dL increased and percentage below 70 mg/dL reduced in Advisor Pro group compared to control group in one study. |
      | Clinical Validity (Alignment with Expert Opinion): Insulin dosing recommendations (basal rate, carb ratio, correction factor) are generally similar to expert physicians. | - Recommendations for basal rate and carbohydrate ratio were "generally similar" to expert physicians.
    • Difference noted for correction factor recommendations between DreaMed Advisor Pro and physicians. |
      | Usability and Comprehension: Users (HCPs and patients/caregivers) can understand and appropriately interpret recommendations. | - Human factors testing performed with 48 lay users and 15 HCPs. "The design and results of the study were reviewed and found acceptable." |
      | Mitigation of Risks: Identified risks to health (erroneous recommendations, incorrect interpretation, inappropriate use, data corruption, insecure transmission) are mitigated to an acceptable level. | - Special controls and general controls are deemed sufficient to mitigate identified risks, with the healthcare professional acting as an intermediary. |

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

    • Study 1 (Expert Physician Survey):

      • Test Set Sample Size: 15 patients. Each patient's data was presented as an anonymized PDF file.
      • Data Provenance: Retrospective data of 3 weeks of CGM, SMBG, and insulin pump data from children and adolescents with Type 1 Diabetes using an insulin pump. Collected from 3 centers in Germany, Israel, and Slovenia.
    • Study 2 (Clinical Intervention Study):

      • Test Set Sample Size:
        • Intervention group (guided by Advisor Pro): 6 subjects.
        • Control group (guided by expert physician): 7 subjects.
      • Data Provenance: Prospective, single-center study conducted at a pediatric hospital in Israel. Subjects used the algorithm for two iterations of treatment recommendations over a 6-week study period, with data collected during this period.

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

    • Study 1 (Expert Physician Survey):

      • Number of Experts: 9 experts.
      • Qualifications: "Expert endocrinologists" with "expert physicians" from 3 centers (3 physicians from each center) participated. No specific years of experience or sub-specialty mentioned beyond "expert endocrinologists."
    • Study 2 (Clinical Intervention Study):

      • Number of Experts: Unspecified number of "diabetes healthcare professionals" or "expert physician" (singular). The control group was guided by "the expert physician." This implies at least one expert managed the control group.
      • Qualifications: "Diabetes healthcare professionals" or "expert physician." No specific qualifications mentioned.

    4. Adjudication Method for the Test Set

    • Study 1 (Expert Physician Survey):

      • Each of the 9 experts independently provided proposed recommended changes.
      • The recommendations from these physicians were then compared among themselves and to the Advisor Pro automated recommendations. The document states "The recommendations from the physicians at each site were also compared." This suggests a form of comparison or analysis of agreement/disagreement among experts, but not a formal consensus-based adjudication to establish a single ground truth before comparison to the device. Diversity in opinions was noted ("diversity between experts").
    • Study 2 (Clinical Intervention Study):

      • This study compared outcomes between two groups: one guided by Advisor Pro and one guided by a physician. There was no explicit adjudication method described for establishing a single "ground truth" for insulin recommendations within this comparative effectiveness study, as the physician's adjustments in the control group served as the "standard of care" for comparison.

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

    An MRMC study was effectively conducted in Study 1 (Expert Physician Survey).

    • Study Design: 9 expert endocrinologists (multi-readers) independently reviewed data from 15 patients (multi-cases) and provided recommendations. These recommendations were then compared to the DreaMed Advisor Pro's recommendations.
    • Effect Size of Human Readers with AI vs. without AI assistance: The study compared the Advisor Pro recommendations to expert physician recommendations. It did not involve human readers using the AI and then comparing their performance to human readers not using the AI. Therefore, it does not provide an effect size of how much human readers improve with AI assistance. Instead, it suggests a degree of similarity between AI and expert recommendations:
      • "the recommendations of the DreaMed Advisor Pro were generally similar to the recommendations of expert physicians with respect to the basal rate as well as the carbohydrate ratio (CR)."
      • "there was a difference between the physicians compared to DreaMed Advisor Pro and physician recommendations for the correction factor (CF)."
      • It also noted "diversity between experts with regards to recommendations to the same data."

    6. Standalone (Algorithm Only) Performance

    Yes, a standalone performance assessment was conducted for the DreaMed Advisor Pro implicit in Study 1 (Expert Physician Survey). The study compared the "Advisor Pro automated recommendations" directly against the recommendations of expert physicians. This indicates the algorithm's output was evaluated without human mediation in terms of generating the recommendation itself.

    7. Type of Ground Truth Used

    • Study 1 (Expert Physician Survey): Expert consensus/comparison. The ground truth for evaluating the DreaMed Advisor Pro's recommendations was the recommendations provided by the panel of 9 expert endocrinologists. However, as noted, there was "diversity between experts," so it wasn't a single "consensus" in a strict sense, but rather a comparison against a spectrum of expert opinions.
    • Study 2 (Clinical Intervention Study): Clinical outcomes data (glycemic control metrics from CGM) and expert physician guidance as a control. The "ground truth" here was less about individual recommendation correctness and more about the impact on patient outcomes. The control group, guided by an expert physician, served as the comparative standard of care.

    8. Sample Size for the Training Set

    The document does not explicitly state the sample size used for the training set of the DreaMed Advisor Pro algorithm. It only describes the evaluation (test) studies.

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

    The document does not provide information on how the ground truth for the training set was established. This information would typically be part of the software development and validation process, but it is not detailed in the provided "DECISION SUMMARY."

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