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510(k) Data Aggregation

    K Number
    K173461
    Date Cleared
    2018-08-03

    (269 days)

    Product Code
    Regulation Number
    870.2800
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ECG recorder and Arrhythmia Detector

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

    The Nuubo System is indicated for use on patients who may be asymptomatic or who may suffer from transient symptoms such as palpitations, shortness of breath, dizziness, light-headedness, presyncope, syncope, fatigue, or anxiety.

    The Nuubo system continuously records and stores ECG and activity data for up to 30 days at a time. The Nuubo System detects arrhythmias at the end of the monitoring period upon download of the ECG data. The Nuubo System is Rx use device.

    Device Description

    The Nuubo System, developed by Smart Solutions Technologies (SST), is a wearable device designed for ambulatory recording electrocardiogram (ECG) up to 30 days. The system is composed of 3 main components:

    • Nuubo30 – The Nuubo30 wearable is a single patient textile like a chest-belt that contains 4 textile electrodes in the inner side that are used for sensing patient 's ECG.
    • NuuboREC - The Nuubo recorder is a small, lightweight device that records ECG continuously. The device records 2 Leads of ECG data up to 30 days. The device also records data from a 3-axis accelerometer located inside the device.
    • Nuubo Leonardo - The Leonardo Software is installed on a computer where the patient´s ECG data stored in the recorder will be downloaded for subsequent analysis and report.
    AI/ML Overview

    This document is a 510(k) summary for the Nuubo System, submitted to the FDA. It details the device's indications for use, technological characteristics, and performance data to demonstrate substantial equivalence to a predicate device.

    Here's an analysis based on the provided information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document explicitly states that "The results obtained validate the Nuubo Arrhythmia Algorithms and prove equivalence to Monebo Automated ECG Analysis And Interpretation Software Library, version 3.0 [manufacturer Monebo Technologies, 510(k) number K062282]." It further mentions that "All results are comparable to the results claimed by Monebo."

    While specific numerical acceptance criteria (e.g., minimum sensitivity/specificity for each arrhythmia) and the Nuubo System's reported performance for each criterion are not directly listed in the provided text, the document indicates that the device's arrhythmia detection performance was validated and found comparable to the Monebo device, which was referenced by the predicate ZioPatch. The table below lists the arrhythmia functionalities and their detection criteria, implying these are the targets for the algorithm:

    Algorithm FunctionalityDetection CriteriaNuubo Reported Performance (Implied)
    Beat detectionModified Tompkins detector with adaptive threshold of beat detection above 0.2mV.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Heart rate measurementCalculated by averaging the RR of beats in non-overlapped 10-second windows.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Normal beats classificationMorphology similar to predominant normal morphologic family, not premature.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Supraventricular beats classificationMorphology similar to predominant normal morphologic family, but premature (RR interval 80% shorter than RR average of 4 preceding beats).Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Ventricular beats classificationMorphology different than predominant normal morphologic family, fits ventricular criteria of width, premature ratio, or dissimilarity.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Atrial FibrillationIrregular rhythm longer than 30 seconds.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Isolated Ventricular beatOne Ventricular beat [V] isolated, surrounded by non-ventricular beats, not in bigeminy or trigeminy.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Ventricular PairTwo consecutive Ventricular beats [VV] surrounded by non-ventricular beats.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Ventricular RunThree or more consecutive Ventricular beats [VVV].Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Ventricular BigeminyAt least one sequence of [Ventricular / Normal or Non Classified / Ventricular] beats [VNV].Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Ventricular TrigeminyAt least one sequence of [Ventricular / Normal or Non Classified / Normal or Non-Classified / Ventricular] beats [VNNV].Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Isolated Supraventricular beatOne Supraventricular beat [S] isolated, surrounded by non-supraventricular beats.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Supraventricular PairTwo consecutive Supraventricular beats [SS] surrounded by non-supraventricular beats.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    Supraventricular RunThree or more consecutive Supraventricular beats [SSS].Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    PausesA RR Interval longer than 2000ms.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    TachycardiaA rhythm faster than 100 bpm longer than 10 beats of any type.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).
    BradycardiaA rhythm slower than 50 bpm longer than 10 seconds with beats of any type.Validated per AAMI/IEC60601-2-47 requirements. Comparable to Monebo Automated ECG Analysis and Interpretation Software Library (K062282).

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

    The arrhythmia detection algorithms were tested using:

    • Public Databases: MIT-BIH, AHA, and MITAF. These are well-known, established retrospective ECG databases. The country of origin for these databases is primarily the United States.
    • Private Database: Comprised of 90 ECG registries from 58 patients. The provenance (country of origin) is not explicitly stated, but the context of the submission to the FDA suggests it aligns with U.S. medical practice. This data is described as "anonymized," potentially retrospective, selected to contain all arrhythmias detected by the algorithm.

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

    For the private database (90 ECG registries from 58 patients), the ground truth was established by "experienced medical professionals." The specific number of experts is not provided, nor are their detailed qualifications (e.g., specific sub-specialty or years of experience). For the public databases (MIT-BIH, AHA, MITAF), ground truth is typically established by consensus of multiple cardiologists or electrophysiologists based on established annotation guidelines, though the document doesn't detail this for these specific databases.

    4. Adjudication Method for the Test Set

    The document states that the private database "was annotated using experienced medical professionals, using prospectively defined guidelines, consistent with US medical practice." This suggests an expert review process. However, the exact adjudication method (e.g., 2+1, 3+1, or simple consensus from a single annotator if a single expert annotated) is not specified. For the public databases, adjudication methods are usually defined by the database creators, often involving multiple experts to establish consensus.

    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

    No MRMC comparative effectiveness study involving human readers' improvement with AI vs. without AI assistance is reported in this document. The study focuses on the standalone performance of the algorithm.

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

    Yes, a standalone performance study of the algorithm was done. The document states: "The Nuubo Arrhythmia detection algorithm was tested per requirements of AAMI/IEC60601-2-47. To validate the arrhythmia detection algorithms were used three public databases and one private database." The results of this testing were compared to the performance claimed by the Monebo Automated ECG Analysis And Interpretation Software Library (K062282), indicating a standalone comparison. The caveat is that "The Nuubo Arrhythmia Detection Algorithm is not intended to replace the Clinician review of signals. The software menu prompts the Clinician or trained technician to review events prior to generating a report," which implies that the intended use is with a human-in-the-loop for final review, even if standalone performance was tested.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    The type of ground truth used for the private database was expert annotation/consensus based on "experienced medical professionals, using prospectively defined guidelines." For the public databases (MIT-BIH, AHA, MITAF), the ground truth is also based on expert annotation (often expert consensus).

    8. The Sample Size for the Training Set

    The document does not explicitly state the sample size used for the training set for the Nuubo arrhythmia detection algorithm. It only mentions the databases used for validation/testing.

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

    Since the training set size and specific databases are not mentioned, how the ground truth for any training set was established is also not described in this document. The description of ground truth establishment is specifically for the test/validation data.

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