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510(k) Data Aggregation

    K Number
    K172569
    Device Name
    GenePOC CDiff
    Manufacturer
    Date Cleared
    2017-11-22

    (89 days)

    Product Code
    Regulation Number
    866.3130
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The GenePOC CDiff assay performed on the revogene instrument is a qualitative in vitro diagnostic test that utilizes automated sample processing and real-time polymerase chain reaction (PCR) to detect the toxin B (tcdB) gene of toxigenic Clostridium difficile( C. difficile) in unformed (liquid or soft) stool specimens obtained from patients suspected of having C. difficile infection (CDI). The GenePOC CDiff assay is intended to aid in the diagnosis of CDI.

    Device Description

    The GenePOC™ CDiff assay is a single-use test for the qualitative detection of the toxin B (tcdB) gene of toxigenic Clostridium difficile (C. difficile) in unformed (liquid or soft) stool specimens. The GenePOC™ CDiff assay kit is comprised of the disposable CDiff microfluidic cartridges (PIE), Disposable Transfer Loops (DTL), Sample Buffer Tubes (SBT), and Disposable Transfer Tools (DTT; pipette). These components are used to suspend the sample, extract, amplify, and detect C. difficile nucleic acid. A Process Control (PrC) is also incorporated into each PIE to verify sample processing and amplification steps. The PrC allows for the verification of potential inhibitor substances as well as microfluidic, instrument or reagent failure. The GenePOC™ CDiff assay is designed to be used on the revogene™. The revogene™ is an instrument that automates sample homogenization, sample dilution, cells lysis, DNA amplification and detection of the amplified PCR products.

    Each GenePOC™ CDiff assay kit provides components for 24 tests. User intervention is required for sample preparation, transferring the stool specimen with the DTL into the SBT, using the DTT to transfer the sample into the PIE, and loading/unloading the PIE into the revogene™ carousel. Each PIE is a completely integrated closed device in which a sample is dispensed and processed through different microfluidic chambers and channels that allow for the sample processing and subsequent real-time PCR steps.

    Upon completion of a run, the results are computed by the revogene™ from measured fluorescent signals and embedded calculation algorithms. The output results include positive, negative, indeterminate, and unresolved. Upon completion of a run, the user removes the used cartridges and disposes of them in normal biological waste. Results may be viewed, printed, transferred, and/or stored by the user.

    AI/ML Overview

    The provided document describes the regulatory submission for the GenePOC CDiff assay, a diagnostic test for Clostridium difficile infection (CDI). The document focuses on the analytical and clinical performance of the device to demonstrate its substantial equivalence to a predicate device.

    Here's a breakdown of the acceptance criteria and study details based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state pre-defined acceptance criteria in a formal table. However, the performance characteristics sections imply the criteria for various analytical and clinical aspects. The reported performance is presented in the tables and text within the document.

    Let's infer the acceptance criteria from the reported results, especially concerning agreement percentages and confidence intervals. Typically, for in vitro diagnostics, high sensitivity and specificity are desired, often above certain thresholds (e.g., 85% or 90% for sensitivity, and 95% or more for specificity). For reproducibility, high agreement is also expected (e.g., >95%).

    MetricAcceptance Criterion (Implied)Reported Device Performance (GenePOC CDiff)
    Analytical Performance
    Reproducibility
    Between-Laboratory Reproducibility:
    Low Positive Samples (Overall Agreement)High agreement (e.g., >90%)97.2% (95% CI: 93.6-99.1%)
    Moderate Positive Samples (Overall Agreement)High agreement (e.g., >90%)98.3% (95% CI: 95.2-99.7%)
    True Negative Samples (Overall Agreement)Very high agreement (e.g., >95%)100% (95% CI: 97.5-100%)
    CVs for Ct ValuesLow variability (e.g., <10%)Consistently below 7.54% (Overall)
    Between-Lot Reproducibility:
    Low Positive Samples (Overall Agreement)High agreement (e.g., >90%)95.0% (95% CI: 90.7-97.7%)
    Moderate Positive Samples (Overall Agreement)High agreement (e.g., >90%)98.3% (95% CI: 95.2-99.7%)
    True Negative Samples (Overall Agreement)Very high agreement (e.g., >95%)100% (95% CI: 97.5-100%)
    Within-Laboratory Precision:
    Low Positive Samples (Overall Agreement)High agreement (e.g., >90%)94.4% (95% CI: 89.3-97.6%)
    Moderate Positive Samples (Overall Agreement)High agreement (e.g., >90%)96.5% (95% CI: 92.1-98.9%)
    True Negative Samples (Overall Agreement)Very high agreement (e.g., >95%)100% (95% CI: 96.9-100%)
    Detection Limit (LoD)Lowest concentration for 95%+ detection1,500 CFU/mL of SB for C. difficile strains (95% or greater detection)
    Analytical InclusivityAll strains detected at 2-3xLoDAll 20 toxigenic C. difficile strains detected at 3,750 CFU/mL SB (2-3xLoD)
    Analytical SpecificityMinimal to no false positivesLimited specific false positives at high concentrations for some Clostridium species. No reactivity at lower concentrations. One case of false positive for Enterococcus faecalis at high concentration.
    InterferenceNo interferenceNo interference from 30 tested organisms; interference from Tums and Stomaax at high concentrations; no interference from 5 endogenous agents.
    Carry-Over & Cross-ContaminationAbsence of carry-over/cross-contaminationDemonstrated absence.
    Clinical Performance
    Sensitivity (Fresh Specimens)High sensitivity (e.g., >80%)80.5% (95% CI: 72.0-87.4%)
    Specificity (Fresh Specimens)High specificity (e.g., >95%)97.1% (95% CI: 95.5-98.2%)
    Sensitivity (Frozen Specimens)High sensitivity (e.g., >80%)87.3% (95% CI: 82.1-91.4%)
    Specificity (Frozen Specimens)High specificity (e.g., >95%)97.3% (95% CI: 96.3-98.1%)
    Unresolved Rate (After Repeat Testing)Low rate (e.g., <1%)Fresh: 0.1% (1/798); Frozen: 0.0% (0/1665)
    Indeterminate Rate (After Repeat Testing)Low rate (e.g., <1%)Fresh: 0.0% (0/798); Frozen: 0.1% (1/1665)

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

    • Clinical Study Test Set (Patients):

      • Total Samples: 2,461 fully compliant samples (797 fresh + 1,664 frozen).
      • Data Provenance: Prospective multicenter trial at 7 geographically diverse clinical trial sites (US and Canada).
      • Retrospective/Prospective: The study design included testing fresh samples (prospectively collected and tested immediately) and retrospectively collected samples that were stored frozen (prospectively collected but tested after freezing).
    • Analytical Performance Test Sets:

      • Precision/Reproducibility: 1,022 samples (383 low positive, 384 moderate positive, and 255 negative samples) were tested across different studies (Between-Laboratory, Between-Lot, Within-Laboratory). These were spiked stool samples. The provenance of the negative stool pool for preparing these panels is not specified by country, but the panel strains are ATCC (American Type Culture Collection), indicating standardized reference strains.
      • Detection Limit (LoD): Not specified in terms of sample size, but involved testing replicates (multiple runs, instruments, operators) of specific C. difficile strains.
      • Analytical Inclusivity: 20 strains of toxigenic C. difficile from various geographic origins.
      • Analytical Specificity: 58 various analytes (1 yeast, 6 viruses, 50 bacteria, and human DNA).
      • Interference (Non-Target Organisms): Tests involved 30 organisms.
      • Interference (Exogenous/Endogenous Substances): 21 potentially interfering substances.

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

    • This information is not explicitly stated in the provided text.
    • For the clinical study, the reference method (ground truth) was "Combined Direct and Enriched Culture" followed by cytotoxicity testing (CCNA) on isolated C. difficile colonies. While this is a laboratory-based gold standard, the document does not specify the number of laboratory experts/technicians involved in performing and interpreting these reference methods or their specific qualifications. It also doesn't mention expert clinical adjudication for the patient diagnosis itself, as the device is for in vitro diagnostic testing based on lab results.

    4. Adjudication Method for the Test Set

    • For the clinical study, the "ground truth" (reference method) was established as follows:
      • A specimen was considered positive for toxigenic C. difficile if C. difficile was recovered by either direct or enriched culture AND if bacterial isolates tested positive by cytotoxicity testing (CCNA).
      • A specimen was considered negative only if it tested negative by both direct and combined culture (i.e., direct and enriched culture).
    • This is a laboratory-based algorithm for establishing ground truth, not a multi-reader clinical adjudication process. The document does not describe an adjudication method involving multiple human readers for the final clinical diagnosis or the interpretation of the reference method.

    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, an MRMC comparative effectiveness study was not done.
    • This device is an in vitro diagnostic (IVD) assay that automates sample processing, DNA amplification, and detection of a specific gene. It provides a "positive," "negative," "indeterminate," or "unresolved" result. It is not an AI-based image analysis tool or a system that assists human readers in interpreting complex data where reader improvement could be measured. Therefore, the concept of human readers improving with AI assistance is not applicable to this type of device. The study evaluates the performance of the automated assay itself against a laboratory reference method.

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

    • Yes, this was a standalone performance study. The GenePOC CDiff assay operates on the revogene instrument, which automates the entire process from sample loading to result computation. The results are "computed by the revogene™ from measured fluorescent signals and embedded calculation algorithms." The performance metrics (sensitivity, specificity, reproducibility) are reported for the device as a whole, essentially as an algorithm-only (automated instrument) performance, without human "in-the-loop" interpretation of the primary signals. Human intervention is limited to sample preparation and loading/unloading.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)

    • The ground truth used for the clinical study was a laboratory-based reference method: "Combined Direct and Enriched Culture" for C. difficile recovery, followed by cytotoxicity testing (CCNA) on the isolated bacterial strain to confirm toxin production. This is a robust and widely accepted method for confirming toxigenic C. difficile in stool samples.

    8. The Sample Size for the Training Set

    • The document does not mention a separate "training set" for an algorithm. This suggests that the device's algorithms and parameters were likely developed and validated internally by the manufacturer during product development, possibly using a series of development and internal validation studies. The clinical and analytical studies described are primarily for performance demonstration and likely served as a "test set" for regulatory submission, rather than a training set for a machine learning model.
    • For an IVD like this, the "training" (calibration, optimization of thresholds) would typically be done during the engineering and design phases and locked down before clinical validation.

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

    • As a dedicated "training set" is not explicitly mentioned or described, the method for establishing its ground truth is also not provided. If an internal training or development set was used, it would have likely relied on similar laboratory reference methods to establish the true positive/negative status of samples.
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