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510(k) Data Aggregation

    K Number
    K123843
    Device Name
    NEUROEPG SYSTEM
    Date Cleared
    2013-06-05

    (174 days)

    Product Code
    Regulation Number
    882.1870
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    NEUROEPG SYSTEM

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

    The NeuroEPG System is an evoked response testing and diagnostic device that is capable of eliciting, acquiring and measuring auditory and somatosensory evoked potentials.

    The intended use of the NeuroEPG System is to objectively record evoked responses from patients 18 years of age and older, upon the presentation of sensory stimuli. The product is indicated for use as a diagnostic aid and adjunctive tool in sensory related disorders (i.e., auditory, somatosensory) and in surgical procedures for intraoperative monitoring.

    The NeuroEPG System is intended to be used by trained personnel in a hospital, clinic, EEG/EP technologist's, surgeon's, or physician's office, operating room, or other appropriate setting.

    The anatomical sites of contact for auditory evoked potential (AEP) testing are the patient's ear canal (with the contact object being a sound delivery ear bud), and the patient's head and possibly other body sites (with the contact object being electrodes that are capable of measuring bio-potentials).

    The anatomical sites of contact for somatosensory evoked potential (SEP) testing are the patient's upper/lower limbs (with the contact object being skin-surface electrodes) and the patient's head and possibly other body sites (with the contact object being electrodes that are capable of measuring bio-potentials).

    Device Description

    The NeuroEPG System is an evoked response testing and diagnostic device that is capable of eliciting, acquiring, and measuring auditory and somatosensory evoked potentials.

    AI/ML Overview

    The provided K123843 document, concerning the Strohl Medical NeuroEPG, does not include a detailed study proving the device meets specific acceptance criteria in terms of performance metrics like sensitivity or specificity for diagnostic accuracy.

    Instead, the submission focuses on demonstrating substantial equivalence to a predicate device (Intelligent Hearing System SmartEP K070608) primarily through comparison of technological characteristics and safety standards. There is no mention of a clinical performance study involving human subjects to assess the device's diagnostic or monitoring accuracy against a defined ground truth.

    Here's an analysis based on the information provided, highlighting the absence of certain requested details:


    1. Table of Acceptance Criteria and Reported Device Performance

    No specific acceptance criteria in terms of diagnostic performance metrics (e.g., sensitivity, specificity, accuracy) or quantitative outcomes are provided in the document. The NeuroEPG System demonstrates equivalence through shared design principles, circuit designs, operating principles, and compliance with safety standards as outlined in the "Comparative Performance and Specifications" section.

    Feature/ParameterAcceptance Criteria (Not explicitly stated as such, but inferred from predicate equivalence)Reported Device Performance (NeuroEPG System)
    Intended UseSame as PredicateSame (SEP and AEP: Stimulate, record, process evoked potentials)
    Indications for UseSame as PredicateSame (Recording and analysis of physiological data for diagnosis of somatosensory and auditory related disorders)
    Target PopulationAll Ages (Predicate)18 years and older (Difference noted, but deemed non-significant for safety/effectiveness by the submission)
    DesignExternal box circuitry connected to CPU via USBSimilar; repackaged into a single, smaller, stand-alone unit; pre-amplifier embedded. Considered "modifications" but not "significant differences."
    SterilityNon-sterileNon-sterile
    Anatomical SitesSEP: Upper/lower limbs and Head; AEP: HeadSame
    Energy DeliverySEP: Surface electrical signals; AEP: Auditory stimulusSame
    Where UsedClinical SettingSame (Hospital, clinic, etc.)
    Safety (Electrical & EMC)Conforms to IEC 60601-1 and related standardsConforms to IEC 60601-1, IEC 60601-1-2, IEC 60601-2-40. Disposable PIK meets ANSVAAMI EC12, EC53, and IEC 60601-1 (1998) [21CFR898].
    Somatosensory StimuliPredicate values for Types, Mode, Shape, Repetition Rate, Phase/Polarity, DurationSame as Predicate (Constant Current, Single/Dual/Train, Mono/Biphasic, 0.1-100Hz, Pos/Neg, 10-1000 µs)
    Stimulus Intensity Levels (SEP)Current: 0-100 mA; Voltage: 0-400V (into 4000 Ohms)Current: 0-25 mA; Voltage: 0-50V (into 2000 Ohms) (Difference noted, considered non-significant)
    Auditory StimuliPredicate values for Types, Duration, Envelopes, Intensity, Repetition Rate, Frequencies, Presentation, MaskingSame as Predicate (Clicks/Pure Tones, 25-5000 µs, various envelopes, 0-125 dB SPL, 1-100 Hz, 500-16000 Hz, Monaural/Binaural, White Noise Programmable)
    Transducers (Auditory)Insert Earphones, Bone Vibrator, Headphones, Sound Field, Ear ProbeEar buds only (Difference noted, considered non-significant)
    Measurement ParametersPredicate values for Analysis Window, Artifact Rejection Threshold, Measured ValuesAnalysis Window (Variable up to 2.5 msec), Artifact Rejection Threshold (25µV fixed, vs. user selectable on predicate). Measured Values (Same plus L vs. R comparison).
    Computer RequirementsPC, Windows 2000/XP, USBSame
    Fundamental TechnologyIdentical to predicateIdentical (stimulation and response mechanisms, scientific technology)
    Software ChangesMinor, not altering safety/effectiveness (predicate)Minor (reduced range of testing/analysis parameters due to additional software, but core data acquisition unit changes considered minor)

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

    • The document does not describe a specific test set or study with human subjects to evaluate the device's diagnostic performance. Therefore, there is no sample size for a test set, nor is there information on data provenance (e.g., country of origin, retrospective/prospective).
    • The comparison is primarily against the specifications and previous clearance of the predicate device (K070608).

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

    • Not applicable, as no human subject test set or ground truth establishment for diagnostic performance is described in this submission.

    4. Adjudication method for the test set

    • Not applicable, as no human subject test set or adjudication process for diagnostic performance is described.

    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. The NeuroEPG System is an evoked response testing and diagnostic device, not an AI-assisted diagnostic tool that aids human readers in interpreting images or other data. This submission does not describe an MRMC study.

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

    • The NeuroEPG System is presented as a device for eliciting, acquiring, and measuring evoked potentials. While it performs objective measurements, the ultimate diagnostic interpretation is still expected to be performed by trained personnel (physicians, technologists). The submission does not describe a "standalone" algorithmic performance study in the context of AI or automated diagnostic decisions, but rather the performance of the measurement system itself against its specifications and the predicate.

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

    • Not applicable in the context of diagnostic accuracy. The "ground truth" for the substantial equivalence claim relies on the established safety and performance characteristics of the predicate device and compliance with relevant industry standards (e.g., IEC 60601-1).

    8. The sample size for the training set

    • Not applicable, as this submission does not describe a machine learning or AI-based device that requires a training set.

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

    • Not applicable, as this submission does not describe a machine learning or AI-based device.

    In summary, this 510(k) submission for the NeuroEPG System establishes substantial equivalence by demonstrating that its technological characteristics, intended use, indications for use, and safety comply with relevant standards and are either identical or insignificantly different from a legally marketed predicate device. It does not contain a clinical performance study with defined acceptance criteria for diagnostic accuracy, nor does it address AI-specific evaluation metrics.

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