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510(k) Data Aggregation
(341 days)
The Neuspera Nuity™ System (NNS) is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.
The Neuspera Nuity™ System (NNS) is also used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) implant.
The Neuspera Nuity™ System is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The System consists of an implantable pulse generator (IPG), electrode array, surgical implant tools, wireless worn transmitter, clinician programmer, a patient controller, and undergarments. The implantable pulse generator is a miniature implanted neurostimulator, powered by an externally worn wireless transmitter device which contains a rechargeable battery.
Same as the predicate, the Neuspera Nuity™ System utilizes pulsed electrical current to create an energy field that acts on the targeted nerve to inhibit the transmission of pain signals to the brain. The Neuspera Nuity™ System may also be used during the trial period before recommendation for permanent implant.
The Neuspera Nuity™ System (NNS) is comprised of the following components: Neuspera Implanted Pulse Generator (IPG) Or Neuspera Implanted Microstimulator, Electrode Array, Surgical/Implant Tools, Externally Worn Wireless Transmitter, Clinician Programmer and Patient Controller.
The provided text does not contain a study that proves the device meets specific acceptance criteria in terms of performance metrics like sensitivity, specificity, accuracy, or any other quantifiable measure. Instead, the document is an FDA 510(k) clearance letter and summary, primarily focusing on demonstrating substantial equivalence to a predicate device based on intended use, technological characteristics, and safety aspects.
Therefore, many of the requested categories cannot be filled as they would relate to a clinical or performance study of the device's diagnostic or therapeutic effectiveness, which is not detailed in this document. The information provided is mainly related to bench testing, engineering comparisons, and biocompatibility.
Here's an analysis of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state acceptance criteria for performance metrics (e.g., pain reduction scores, successful stimulation rates) nor does it provide a clinical study to report on these. The closest information available is a comparison of technological characteristics to a predicate and reference device, implying that meeting or being comparable to these characteristics is a form of acceptance.
| Acceptance Criterion (Implicit) | Reported Device Performance (from Tables 1, 2, 3) |
|---|---|
| Intended Use | Subject Device (Neuspera Nuity™ System): Stimulation of peripheral nerves for chronic, intractable pain. Also for trial stimulation (no longer than 30 days).Predicate Device (Neuspera Neurostimulation System K202781): Same.Reference Device (Nalu Neurostimulation System K183579): Same.Analysis: Same. Differences in wording do not affect safety and effectiveness of intended use. |
| Product Code & Class | Subject Device: GZF, Class IIPredicate Device: SameReference Device: SameAnalysis: Same |
| Regulation Number | Subject Device: 21 CFR §882.5870Predicate Device: SameReference Device: SameAnalysis: Same |
| Classification Name | Subject Device: Implanted peripheral nerve stimulator for pain reliefPredicate Device: SameReference Device: SameAnalysis: Same |
| Prescription Use? | Subject Device: YesPredicate Device: SameReference Device: SameAnalysis: Same |
| Implant Site | Subject Device: Adjacent to nerves peripheral to central nervous system, excluding craniofacial region.Predicate Device: SameReference Device: SameAnalysis: Same |
| Environmental Use | Subject Device: Hospital, HomePredicate Device: SameReference Device: SameAnalysis: Same |
| Intended Clinician | Subject Device: Orthopedic, Neurosurgeon, AnesthesiologistPredicate Device: SameReference Device: SameAnalysis: Same |
| Intended User | Subject Device: Physician, LaypersonPredicate Device: SameReference Device: SameAnalysis: Same |
| Mode of Action | Subject Device: RF wireless transmission of energy to charge implanted energy source with stimulation pulse generator to produce stimulation at stimulator electrodes.Predicate Device: SameReference Device: RF wireless transmission of energy to produce stimulation at stimulator electrodes. (Note: Reference device description is slightly different from subject/predicate in that it omits "implanted energy source with stimulation pulse generator")Analysis: Same as K202781 |
| Software Level of Concern | Subject Device: ModeratePredicate Device: ModerateReference Device: ModerateAnalysis: Same |
| Dimensions (IPG, Electrode Array) | Subject Device: IPG: 2.33 mm diameter, electrode array 1.3 mm diameter, 4.5-5.2 cm total length. Subject devices consist of 2 lengths (30mm and 35mm electrode array lengths).Predicate Device: IPG: 2.33 mm diameter, electrode array 1.3 mm diameter, 5.1 cm total length. Predicate electrode array length is 34mm.Reference Device: Lead = 1.30 mm diameter, 40 or 60 cm length, IPG = 28 x 11 x 4.9 mm.Analysis: Differences in electrode array lengths are negligible as therapy output remains the same between subject and predicate devices. |
| Configuration | Subject Device: Implanted antenna receiver, energy storage capacitor, stimulation pulse generator coupled with electrode arrays.Predicate Device: Same.Reference Device: Embedded receiver, flexible circuit board.Analysis: Same as K202781 |
| Electrical Components | Subject Device: Embedded receiver, flexible circuit board with energy storage and stimulation pulse generator.Predicate Device: Same.Reference Device: Same.Analysis: Same |
| Power Delivery | Subject Device: Radio frequency transmission receiver.Predicate Device: Same.Reference Device: Coupled receiver radio frequency transmission.Analysis: Same as K202781 |
| Electrode Material | Subject Device: Platinum-iridium 90:10Predicate Device: SameReference Device: SameAnalysis: Same |
| Insulation Body Material | Subject Device: Pellethane 2363-55DPredicate Device: SameReference Device: SameAnalysis: Same |
| Electrode Array Diameter | Subject Device: 1.30 mmPredicate Device: SameReference Device: SameAnalysis: Same |
| Electrode Array Length | Subject Device: 21 mm (Measured Start of First to End of Last Electrode)Predicate Device: SameReference Device: 52 mmAnalysis: Same as K202781 |
| No. of Electrodes per array | Subject Device: 4Predicate Device: SameReference Device: 8Analysis: Same as K202781 |
| Individual Electrode Length | Subject Device: 3 mmPredicate Device: SameReference Device: SameAnalysis: Same |
| Electrode Surface Area | Subject Device: 12.25 mm²Predicate Device: SameReference Device: 12.25 mm³ (likely a typo, should be mm²)Analysis: Same |
| Sterilization | Subject Device: Ethylene OxidePredicate Device: SameReference Device: SameAnalysis: Same |
| Pulse Frequency | Subject Device: 2 to 1500 HzPredicate Device: 4 to 130 HzReference Device: 2 to 1500 HzAnalysis: Neuspera Nuity pulse frequency range covers predicate device and is within range of reference device. Therefore, differences do not affect safety and effectiveness. |
| Pulse Width | Subject Device: 15 to 960 µsPredicate Device: 105 to 960 µsReference Device: 12 to 1000 µsAnalysis: Neuspera Nuity pulse width range covers predicate device and is within range of reference device. Therefore, differences do not affect safety and effectiveness. |
| Current/Voltage Regulated | Subject Device: Voltage or CurrentPredicate Device: VoltageReference Device: CurrentAnalysis: Adjustable between regulation mode of both predicate and reference devices. Therefore, differences do not affect safety and effectiveness. |
| Output Current | Subject Device: (300 Ohms) 0 to 5.73 mA*, (500 Ohms) 0 to 5.44 mA*, (800 Ohms) 0 to 5.20 mA*Predicate Device: SameReference Device: (all) 0 to 10.2 mAAnalysis: Same as K202781 (*measured with typical therapy pulse width of 240us) |
| Waveform | Subject Device: Charge balanced (delayed) biphasic asymmetricalPredicate Device: SameReference Device: SameAnalysis: Same |
| Pulse Shape | Subject Device: Decaying ExponentialPredicate Device: SameReference Device: SameAnalysis: Same |
| Maximum Phase Charge | Subject Device: (300 Ohms) 2.88 µC/pulse**, (500 Ohms) 2.74 µC/pulse**, (800 Ohms) 2.43 µC/pulse**Predicate Device: SameReference Device: (300 Ohms) 6.8 µC/pulse, (500 Ohms) 6.4 µC/pulse, (800 Ohms) 4.7 µC/pulseAnalysis: Same as K202781 (**measured with maximum pulse width of 960us) |
| Maximum Charge Density | Subject Device: (300 Ohm) 23.5 µC/cm2**, (500 Ohm) 22.4 µC/cm2**, (800 Ohm) 19.8 µC/cm2**Predicate Device: SameReference Device: (300 Ohm) 53.1 µC/cm², (500 Ohm) 50.3 µC/cm², (800 Ohm) 15.9 µC/cm2***Analysis: Same as K202781 |
| Maximum Current Density | Subject Device: (300 Ohm) 46.8 mA/cm2*, (500 Ohm) 44.4 mA/cm2*, (800 Ohm) 42.4 mA/cm2*Predicate Device: SameReference Device: (all) 26.5 mA/cm2***Analysis: Same as K202781 |
| Net Charge | Subject Device: 0 µCPredicate Device: SameReference Device: SameAnalysis: Same |
| Pulse Delivery Mode | Subject Device: ContinuousPredicate Device: SameReference Device: SameAnalysis: Same |
| Current Path Options | Subject Device: BipolarPredicate Device: SameReference Device: SameAnalysis: Same |
| Program Cycle | Subject Device: Cycle through programsPredicate Device: SameReference Device: SameAnalysis: Same |
| Pulse Pattern | Subject Device: Fine tuning of pulse patternsPredicate Device: SameReference Device: SameAnalysis: Same |
| Dosage Time | Subject Device: Cycling ON/OFF 1 second-1 dayPredicate Device: SameReference Device: SameAnalysis: Same |
| Biocompatibility | Subject Device: Complies with ISO 10993-1:2018 for long-term implant (>30 days) and limited duration tissue contact (<24 hours) for tools. Tested for genotoxicity, cytotoxicity, sensitization or intracutaneous reactivity, systematic toxicity, implant studies, and chemical characterization.Predicate Device: Implied equivalence.Reference Device: Implied equivalence.Analysis: Biocompatibility demonstrated. |
| Electrical Safety/Performance | Subject Device: Conforms to ES60601-1:2005/(R)2012, HA60601-1-11:2015, and 14708-3 Second edition 2017-04.Predicate Device: Implied equivalence.Reference Device: Implied equivalence.Analysis: Conforms to relevant standards. |
| Sterilization Validation | Subject Device: Conforms to 11135 Second edition 2014-07-15 (Ethylene Oxide sterilization).Predicate Device: Implied equivalence.Reference Device: Implied equivalence.Analysis: Conforms to relevant standards for sterilization. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document mentions "Non-clinical testing activities" including visual tests, dimensional measurement tests, tensile tests, mechanical tests, electrical tests, EMC tests, and MRI tests. These are bench tests, not clinical studies with patients. Therefore, clinical "sample size" and "data provenance" (country/retrospective/prospective) are not applicable to the non-clinical testing described.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not applicable. The document refers to non-clinical (bench) testing and substantial equivalence, not a clinical study involving expert interpretation or "ground truth" establishment for diagnostic or therapeutic outcomes in patients.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not applicable as there is no clinical "test set" in the context of expert adjudication described 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
This is not applicable. The device is a neurostimulation system for pain management, not an AI-assisted diagnostic or interpretative tool that would involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. The device is a physical neurostimulation system, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
This is not applicable in the context of a clinical performance study. For the non-clinical tests mentioned (e.g., electrical, mechanical, biocompatibility), the "ground truth" would be established by validated test methods and reference standards, rather than expert consensus or pathology data from patients.
8. The sample size for the training set
This is not applicable. The document describes a physical medical device, not an AI/ML algorithm that requires a training set.
9. How the ground truth for the training set was established
This is not applicable, as there is no training set for an AI/ML algorithm described in the document.
In summary:
The provided document is an FDA 510(k) clearance, which focuses on demonstrating substantial equivalence to a previously cleared predicate device. It primarily relies on non-clinical (bench) testing, engineering comparisons, and adherence to recognized standards to assure safety and effectiveness. It does not contain a detailed report of a clinical performance study with specific acceptance criteria, sample sizes for patient data, expert adjudication, or AI/ML algorithm validation.
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