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510(k) Data Aggregation

    K Number
    K221303
    Date Cleared
    2023-04-11

    (341 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    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.

    Device Description

    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.

    AI/ML Overview

    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 UseSubject 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 & ClassSubject Device: GZF, Class IIPredicate Device: SameReference Device: SameAnalysis: Same
    Regulation NumberSubject Device: 21 CFR §882.5870Predicate Device: SameReference Device: SameAnalysis: Same
    Classification NameSubject Device: Implanted peripheral nerve stimulator for pain reliefPredicate Device: SameReference Device: SameAnalysis: Same
    Prescription Use?Subject Device: YesPredicate Device: SameReference Device: SameAnalysis: Same
    Implant SiteSubject Device: Adjacent to nerves peripheral to central nervous system, excluding craniofacial region.Predicate Device: SameReference Device: SameAnalysis: Same
    Environmental UseSubject Device: Hospital, HomePredicate Device: SameReference Device: SameAnalysis: Same
    Intended ClinicianSubject Device: Orthopedic, Neurosurgeon, AnesthesiologistPredicate Device: SameReference Device: SameAnalysis: Same
    Intended UserSubject Device: Physician, LaypersonPredicate Device: SameReference Device: SameAnalysis: Same
    Mode of ActionSubject 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 ConcernSubject 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.
    ConfigurationSubject 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 ComponentsSubject Device: Embedded receiver, flexible circuit board with energy storage and stimulation pulse generator.Predicate Device: Same.Reference Device: Same.Analysis: Same
    Power DeliverySubject Device: Radio frequency transmission receiver.Predicate Device: Same.Reference Device: Coupled receiver radio frequency transmission.Analysis: Same as K202781
    Electrode MaterialSubject Device: Platinum-iridium 90:10Predicate Device: SameReference Device: SameAnalysis: Same
    Insulation Body MaterialSubject Device: Pellethane 2363-55DPredicate Device: SameReference Device: SameAnalysis: Same
    Electrode Array DiameterSubject Device: 1.30 mmPredicate Device: SameReference Device: SameAnalysis: Same
    Electrode Array LengthSubject 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 arraySubject Device: 4Predicate Device: SameReference Device: 8Analysis: Same as K202781
    Individual Electrode LengthSubject Device: 3 mmPredicate Device: SameReference Device: SameAnalysis: Same
    Electrode Surface AreaSubject Device: 12.25 mm²Predicate Device: SameReference Device: 12.25 mm³ (likely a typo, should be mm²)Analysis: Same
    SterilizationSubject Device: Ethylene OxidePredicate Device: SameReference Device: SameAnalysis: Same
    Pulse FrequencySubject 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 WidthSubject 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 RegulatedSubject 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 CurrentSubject 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)
    WaveformSubject Device: Charge balanced (delayed) biphasic asymmetricalPredicate Device: SameReference Device: SameAnalysis: Same
    Pulse ShapeSubject Device: Decaying ExponentialPredicate Device: SameReference Device: SameAnalysis: Same
    Maximum Phase ChargeSubject 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 DensitySubject 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 DensitySubject 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 ChargeSubject Device: 0 µCPredicate Device: SameReference Device: SameAnalysis: Same
    Pulse Delivery ModeSubject Device: ContinuousPredicate Device: SameReference Device: SameAnalysis: Same
    Current Path OptionsSubject Device: BipolarPredicate Device: SameReference Device: SameAnalysis: Same
    Program CycleSubject Device: Cycle through programsPredicate Device: SameReference Device: SameAnalysis: Same
    Pulse PatternSubject Device: Fine tuning of pulse patternsPredicate Device: SameReference Device: SameAnalysis: Same
    Dosage TimeSubject Device: Cycling ON/OFF 1 second-1 dayPredicate Device: SameReference Device: SameAnalysis: Same
    BiocompatibilitySubject 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/PerformanceSubject 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 ValidationSubject 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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