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510(k) Data Aggregation

    K Number
    K251088
    Date Cleared
    2025-06-30

    (82 days)

    Product Code
    Regulation Number
    880.6305
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Otsuka Digital Feedback Device

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

    The Otsuka Digital Feedback Device consists of a miniaturized, wearable sensor for ambulatory recording of physiological and behavioral metrics such as heart rate, activity, body angle relative to gravity (body position), and time-stamped patient-logged events, including events signaled by co-incidence with, or co ingestion with, the ingestible sensor accessory. When the ingestible sensor is ingested, the Otsuka Digital Feedback Device is intended to log, track, and trend intake times. When co-ingested with medication, the tracking and trending of intake times may be used as an aid to measure medication adherence. The Otsuka Digital Feedback Device may be used in any instance where quantifiable analysis of event-associated physiological and behavioral metrics is desirable and enables unattended data collection for clinical and research applications.

    Device Description

    The Otsuka Digital Feedback Device consists of 3 components: a wearable sensor, an ingestible sensor accessory, and software that aggregates, processes, and enables display of data collected by the sensors.

    The wearable sensor in the Otsuka Digital Feedback Device is a body-worn sensor that consists of a single-use patch known as the D-Tect wearable sensor or D-Tect Patch. The D-Tect Patch collects physiological and behavioral metrics such as heart rate, activity, body angle, and time stamped patient-logged events, including events signaled by the co-incidence with, or co-ingestion with, the ingestible sensor accessory. Note: While the device includes automated heart rate (HR) measurement, it does not provide an ECG waveform recording for display or analysis. The device is not intended to diagnose heart-related conditions and does not include alarms. HR measurement is not intended to be used in alarm system. HR data may not be accurate for patients with pacemakers.

    The ingestible sensor is embedded inside an inactive tablet (the pill or sensor-enabled pill) for ease of handling and swallowing. After the ingestible sensor reaches the stomach, it activates and communicates its presence with a unique identifier to the wearable sensor. When the ingestible sensor is co-ingested with medication, the Otsuka Digital Feedback Device is intended to log, track, and trend medicine intake times to measure medication adherence.

    The software on the general computing device receives the data from the wearable sensor for further processing and analysis of metrics. The processed data is then sent to the user interface for display, as well as being saved in a local record database for storage. The software component includes firmware running on the wearable sensor that collects and records the data from the sensors and a software that receives data from the wearable sensor for further analysis, processing, storage, and display to the user.

    For purposes of this 510(k), the changes from the predicate device (Otsuka Digital Feedback Device-RW, K223463) to the Otsuka Digital Feedback Device with D-Tect Patch (the device subject of this 510[k]) are the wearable sensor and the software for the user interface. The ingestible sensor remains the same as the predicate device.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study that proves the Otsuka Digital Feedback Device meets them, based on the provided FDA 510(k) clearance letter.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document implicitly defines acceptance criteria through its performance testing sections. For the purpose of this analysis, I will focus on the most explicitly quantified performance metrics from the provided text.

    Performance CharacteristicAcceptance Criteria (from text)Reported Device Performance (from text)
    Wear Duration (Adherence)≥ 5 days in ≥ 50% of subjectsMinimum of 79.0% adherence for a minimum of 5 days (95% CI)
    Wear Duration (Extended Adherence)Not explicitly stated as a pass/fail criterion, but reported as an improvement.Minimum of 61.5% adherence for a minimum of 7 days (95% CI)
    Comfort> 3.5 (on a scale of 1-5 where 5 = very comfortable)Average comfort rating of 4.7 (very comfortable)
    Skin Irritation (Safety)Similar safety profile to predicate device, no new safety concerns identified.7/55 (12.7%) subjects experienced Grade 1 or 2 AE; 6/55 (10.9%) Grade 1; 2/55 (3.6%) Grade 2. All other subjects Grade 0. Similar to predicate.
    Pill Detection CapabilityNot explicitly quantified, but stated as an "Improvement" over predicate.Enhanced low-noise analog front end improves sensitivity of IEM detection by >50%.
    Step CountingNot explicitly quantified, but stated as an "Improvement" over predicate.Improved step metric based on passive fully continuous step counting.
    Heart Rate MeasurementsNot explicitly quantified, but stated as an "Improvement" over predicate.Verified against real ECG signals and 100% measurement accuracy for simulated ECG signal.
    BiocompatibilityCompliant with ISO 10993 standards (Irritation, Cytotoxicity, Sensitization)Deemed compliant with ISO 10993-23-2021, ISO 10993-5-2009, and ISO 10993-10-2021.
    Shelf LifeVerified shelf life3-years from the date of manufacturing.
    Mechanical & ElectricalMeets all requirements and specifications.Formal verification testing with passing results for LED, button, integrity, dimensions, water ingress, vibration, impact, push, drop, markings, static, functional, environmental.
    Patient Electrical Safety (IEC 60601-1)Compliant with IEC 60601-1, -1-2, -1-11, -1-6.Compliant with all applicable requirements of IEC 60601-1: 2005 + A1:2012 + A2:2020, IEC 60601-1-2: 2014 + A1:2020, IEC 60601-1-11: 2015 + A1:2020, IEC 60601-1-6: 2010 + A1:2013 + A2:2020.
    EMC (IEC 60601-1-2)Meets IEC 60601-1-2 EMC standard (third and fourth edition). RF Emissions CISPR 11 Group 1, Class B; RF Immunity IEC 61000-4-3 Level 3; ESD Immunity IEC 61000-4-2 Level 4.Meets requirements. Patch, mobile device, and software underwent evaluation.
    Device Software (Firmware & Mobile App)Meets requirements, no anomalies impacting performance/safety/effectiveness.All identified requirements tested and successfully passed. No unresolved issues.
    CybersecurityCompliant with FDA guidance, FD&C Act, AAMI/UL 2900-1, AAMI TIR-57, NIST SP 800-30, ISO 14971. No critical vulnerabilities in third-party testing.Verified compliance, applicable security tests conducted. No critical vulnerabilities found.

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

    • Sample Size (Clinical Performance Data): A total of 55 subjects were tested for the clinical performance evaluation.
    • Data Provenance: The study was conducted at 1 site in the United States. It was a prospective noninterventional validation study in healthy subjects.

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

    The document does not specify the number or qualifications of experts used to establish a "ground truth" for the test set in the conventional sense (e.g., radiologists reviewing images). The clinical performance study focused on objective measurements like wear duration, comfort ratings self-reported by subjects, and skin irritation scores, which are typically assessed by trained clinical staff rather than expert consensus on a diagnostic outcome. Skin irritation scores are based on established clinical grading scales.

    4. Adjudication Method for the Test Set

    The document does not describe an explicit adjudication method (like 2+1 or 3+1 consensus) for the test set. For the wear duration, comfort, and skin irritation metrics, the data collection methods (instrumental recording for wear duration, self-reporting for comfort, and clinical scoring for irritation) are inherently less reliant on such adjudication compared to subjective diagnostic tasks.

    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 was mentioned in this document. The device, an "Ingestible Event Marker with wearable patch," is primarily focused on automated data collection for physiological and behavioral metrics and medication adherence, not on aiding human readers in interpreting complex diagnostic images or data where "AI assistance" would directly improve a reader's performance in a diagnostic task.

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

    Yes, the testing described appears to largely cover standalone algorithm and device performance, particularly for:

    • Pill Detection Capability: "Enhanced low-noise analog front end improves sensitivity of the IEM detection by >50%, increasing the likelihood of detection." This is an intrinsic algorithmic/hardware capability.
    • Step Counting: "Improved step metric based on passive fully continuous step counting." This is an algorithmic function.
    • Heart Rate Measurements: "Verified against real ECG signals and 100% measurement accuracy for simulated ECG signal." This tests the algorithm's performance.
    • Wear Duration: This is objectively measured by the device's logging capability.

    The clinical performance study focuses on the overall system's ability to log data correctly and be comfortable and safe, which inherently relies on the standalone performance of its components.

    7. The Type of Ground Truth Used

    • Wear Duration: Objective logging by the device itself, validated against study protocols of subjects wearing patches for specified periods.
    • Comfort: Subject self-reporting on a defined scale.
    • Skin Irritation: Clinical assessment based on established grading scales (Grade 0, 1, 2).
    • Pill Detection, Step Counting, Heart Rate: Verified against reference methods/signals (e.g., real ECG signals, simulated ECG signals).
    • Mechanical, Electrical, Software, Cybersecurity, Biocompatibility, Shelf Life: Ground truth is defined by compliance with applicable standards, specifications, and successful completion of pre-defined test protocols.

    8. The Sample Size for the Training Set

    The document does not provide details on the sample size used for the training set of any algorithms within the device. It focuses on the validation of the finalized device.

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

    Since the document does not mention the training set size, it also does not elaborate on how the ground truth for any potential training data was established. The improvements noted (e.g., improved pill detection, step counting, HR measurements) suggest iterative development and potentially machine learning, but the specifics of their training data and ground truth are not detailed in this regulatory summary.

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    K Number
    K223463
    Date Cleared
    2023-08-11

    (268 days)

    Product Code
    Regulation Number
    880.6305
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Otsuka Digital Feedback Device-RW

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

    The Otsuka Digital Feedback Device-RW consists of a miniaturized, wearable sensor for ambulatory recording of physiological and behavioral metrics such as heart rate, activity, body angle relative to gravity (body position), and timestamped patient-logged events, including events signaled by the co-incidence with, or co-ingestible sensor accessory. When the ingestible sensor is ingested, the Otsuka Digital Feedback Device-RW is intended to log, track and trend intake times. When co-ingested with medication, the tracking of intake times may be used as an aid to measure medication adherence. The Otsuka Digital Feedback Device-RW may instance where quantifiable analysis of event-associated physiological and behavioral metrics is desirable, and enables unattended data collection for clinical and research applications.

    Device Description

    The Otsuka Digital Feedback Device-RW consists of three components: a wearable sensor, an ingestible sensor accessory, and software that aggregates, processes and enables display of data collected by the sensors. The wearable sensor is a body-worn sensor (also called the patch) that collects physiological and behavioral metrics such as heart rate, activity, body angle, and time-stamped patient-logged events, including events signaled by the co-incidence with, or co-ingestion with, the ingestible sensor accessory. The wearable sensor in the Otsuka Digital Feedback Device-RW is a 2-component patch known as the RW2 wearable sensor or RW2 patch. The ingestible sensor is embedded inside an inactive tablet (the pill or sensor-enabled pill) for ease of handling and swallowing. After the ingestible sensor reaches the stomach, it activates and communicates its presence with a unique identifier (ID) to the wearable sensor. When the ingestible sensor is co-ingested with medication, the Otsuka Digital Feedback Device-RW is intended to log, track and trend medicine intake times to measure medication adherence. The software on a general computing device (eg, mobile device) receives the data from the body-worn sensor or patch for further processing and analysis of the behavioral and physiological metrics. The processed data is then sent to the user interface (UI) for display as well as being saved in a local record database for storage.

    AI/ML Overview

    The provided text describes the Otsuka Digital Feedback Device-RW, which is an ingestible event marker with a wearable patch. The primary function highlighted is logging and trending medication intake times to aid in measuring medication adherence, as well as tracking physiological and behavioral metrics.

    However, the document is an FDA 510(k) clearance letter and its associated summary. While it mentions "acceptance criteria" for "firmware verification, mechanical verification, electrical verification, biocompatibility evaluation, and system verification testing," it does not provide specific numerical acceptance criteria for the device's performance in its intended use (i.e., accurately tracking ingestion or medication adherence). It also clarifies that no new clinical studies were performed to support the changes in this submission, indicating that the performance data for the core functionality would likely be derived from previous predicate device studies or non-clinical testing.

    Therefore, many of the requested details about a study proving the device meets acceptance criteria related to its clinical performance (e.g., accuracy of ingestion detection, improved human reader performance with AI) cannot be extracted directly from this document. The document focuses on showing substantial equivalence to a predicate device, based on similar technology, non-clinical testing, and existing clinical data from the predicate for some aspects.

    Based on the provided text, here's what can be extracted and what cannot:


    1. A table of acceptance criteria and the reported device performance

    The document mentions acceptance criteria were met for:

    • Firmware verification
    • Mechanical verification
    • Electrical verification
    • Biocompatibility evaluation
    • System verification testing

    No specific numerical acceptance criteria or performance metrics related to the core function of "logging, tracking, and trending intake times" or "measuring medication adherence" are provided in this document. The document states "The results demonstrate that the acceptance criteria for firmware verification, mechanical verification, electrical verification, biocompatibility evaluation, and system verification testing were met," but it does not quantify these.


    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 explicitly states: "However, new clinical studies were not performed to support the changes proposed in this submission." It implies that any performance data for the core functions relies on the predicate devices. Therefore, details about sample size, provenance, and retrospective/prospective nature of a new clinical test set are not available in this document.

    The document mentions: "Clinical studies were conducted to support the expanded wear location of the patch to include the entire front abdomen." This suggests some clinical data was generated for this specific change, but details on sample size, design, or performance metrics for that specific study are not provided.


    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)

    Not applicable, as no new clinical study on the primary function is detailed, and the document does not describe efforts to establish ground truth with experts for the device's performance (e.g., in medication adherence).


    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable, as no new clinical study on the primary function is detailed.


    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. This device is an ingestible event marker and wearable sensor, not an AI-assisted diagnostic imaging device that would typically involve human "readers" interpreting images. Its purpose is data collection (ingestion times, physiological metrics), not interpretation by human experts.


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

    The device itself is essentially a "standalone" data collection system. It's intended to continuously log data without constant human intervention.

    • Performance: The document indicates non-clinical verification and validation testing was done (firmware, mechanical, electrical, system testing), and those "acceptance criteria were met." However, no quantifiable performance metrics for the device's accuracy in detecting ingestion events are provided.

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

    The document does not specify the method for establishing ground truth for ingestion events or medication adherence from any past studies. Given the nature of the device (detecting ingestion), ground truth likely involves direct observation or very high-fidelity data from a controlled setting.


    8. The sample size for the training set

    Not applicable to this document. The document describes a medical device cleared via 510(k), not an AI/ML model for which a "training set" in the computational sense would be explicitly outlined. While the device contains firmware and software, the development process and data used for its internal algorithms are not detailed here as a separate "training set."


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

    Not applicable, as explained in point 8.

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