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510(k) Data Aggregation
(192 days)
Prismira is a digital therapeutic indicated to improve attention function in adults ages 22-55 years old with primarily inattentive or combined-type Attention Deficit and Hyperactivity Disorder (ADHD). Patients who engage with Prismira demonstrate improvements in a digitally assessed measure of sustained and selective attention, Test of Variables of Attention (TOVA), and may not display benefits in typical behavioral symptoms, such as hyperactivity.
Prismira should be considered for use as part of a therapeutic program that may include clinician directed therapy, medication, and/or educational programs, which further address symptoms of the disorder.
Prismira is software-as-a-medical device (SaMD) that resides on the user's mobile device and can be executed at home.
Prismira is a prescription digital therapeutic indicated to improve attention function in patients 22 and older with primarily inattentive or combined type ADHD. Patients who engage with Prismira demonstrate improvements in attention functioning and may not display benefits in other behavioral symptoms such as hyperactivity. Prismira is intended to be used as part of a therapeutic program that may include clinician-directed therapy, medication, and/or educational programs, which further address symptoms of the disorder.
The Prismira App also includes an Engagement System to promote compliance with the treatment. The Engagement System gives the patient encouragement and feedback on progress at multiple timescales: performance on the most recent gameplay and historical game performance, completion of the daily assignment, progress toward the weekly target in the current week, and historical assignment completion.
Each game includes visual and optional auditory stimulus presentation. The basic input from the patient includes physical interaction with a touch screen accomplished by using the mobile device. The device's feedback within each game includes visual and optional auditory responses to the inputs. Output from each game includes a score earned by playing the game. Each gameplay is brief, typically between 1 and 5 minutes in duration, depending on the game. The treatment program guides patients through an ordered list of games (the "script") that enables subjects to engage in the recommended daily regimen (approximately 15 minutes per day).
Here's a breakdown of the acceptance criteria and study details for the Prismira device, based on the provided FDA 510(k) clearance letter:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (as implied by study success and substantial equivalence claims):
- Primary Endpoint: Statistically significant improvement in TOVA ACS in the LLM-001 therapy arm compared to the control arm.
- Safety: No new or increased safety risks compared to the predicate device, and a favorable safety profile with minimal adverse events.
| Metric / Endpoint | Acceptance Criteria (Implied) | Reported Device Performance (Prismira / LLM-001) |
|---|---|---|
| Primary Endpoint: TOVA ACS Change from Baseline at Day 63 | Statistically significant difference between active and control arms. | - LLM-001 Change from Baseline Mean: 1.1 points (SD=3.6) - Control Change from Baseline Mean: 0.3 points (SD=3.6) - LSM Difference (LLM-001 - Control): 0.78 points (SE=0.32) - LSM Difference p-value: 0.0149 (statistically significant) - LSM improvement of 1.09 points was less than the recognized MCID of 1.4 points, but notably greater than the predicate device (0.93 points). |
| Secondary Endpoint: CGI-I | Improvement over control (desirable for clinical benefit). | Superior clinical benefit for the LLM-001 arm over control (p=0.0087). (For LLM-001 subjects, 32.1% were assessed as "very much improved" on the CGI-I). |
| Secondary Endpoint: ADHD-RS Total Score | Improvement over control (desirable for clinical benefit). | 30.4% of LLM-001 subjects experienced greater than 30% reduction in their ADHD symptoms based on ADHD-RS total score. (Numerically favored LLM-001, but no statistically meaningful differences between groups for the continuous measure). |
| Adverse Events (AEs) | Minimal; no serious AEs; low treatment-related AE rate. | - No serious adverse events reported. - Only two treatment-related AEs (frustration) out of 275 LLM-001 treated subjects (AE rate of 0.7%). - No subjects exited early for medical or gameplay-related complaints. |
| Treatment Compliance | High, demonstrating feasibility of use. | Mean of 874.7 minutes (97.2%) of 900 expected minutes. |
2. Sample Size and Data Provenance for the Test Set (Clinical Study)
- Sample Size: 560 subjects were enrolled in The GAMES Study.
- Safety Population: All 560 subjects.
- Intent-to-Treat (ITT) Population: 456 subjects (224 randomized to LLM-001 active therapy, 232 to control therapy) who successfully completed gameplay treatment and Day 63 follow-up assessments.
- Data Provenance: Not explicitly stated (e.g., country of origin). However, it was a "multi-center" clinical trial, suggesting diverse locations. It was a prospective, randomized, double-blind, parallel-group, sham-controlled clinical trial.
3. Number of Experts and Qualifications for Ground Truth (Test Set)
- The study used blinded clinicians to assess the CGI-I (Clinical Global Impression-Improvement), a global measure of clinical improvement.
- Qualifications of Experts: Not explicitly stated beyond "blinded clinicians." Their expertise would be in diagnosing and assessing ADHD.
4. Adjudication Method for the Test Set
- The primary effectiveness measure (TOVA ACS) was a digitally assessed measure, so it wouldn't typically require human adjudication in the same way imaging studies might.
- For the CGI-I, it was assessed by "blinded clinicians." This implies independent assessment rather than a consensus/adjudication process among multiple experts for each individual case's outcome on this specific measure. The "blinded" nature is the key control here.
- There's no mention of a 2+1, 3+1, or other specific adjudication method for the clinical endpoints.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC comparative effectiveness study was not done. This type of study typically applies to diagnostic imaging devices where human readers interpret medical images with and without AI assistance.
- This study was a randomized controlled clinical trial evaluating a digital therapeutic, focusing on its direct effect on patient outcomes (attention function) compared to a control.
6. Standalone Performance Study
- Yes, a standalone (algorithm only) performance study was done in the context of the clinical trial.
- The "LLM-001 active therapy" arm represents the device's performance when used by the patient as intended, without direct human-in-the-loop interaction from the algorithm's perspective. The clinicians were involved in diagnosis and overall patient care, but the daily therapeutic delivery was directly from the device to the patient.
- The primary endpoint, "change from baseline in the digitally assessed measure of sustained and selective attention, the Test of Variables of Attention (TOVA®)," is a direct measure of the algorithm's effect on attention function.
7. Type of Ground Truth Used (Clinical Study)
- The primary ground truth for effectiveness was derived from the Test of Variables of Attention (TOVA®) Attention Comparison Score (ACS), a digitally assessed, objective measure of sustained and selective attention. This is a standardized, quantitative neuropsychological assessment tool.
- Secondary ground truths included:
- ADHD-RS: ADHD Rating Scale, likely a clinician-rated symptom scale or patient-reported outcome.
- CGI-I: Clinical Global Impression-Improvement, a clinician-assessed global measure of improvement.
- BRIEF-A: Behavior Rating Inventory of Executive Function – Adult, likely a patient-reported or clinician-rated scale.
- WFIRS-S: Weiss Functional Impairment Rating Scale – Self Report, a patient-reported outcome.
- AAQoL: Adult ADHD Quality of Life Questionnaire, a patient-reported outcome.
- Diagnosis of ADHD (combined or inattentive type) was confirmed using the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (DSM-5) criteria and confirmed by the Mini-International Neuropsychiatric Interview (MINI) for ADHD adult version.
8. Sample Size for the Training Set
- The document does not explicitly state the sample size for the training set used to develop the Prismira algorithm. The provided clinical study (The GAMES Study) is the pivotal validation study designed to test the already developed device.
- The device description mentions an "Adaptive algorithm and Engagement System." Adaptive algorithms are often trained on large datasets, but the details of that training process and dataset size are not included in this 510(k) summary. References ¹ and ² hint at large-scale cognitive training data and online trials, which might relate to the algorithm's development.
9. How Ground Truth for the Training Set Was Established
- Similar to the training set sample size, the document does not explicitly describe how ground truth for the training set was established.
- Given that it's an "adaptive algorithm," training data would likely involve cognitive performance metrics and potentially diagnostic information from previous patient populations. This could involve using standardized cognitive tests (like TOVA or similar measures) as the "ground truth" to train the algorithm to improve performance on those measures.
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(242 days)
Prism is a neurofeedback software device intended for relaxation and stress reduction through the use of EEG biofeedback. The device is indicated as an adjunctive treatment of symptoms associated with posttraumatic stress disorder (PTSD), to be used under the direction of a healthcare professional, together with other pharmacological and/or non-pharmacological interventions.
Prism is a software as medical device, to be prescribed for treatment of patients with PTSD by clinicians as adjunct to standard of care. Prism is a software device running on a laptop that uses EEG signal input from an EEG device (g.Nautilos PRO (K171669)). Prism therapy consists of 15, 30-minute sessions and optional periodic refresher sessions. During a session, the patient is connected to 8 or more EEG channels and views an interactive audio/visual interface.
Acceptance Criteria and Device Performance Study for Prism Device
The Prism device is a neurofeedback software device intended for relaxation and stress reduction through the use of EEG biofeedback, specifically indicated as an adjunctive treatment for symptoms associated with Posttraumatic Stress Disorder (PTSD). The acceptance criteria for its effectiveness were defined by the primary performance measure of a prospective, single-arm, open-label, unblinded study.
The primary effectiveness hypothesis was that from baseline to the 3-month follow-up, at least 50% of study participants would experience a response to the treatment, defined as a 6-point reduction in the Clinician Administered PTSD Scale (CAPS-5) score from baseline.
1. Acceptance Criteria and Reported Device Performance
Table: Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Primary Endpoint) | Reported Device Performance (Efficacy Analysis Set) |
|---|---|
| At least 50% of study participants will experience a 6-point (or more) reduction in CAPS-5 score from baseline to the 3-month follow-up visit. | 66.67% of participants showed a ≥6-point reduction in CAPS-5 at 3 months follow-up. |
| Secondary Performance Measures (additional context, not primary acceptance criteria): - 54.55% of participants showed a ≥10-point reduction in CAPS-5 at 3 months follow-up. - 50.00% of participants showed a ≥13-point reduction in CAPS-5 at 3 months follow-up. |
Safety Acceptance Criteria (Implicit):
The pre-specified safety goals of the study were met, indicating an acceptable safety profile. This would implicitly mean that the incidence and severity of adverse events were within acceptable clinical limits for the target population and device type.
2. Sample Size and Data Provenance
-
Test Set (Clinical Study Participants):
- Screened: 101 subjects
- Full Analysis Dataset: 79 subjects
- Efficacy Analysis Set: 66 subjects (This is the primary sample size for evaluating the effectiveness against the acceptance criteria).
- Per-Protocol Analysis Set: 63 subjects
-
Data Provenance: The study was a prospective, single-arm, open-label, unblinded study. It was conducted at 4 sites outside the United States (OUS) in Israel and one US site. This indicates a combination of Israeli and US data.
3. Number of Experts and Qualifications for Ground Truth
The document does not explicitly state the number of experts used to establish ground truth for the test set. However, it mentions:
- Diagnosis of PTSD: Established according to the DSM-5 criteria and CAPS-5.
- Clinician assessments: Performed and documented by the investigator or qualified and trained designee.
This implies that the ground truth for PTSD diagnosis and symptom severity (CAPS-5 scores) was established by licensed healthcare professionals (investigators or their designees) who were qualified to administer and interpret DSM-5 and CAPS-5. While specific qualifications (e.g., "radiologist with 10 years of experience") are not provided, "qualified and trained designee" suggests adherence to clinical standards for diagnostic assessment.
4. Adjudication Method for the Test Set
The document does not describe a formal adjudication method (like 2+1 or 3+1 consensus) for the initial PTSD diagnosis or CAPS-5 scoring. The assessments were performed by the "investigator or qualified and trained designee." This implies that the initial assessment by a single qualified professional served as the ground truth.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
There is no indication of a Multi-Reader Multi-Case (MRMC) comparative effectiveness study comparing human readers with and without AI assistance. The study described is a single-arm clinical study evaluating the device's adjunctive efficacy.
6. Standalone (Algorithm Only) Performance
The study evaluates the Prism software in conjunction with an EEG device (g.Nautilos PRO) as an adjunctive treatment for PTSD. Therefore, this is not a study of standalone algorithm performance without human-in-the-loop, as the device provides visual feedback to the patient to aid in learning to control EEG activity, and it is used under the direction of a healthcare professional.
7. Type of Ground Truth Used
The ground truth for effectiveness was based on:
- Clinical Assessments: Clinician Administered PTSD Scale (CAPS-5) scores. CAPS-5 is a structured interview administered by a trained clinician and is considered the gold standard for PTSD diagnosis and severity assessment.
- Self-Report Questionnaires: (Secondary measures, not primary ground truth for the acceptance criteria) PTSD Checklist for DSM-5 (PCL-5), Emotion Regulation Questionnaire (ERQ), Patient Health Questionnaire (PHQ-9), Clinical Global Impression (CGI).
8. Sample Size for the Training Set
The document does not provide information regarding the training set size or how the device's algorithms were trained. The provided text describes the clinical study for device validation, not the development or training phase of the software.
9. How Ground Truth for Training Set was Established
As information on the training set is not provided, the method for establishing its ground truth is also not described in this document.
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(259 days)
The Prismaflex ST set is a single use device that provides blood purification through a semipermeable membrane.
The Prismaflex ST set is for use only in conjunction with the PrismaFlex control unit or with the PrisMax control unit (in countries where PrisMax is cleared or registered).
All treatments administered via the PrismaFlex ST sets must be prescribed by a physician. The size, weight, state of uremia, cardiac status, and general physical condition of the patient must be carefully evaluated by the prescribing physician before each treatment.
If patients suffer from acute kidney injury and / or volume overload, the Prismatlex ST set is indicated for continuous renal replacement therapies (CRRT), in modalities such as:
- · Slow Continuous UltraFiltration (SCUF)
- · Continuous Veno-Venous Hemofiltration (CVVH)
- · Continuous Veno-Venous HemoDialysis (CVVHD)
- Continuous Veno-Venous HemoDiaFiltration (CVVHDF)
to perform fluid management and reduction of uremic toxins.
The Prismaflex ST100 and ST150 set is indicated for use in patients with a body weight equal or greater than 30 kg (661b) and Prismaflex ST60 set is indicated to patients with a body weight greater than 11kg (24lb).
The Prismaflex ST60/ST100/ST150 set is a disposable, extracorporeal circuit for use with the PrismaFlex system, or with the PrisMax system. The Prismaflex ST60/ST100/ST150 set consists of an AN69 ST hollow fiber haemofilter/dialyser and tubing system.
These Prismaflex disposable sets allow the following fluid management and renal replacement therapies to be performed :
- SCUF: Slow Continuous Ultrafiltration
- CVVH: Continuous Veno-Venous Hemofiltration
- CVVHD: Continuous Veno-Venous Hemodialysis
- CVVHDF: Continuous Veno-Venous Hemodiafiltration
The fluid pathways of the Prismaflex set are guaranteed sterile and pyrogen-free. The Prismaflex set is sterilized by ethylene oxide (EO).
The shelf life of the Prismaflex ST60/ST100/ST150 sets is 24 months from the date of sterilization. The device is intended for single use.
The provided text describes a 510(k) premarket notification for the "Prismaflex ST set" (ST60/ST100/ST150 sets), a high permeability hemodialysis system. The submission aims to demonstrate substantial equivalence to legally marketed predicate devices. The document focuses on non-clinical testing to support this claim.
Here's an analysis of the acceptance criteria and the study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present a table of acceptance criteria with corresponding device performance values like a clinical trial report would for specific endpoints (e.g., sensitivity, specificity for diagnostic devices, or specific measurable outcomes for therapeutic devices).
Instead, it states that the device was evaluated against established international standards and internal performance requirements. The "reported device performance" is described qualitatively as meeting these standards and requirements.
Here's a synthesized representation based on the information provided, inferring "acceptance criteria" from the standards and tests mentioned:
| Acceptance Criteria Category | Reported Device Performance (as stated) |
|---|---|
| Structural Integrity | Successfully verified and validated. Complies with ISO 8637-1 (mechanical characteristics). |
| Membrane Integrity | Successfully verified and validated. Complies with ISO 8637-1 (mechanical characteristics). |
| Ultrafiltration Rate | Successfully verified and validated. Complies with ISO 8637-1 (performance characteristics - ultrafiltration coefficient). |
| Clearances | Successfully verified and validated. Complies with ISO 8637-1 (performance characteristics - solute clearances). |
| Sieving Coefficients | Successfully verified and validated. Complies with ISO 8637-1 (performance characteristics - sieving coefficients). |
| Blood Pressure Drop | Successfully verified and validated. Complies with ISO 8637-1 (volume and pressure drop of blood compartment). |
| Total Volume of Blood | Successfully verified and validated. Complies with ISO 8637-1 (volume and pressure drop of blood compartment). |
| Priming Efficacy | Successfully verified and validated. |
| Shelf Life | Successfully verified and validated. 24 months from sterilization date. Complies with ISO 8637-1 (expiry date) and ISO 8638 (expiry date). |
| Sterilization Validation | Successfully verified and validated. EO sterilization. Complies with ISO 8637-1 (sterility) and ISO 8638 (sterility). |
| Pyrogenicity / LAL | Successfully verified and validated. Complies with ISO 8637-1 (non-pyrogenicity) and ISO 8638 (non-pyrogenicity). |
| EO Residuals | Successfully verified and validated. |
| Biocompatibility | Successfully verified through a battery of tests (Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Material Mediated Pyrogen, Subacute/Subchronic Toxicity, Hemolysis) in accordance with ISO 10993-1, -4, -5, -10, -11. |
| Design Validation | The Prismaflex ST set design validation meets user needs and intended use, and is substantially equivalent to the predicate. |
| Tubing Compliance | Complies with ISO 8638 (tubing compliance). |
| Risk Assessment | Risk analysis confirms the device is appropriately designed, performs as expected, and in a safe manner. |
2. Sample Size Used for the Test Set and Data Provenance
The provided text describes non-clinical bench and pre-clinical testing. These are laboratory-based tests of the device's physical and chemical properties, as well as its interaction with biological models (e.g., blood, cell cultures).
- Sample Size for Test Set: The document does not specify the exact number of units/sets tested for each performance characteristic. In bench testing for medical devices, this often involves a pre-defined number of samples per batch or according to a statistical sampling plan to ensure reliability and representativeness for the specific test (e.g., n=3, n=5, n=10 per test condition). However, these specific numbers are not disclosed in this summary.
- Data Provenance: The data provenance is from non-clinical (bench and pre-clinical) laboratory testing. There is no mention of human subject data, retrospective, or prospective studies involving patients.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This question is not applicable to the type of study described. "Ground truth" established by experts (like radiologists for image analysis) is relevant for clinical studies, especially those involving human interpretation or diagnostic accuracy. The studies detailed here are non-clinical, focusing on the device's physical and chemical performance, where "ground truth" is typically defined by objective measurements against established engineering specifications and international standards, not expert consensus.
4. Adjudication Method for the Test Set
This question is not applicable. Adjudication methods (e.g., 2+1, 3+1) refer to procedures for resolving disagreements among multiple human readers/experts in clinical studies, particularly in diagnostic accuracy assessments. As this is a non-clinical device performance study, such a method would not be used.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No, an MRMC comparative effectiveness study was not done. The document explicitly states that the safety and performance were evaluated through non-clinical testing. There is no mention of human readers, AI assistance, or comparative effectiveness studies involving human-in-the-loop performance.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
This question is not applicable. The device described, the "Prismaflex ST set," is a medical device for blood purification (hemodialysis/hemofiltration), not an AI algorithm or a diagnostic tool that would typically have a "standalone" algorithmic performance. The "performance" here refers to its physical and functional operation.
7. Type of Ground Truth Used
The "ground truth" for these non-clinical tests is established by:
- Objective Measurements: Directly measuring physical and chemical properties (e.g., ultrafiltration rate, clearances, pressure drop) using calibrated equipment.
- International Standards: Compliance with recognized international standards (ISO 8637-1, ISO 8638, ISO 10993 series) which define acceptable ranges and methodologies.
- Device Specifications: Meeting internal design specifications for the device.
There is no use of expert consensus, pathology, or outcomes data as "ground truth" in these non-clinical tests.
8. Sample Size for the Training Set
This question is not applicable. The Prismaflex ST set is a hardware medical device; its development and validation do not involve "training sets" in the context of machine learning or AI algorithms. The "training" that occurs is in the manufacturing and quality control processes to ensure consistency and adherence to specifications.
9. How the Ground Truth for the Training Set Was Established
This question is not applicable, as there is no "training set" in the context of an AI/machine learning algorithm for this device.
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(87 days)
The PrisMax control unit is intended for:
· Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload.
• Therapeutic Plasma Exchange (TPE) therapy for patients weighing 20 kilograms or more with diseases where removal of plasma components is indicated.
All treatments administered via the PrisMax control unit must be prescribed by a physician.
The PrisMax System is intended for Continuous Renal Replacement Therapy (CRRT) for patients with acute renal failure and/or fluid overload. The goals of acute renal failure treatments are removal of waste products, restoration of acid-base balance; correction of electrolyte imbalances (e.g., hyperkalemia), patient fluid balance, nutritional support, and other conditions in which fluid removal is needed. PrisMax System offers four Continuous Renal Replacement Therapy (CRRT) options: Slow Continuous Ultrafiltration (SCUF), Continuous Veno-Venous Hemofiltration (CVVH), Continuous VenoVenous Hemodialysis (CVVHD), and Continuous Venovenous Hemodialfiltration (CVVHDF). The proposed device PrisMax System Version 3 uses the current marketed device PrisMax System Version 2 as the predicate.
This document is a 510(k) Pre-market Notification for a medical device, the PrisMax System Version 3. The document aims to demonstrate that the new device is substantially equivalent to a legally marketed predicate device (PrisMax System Version 2), and therefore does not require a new premarket approval application (PMA).
Here's an analysis of the provided information regarding acceptance criteria and the supporting study, organized by your requested points:
Acceptance Criteria and Device Performance
The acceptance criteria are implicitly defined by the technical specifications outlined in the "Substantial Equivalence Summary" tables (Table 3), comparing the PrisMax System Version 3 to the predicate PrisMax System Version 2. The reported device performance is stated as meeting these specifications, thereby achieving "substantial equivalence" to the predicate.
Table 1: Acceptance Criteria and Reported Device Performance
| Feature | Acceptance Criteria (Predicate PrisMax Version 2) | Reported Device Performance (PrisMax Version 3) |
|---|---|---|
| Indications for Use | Continuous Renal Replacement Therapy (CRRT) for patients ≥ 20 kg with acute renal failure/fluid overload; Therapeutic Plasma Exchange (TPE) for patients ≥ 20 kg where plasma component removal is indicated. All treatments by physician prescription. | Identical to predicate. |
| Dedicated Disposable Sets Available | For CRRT: M60/M100/M150, HF1000 & HF1400; For TPE: TPE 2000 Set. | Identical to predicate. |
| Syringe Sizes | 20 & 50 ml | Identical to predicate. |
| Anticoagulation | User-controllable (continuous or bolus) | Identical to predicate. |
| Dialysate Flow Rate (CVVH & CVVHDF) | Range: 0 to 8000 ml/hr, Increment: 10 ml/hr | Identical to predicate. |
| Dialysate Flow Rate Accuracy | ± 30 ml/hr | Identical to predicate. |
| Replacement solution / Fluid Flow Rate (CVVH & CVVHDF) | Range: 0 to 8000 ml/hr, Increment: 10 ml/hr | Identical to predicate. |
| Replacement solution / Fluid Flow Rate (TPE) | Range: 0 to 5000 ml/hr, Increment: 10 ml/hr | Identical to predicate. |
| Replacement Flow Rate Accuracy | ± 30 ml/hr | Identical to predicate. |
| Blood Flow Rate | Range: 10-450 ml/min | Identical to predicate. |
| Blood Flow Rate Accuracy | ± 10 % of user set rate at nominal blood flow of 450 ml/min or highest achievable disposable blood flow, 37°C, access pressure -200 mmHg, without PBP flow. | Identical to predicate. |
| Pre-Blood Pump Flow Rate (SCUF) | Range: 0 to 2000 ml/hr | Identical to predicate. |
| Pre-Blood Pump Flow Rate (CVVH, CVVHD, CVVHDF) | Range: 0 to 4000 ml/hr | Identical to predicate. |
| Pre-Blood Pump Flow Rate (TPE) | Range: 0 to 1000 ml/hr (Note: PBP Volume 2000 ml/treatment for TPE2000) | Identical to predicate. |
| Pre-Blood Pump Accuracy | ± 30 ml/hr | Identical to predicate. |
| Effluent Pump Flow Rate | Range: 0 to 10,000 ml/h (depending on therapy) | Identical to predicate. |
| ECG Discharger | YES | Identical to predicate. |
| Therapies | SCUF, CVVH, CVVHD, CVVHDF, TPE | Identical to predicate. |
| Pumps | PBP solution, Replacement solution, Dialysate solution, Effluent, Blood. | Identical to predicate. |
| Scales | Dialysate, Replacement, Effluent, Pre Blood Pump (PBP) | Identical to predicate. |
| Trans Membrane Pressure (TMP) Alarms (CRRT) | Default: +300 mmHg | Identical to predicate. |
| TMPa (TPE) | User settable; +50 to +100 mmHg; Default: +100 mmHg | Identical to predicate. |
| Dialysate Conductivity and Temperature Control | Not controlled by PrisMax | Identical to predicate. |
| Patient Fluid Removal (CRRT) Range | 0 to 2000 ml/hr, Increment: 5 ml/hr | Identical to predicate. |
| Patient Fluid Removal (TPE) Range | 0 to 1000 ml/hr, Increment: 5 ml/hr | Identical to predicate. |
| Patient Fluid Removal Performance (Accuracy) | ± 30 ml/hr; ± 70 ml/3hr; ± 300 ml/24hr. Scales calibrated at ambient temperature, change < +3 °C (5.4 °F) during treatment. | Identical to predicate. |
| Access Pressure Sensor | Range: -250 to +450 mmHg, Accuracy: ±15 mmHg | Identical to predicate. |
| Return Pressure Sensor | Range: -50 to +350 mmHg, Accuracy: ±5 mmHg | Identical to predicate. |
| Filter Pressure Sensor | Range: -50 to +450 mmHg, Accuracy: ±15 mmHg | Identical to predicate. |
| Effluent Pressure Sensor | Range: -350 to +400 mmHg (CRRT/TPE), Accuracy: ±15 mmHg | Identical to predicate. |
| TPE Specific Settings (Patient Hematocrit) | Range: 10 to 60%, Increment: 1%, Default: 30% | Identical to predicate. |
| TPE Specific Settings (Total Replacement Volume) | Range: 0 to 10,000 ml, Increment: 1 ml, Default: 0 ml | Identical to predicate. |
| TPE Specific Settings (Patient Plasma Loss Rate) | Range: 0 or 10 to 1000 ml/hr, Increment: 5 ml/hr, Default: 0 ml/hr | Identical to predicate. |
| TPE Specific Settings (Replacement Container Volume) | Range: 0 to 5000 ml, Increment: 0.1 ml | Identical to predicate. |
| Control Unit Software | PrisMax Version 2 | PrisMax Version 3 |
| Blood Warmer Accessory | Prismatherm Warmer, PrismaFlo Blood Warmer, Prismacomfort Blood Warmer, TherMax Blood Warmer | Identical to predicate. |
Summary of Device Performance: The document explicitly states that for all technical specifications listed, the "Proposed K19XXXX PrisMax Version 3" is identical ("SE" - Substantial Equivalence) to the "Proposed K190910 PrisMax Version 2," with the only explicitly identified difference being the Control Unit Software version (Version 3 vs. Version 2). The performance testing conducted confirms that PrisMax System Version 3 remains as safe and effective as the predicate.
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 does not specify a "test set" in the context of clinical or imagery data. Instead, the evaluation relies on nonclinical performance testing of a physical device.
- Sample Size for Test Set: Not applicable in the traditional sense of patient data. The "test set" would refer to the instantiated PrisMax System Version 3 device(s) and its components undergoing rigorous engineering and functional tests. The document does not specify the number of units tested.
- Data Provenance: The tests are "nonclinical" and focus on functional performance. The document doesn't explicitly state the country of origin for the testing, but it is submitted to the U.S. FDA by Baxter Healthcare Corporation (Deerfield, Illinois, USA). The testing is prospective in the sense that newly manufactured or updated devices were tested to verify performance against established specifications.
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 is not applicable as the document describes a nonclinical, engineering-focused substantial equivalence demonstration for a medical device (Continuous Renal Replacement Therapy system), not a diagnostic AI/imaging device requiring expert ground truth in a clinical context. The "ground truth" here is the established functional and safety specifications of the device, typically defined by engineering standards, regulatory requirements, and performance of the predicate device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. Adjudication methods like 2+1 or 3+1 are used for resolving discrepancies in expert interpretations of clinical data (e.g., medical images). This document describes nonclinical performance testing of hardware and software, where objective measurements and adherence to engineering specifications are the primary evaluation methods, not subjective expert reviews.
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. An MRMC study is designed for evaluating the diagnostic performance of a system (often AI-assisted) in a clinical setting by comparing multiple readers' interpretations of multiple cases. The PrisMax System is a therapeutic and fluid management device, not a diagnostic tool, and its evaluation did not involve human "readers" or AI assistance in this context.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as the PrisMax System is a physical medical device. While it contains software (Control Unit Software Version 3), the performance evaluation is of the integrated system, and not an algorithm in isolation for diagnostic purposes. The software verification and validation are part of the overall system's nonclinical testing.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
The "ground truth" for the nonclinical tests is based on:
- Established engineering specifications and performance limits: These are derived from general medical device standards (e.g., IEC60601-2-16, IEC60601-1, IEC60601-1-2), regulatory guidelines, and the proven performance of the predicate device (PrisMax System Version 2).
- Risk analysis: Ensuring the device does not perform in an unexpected or unsafe manner.
- User needs and intended use: The design validation aimed to meet these.
In essence, the ground truth is the successful demonstration of consistent functional performance within predefined, objective, and safety-critical parameters, validated against a well-established and previously cleared predicate device.
8. The sample size for the training set
This is not applicable. The PrisMax System is not an AI/machine learning model in the sense that it requires a "training set" of data to learn from for diagnostic or predictive purposes. It is a control unit for CRRT and TPE, meaning its software is deterministic and engineered to perform specific, pre-programmed functions and calculations based on input parameters.
9. How the ground truth for the training set was established
This is not applicable for the reasons stated in point 8.
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(108 days)
The PrisMax control unit is intended for:
· Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload.
• Therapeutic Plasma Exchange (TPE) therapy for patients weighing 20 kilograms or more with diseases where removal of plasma components is indicated.
All treatments administered via the PrisMax control unit must be prescribed by a physician.
The PrisMax System is intended for Continuous Renal Replacement Therapy (CRRT) for patients with acute renal failure and/or fluid overload. The goals of acute renal failure treatments are removal of waste products, restoration of acid-base balance; correction of electrolyte imbalances (e.g., hyperkalemia), patient fluid balance, nutritional support, and other conditions in which fluid removal is needed. PrisMax System offers four Continuous Renal Replacement Therapy (CRRT) options: Slow Continuous Ultrafiltration (SCUF), Continuous Veno-Venous Hemofiltration (CVVH), Continuous VenoVenous Hemodialysis (CVVHD), and Continuous Venovenous Hemodialfiltration (CVVHDF). The proposed device PrisMax, which is the subject of this Traditional premarket notification (510(k)), consists of the PrisMax Control Unit System, Blood Tubing Sets and Accessories. Specific to this submission, is the accessory for blood warming and a blood tubing set for Therapeutic Plasma Exchange (TPE2000).
Here's a breakdown of the acceptance criteria and the study information for the PrisMax System Version 2, based on the provided document.
It's important to note that this document is a 510(k) summary for a medical device and not a study report for an AI/algorithm-based device. Therefore, many of the requested categories (like sample sizes for test/training sets, number of experts, adjudication methods, MRMC studies, standalone AI performance, and ground truth establishment for AI) are not applicable to this submission, as it concerns a physical medical device (CRRT/TPE system) and its software/accessories, not an AI model.
Acceptance Criteria and Reported Device Performance
The acceptance criteria are implicitly defined by the safety and performance requirements for a high permeability hemodialysis system, as demonstrated by equivalence to predicate devices and compliance with recognized standards. The "performance" here refers to the functional performance of the device's physical and software components.
| Feature / Acceptance Criteria (defined by equivalence to predicates and standards) | Reported Device Performance (PrisMax System Version 2) |
|---|---|
| Indications for Use | CRRT: For patients ≥20 kg with acute renal failure and/or fluid overload. TPE: For patients ≥20 kg with diseases where removal of plasma components is indicated. (Matches predicate Prismaflex sw8.10; expands beyond PrisMax V1) |
| Dedicated Disposable Sets | CRRT: M60/M100/M150, HF1000 & HF1400. TPE: TPE 2000 Set. (Matches predicate Prismaflex sw8.10; expands beyond PrisMax V1) |
| Syringe Sizes | 20 & 50 ml. (Matches PrisMax V1, differs slightly from Prismaflex sw8.10 which also has 30 ml) |
| Anticoagulation | User-controllable as continuous or bolus. (Matches predicates) |
| Dialysate Flow Rate (CVVH & CVVHDF) | Range: 0 to 8000 ml/hr, Increment: 10 ml/hr. (Matches PrisMax V1; finer increment than Prismaflex sw8.10's 50 ml/hr) |
| Dialysate Flow Rate Accuracy | ± 30 ml/hr. (Matches predicates) |
| Replacement solution / Fluid Flow Rate (CVVH & CVVHDF) | Range: 0 to 8000 ml/hr, Increment: 10 ml/hr. (Matches PrisMax V1; finer increment than Prismaflex sw8.10's 50 ml/hr) |
| Replacement solution / Fluid Flow Rate (TPE) | Range: 0 to 5000 ml/hr, Increment: 10 ml/hr. (Matches predicate Prismaflex sw8.10; adds TPE functionality not in PrisMax V1) |
| Replacement Flow Rate Accuracy | ± 30 ml/hr. (Matches predicates) |
| Blood Flow Rate | Range: 10-450 ml/min. (Matches predicates) |
| Blood Flow Rate Accuracy | ±10% of user set rate at nominal blood flow of 450 ml/min or the highest achievable disposable blood flow, having 37 °C, at an access pressure of -200 mmHg and without any PBP flow. (Matches predicates) |
| Pre-Blood Pump Flow Rate (SCUF) | Range: 0 to 2000 ml/hr. (Matches predicates) |
| Pre-Blood Pump Flow Rate (CVVH, CVVHD, CVVHDF) | Range: 0 to 4000 ml/hr. (Matches predicates) |
| Pre-Blood Pump Flow Rate (TPE) | Range: 0 to 1000 ml/hr. PBP Volume is 2000 ml/treatment for TPE2000. (Matches predicate Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| Pre-Blood Pump Accuracy | ± 30 ml/hr. (Matches predicates) |
| Effluent Pump Flow Rate | Range: 0 to 10,000 ml/h, depending on therapy. (Matches predicates) |
| ECG Discharger | YES. (Matches predicates) |
| Therapies | SCUF, CVVH, CVVHD, CVVHDF, TPE. (Matches predicate Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| Pumps | PBP solution, Replacement solution, Dialysate solution, Effluent, Blood. (Matches predicates) |
| Scales | Dialysate, Replacement, Effluent, Pre Blood Pump (PBP). (Matches predicates) |
| Trans Membrane Pressure (TMP) Alarms (CRRT) | Default: +300 mmHg. (Matches PrisMax V1, somewhat different from user settable +70 to +350 mmHg for Prismaflex sw8.10) |
| TMPa Alarms (TPE) | User settable: +50 to +100 mmHg, Default: +100 mmHg. (Matches predicate Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| Dialysate Conductivity and Temperature Control | Not controlled by PrisMax. (Matches predicates) |
| Patient Fluid Removal Performance (CRRT) | Range: 0 to 2000 ml/hr, Increment: 5 ml/hr. (Finer increment than Prismaflex sw8.10's 10 ml/hr) |
| Patient Fluid Removal Performance (TPE) | Range: 0 to 1000 ml/hr, Increment: 5 ml/hr. (Finer increment than Prismaflex sw8.10's 10 ml/hr; adds TPE not in PrisMax V1) |
| Patient Fluid Removal Performance (Accuracy) | ± 30 ml/hr; ± 70 ml/3hr; ± 300 ml/24hr. (Matches predicates) |
| Scale Calibration | Scales calibrated at ambient temperature at which they will be used. Ambient temperature change less than ±3 °C (5.4 °F) during treatment. (Matches predicates) |
| Access Pressure Sensor | Range: -250 to +450 mmHg, Accuracy: ±15 mmHg. (Matches predicates) |
| Return Pressure Sensor | Range: -50 to +350 mmHg, Accuracy: ±5 mmHg. (Matches predicates) |
| Filter Pressure Sensor | Range: -50 to +450 mmHg, Accuracy: ±15 mmHg. (Matches PrisMax V1; different from Prismaflex sw8.10's ±10% or ±8mmHg) |
| Effluent Pressure Sensor (CRRT) | Range: -350 to +400 mmHg, Accuracy: ±15 mmHg. (Matches PrisMax V1; different from Prismaflex sw8.10's ±10% or ±8mmHg) |
| Effluent Pressure Sensor (TPE) | Range: -350 to +400 mmHg, Accuracy: ±15 mmHg. (Adds TPE not in PrisMax V1; different from Prismaflex sw8.10's ±10% or ±8mmHg) |
| TPE Specific Settings (Patient Hematocrit) | Not specified for PrisMax V2 in the comparative table. Prismaflex sw8.10 has Range: 10 to 60%, Increment: 1%, Default: 30%. |
| TPE Specific Settings (Total Replacement Volume) | Range: 0 to 10,000 ml, Increment: 0.1 ml, Default: 0 ml. (Finer increment and different default than Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| TPE Specific Settings (Patient Plasma Loss Rate) | Range: 0, or 10 to 1000 ml/hr, Increment: 5 ml/hr, Default: 0 ml/hr. (Finer increment than Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| TPE Specific Settings (Replacement Container Volume) | Range: 0 to 5000 ml, Increment: 0.1 ml. (Finer increment than Prismaflex sw8.10; adds TPE not in PrisMax V1) |
| Control Unit Software | PrisMax Version 2. (Updates from PrisMax Version 1) |
| Blood Warmer Accessory | Prismatherm Warmer, PrismaFlo Blood Warmer, Prismacomfort Blood Warmer, TherMax Blood Warmer. (Adds TherMax Blood Warmer) |
Study Information (Relevant to this device submission)
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Sample size used for the test set and the data provenance: Not applicable. This is a submission for a physical medical device and its accessories/software, not an AI/algorithm. Performance was evaluated through non-clinical functional testing, verification, and validation of the device components and system.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical device's functional performance is typically based on engineering specifications, physical measurements using calibrated equipment, and compliance with recognized standards.
-
Adjudication method: Not applicable for an AI context. Device performance was assessed against predefined engineering specifications and regulatory standards in non-clinical testing.
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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 is a medical device, not an AI diagnostic/classification system requiring human reader studies.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This device is not an AI algorithm. Its software runs on the device to control its functions.
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The type of ground truth used:
- Engineering Specifications: The device's operating ranges, accuracies (e.g., flow rates, pressure sensors, fluid removal), and control parameters were tested against predetermined engineering specifications.
- Regulatory Standards: Compliance with recognized international standards (e.g., IEC60601-2-16 for Hemodialysis Equipment, IEC60601-1 for Electrical Safety, IEC60601-1-8 for Alarms, IEC60601-1-2 for EMC, ISO10993-1 for Biocompatibility).
- Successful Functional Performance: Verification and validation testing confirmed that the device and its accessories (including software) performed as intended and met user needs.
-
The sample size for the training set: Not applicable. No AI model training set is mentioned or relevant for this device submission. The "software" referred to is control software, not a machine learning model.
-
How the ground truth for the training set was established: Not applicable. There is no AI training set. Software verification and validation (V&V) involved testing against functional requirements derived from design specifications, risk analysis, and regulatory requirements.
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(262 days)
The Prismaflex control unit is intended for:
· Continuous Renal Replacement Therapy (CRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload.
• Therapeutic Plasma Exchange (TPE) therapy for patients weighing 20 kilograms or more with diseases where removal of plasma components is indicated.
All treatments administered via the Prismaflex control unit must be prescribed by a physician.
The Prismaflex control unit is a software controlled device that performs the following functions:
Loads and primes the Prismaflex disposable set automatically.
• Pumps blood through the blood flow path of the Prismaflex disposable set.
· Delivers anticoagulant solution into the blood flow path.
• Pumps sterile infusion solutions into the blood flow path of the Prismaflex disposable set according to therapy in use.
· Pumps sterile dialysate into the fluid compartment of the filter in CRRT therapies.
· Controls the patient fluid removal or plasma loss according to the therapy in use.
• Monitors the system and alerts the operator to abnormal situations through alarms.
· Provides treatment data to an external Patient Data Management Systems (PDMS)
The provided document, a 510(k) premarket notification letter from the FDA to Baxter Healthcare Corporation for the Prismaflex System 8.10, is a regulatory submission for a medical device. It does not contain information about an AI/ML-based medical device software or a study that proves a device meets acceptance criteria in the context of an AI/ML system's performance metrics (like sensitivity, specificity, or AUC).
The document details the device's substantial equivalence to a predicate device (Prismaflex System 7.10) based on its functional parameters, physical characteristics, and adherence to performance standards for a hemodialysis system. The "acceptance criteria" here refer to the predefined performance ranges and characteristics of the device itself (e.g., dialysate flow rate accuracy, blood flow rate accuracy, pressure sensor accuracy), and the "study" is the non-clinical testing (software and system verification and validation) done to prove that the updated Prismaflex System 8.10 meets these established parameters and functions equivalently to its predecessor.
Therefore, I cannot extract the requested information, which pertains to AI/ML device performance and testing, from this document. The document primarily focuses on demonstrating substantial equivalence for a non-AI/ML medical device based on established performance specifications and regulatory compliance.
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(138 days)
The PrisMax control unit is intended for:
• Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload.
All treatments administered via the PrisMax control unit must be prescribed by a physician.
The PrisMax System is intended for Continuous Renal Replacement Therapy (CRRT) for patients with acute renal failure and/or fluid overload. The PrisMax System offers four Continuous Renal Replacement Therapy (CRRT) options: Slow Continuous Ultrafiltration (SCUF), Continuous Veno-Venous Hemofiltration (CVVH), Continuous VenoVenous Hemodialysis (CVVHD), and Continuous Venovenous Hemodialfiltration (CVVHDF). The proposed device PrisMax consists of PrisMax Control Unit and accessories for removing effluent.
The provided text describes a 510(k) premarket notification for the PrisMax device, which is a high-permeability hemodialysis system. The core of this submission is to demonstrate the substantial equivalence of the PrisMax to a predicate device, the Prismaflex.
Here's an analysis of the acceptance criteria and the study proving the device meets them, based solely on the provided text. It's important to note that a 510(k) summary often summarizes extensive testing, so not all details of the actual studies might be present in this brief document.
First and foremost, this document describes a device comparison for substantial equivalence to a predicate, not a study evaluating clinical performance against a specific disease outcome or a MRMC study. Therefore, some of the requested information (like effect size of human readers improving with AI, or number of experts for ground truth) is not applicable to this type of regulatory submission. The acceptance criteria here are about equivalence to the predicate device's established performance parameters and safety.
1. Table of Acceptance Criteria and the Reported Device Performance
The acceptance criteria are generally that the PrisMax device performs at least as well as or equivalently to the predicate Prismaflex device for various technical specifications. The reported device performance is the PrisMax's specification for that feature. The table below is extracted directly from the "Table 3. Substantial Equivalence Table Device Comparison" in the provided document. The "Acceptance Criteria" column reflects the predicate device's performance, as the goal is to demonstrate equivalence or improvement without raising new safety/effectiveness concerns.
| Feature | Acceptance Criteria (Predicate Prismaflex 7.10, K131516) | Reported Device Performance (Proposed PrisMax 1.0.6.0) |
|---|---|---|
| Indications for use | Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload. All treatments administered via the Prismaflex control unit must be prescribed by a physician. | Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload. All treatments administered via the PrisMax control unit must be prescribed by a physician. |
| Dedicated Disposable Sets Available in U.S. | For CRRT: M60/M100/M150, HF1000 & HF1400 | For CRRT: M60/M100/M150, HF1000 & HF1400 |
| Syringe Sizes | 20, 30 & 50 ml | 20 & 50 ml |
| Anticoagulation | User-controllable as continuous or bolus | User-controllable as continuous or bolus |
| Dialysate Flow Rate CVVH & CVVHDF (Range) | 0 to 8000 ml/hr | 0 to 8000 ml/hr |
| Dialysate Flow Rate CVVH & CVVHDF (Increment) | 50 ml/hr | 10 ml/hr |
| Dialysate Flow Rate Accuracy | ± 30 ml/hr | ± 30 ml/hr |
| Replacement solution / Fluid Flow Rate CVVH & CVVHDF (Range) | 0 to 8000 ml/hr | 0 to 8000 ml/hr |
| Replacement solution / Fluid Flow Rate CVVH & CVVHDF (Increment) | 50 ml/hr | 10 ml/hr |
| Replacement Flow Rate Accuracy | ± 30 ml/hr | ± 30 ml/hr |
| Blood Flow Rate (Range) | 10-450 ml/min | 10-450 ml/min |
| Blood Flow Rate Accuracy | ±10 % of user-set rate at nominal blood flow of 450 ml/min or the highest achievable disposable blood flow, having 37 °C, at an access pressure of -200 mmHg and without any PBP flow | ±10 % of user-set rate at nominal blood flow of 450 ml/min or the highest achievable disposable blood flow, having 37 °C, at an access pressure of -200 mmHg and without any PBP flow |
| Pre-Blood Pump Flow Rate SCUF (Range) | 0 to 1000 ml/hr (but actual was 0 to 2000 ml/hr) | 0 to 2000 ml/hr |
| Pre-Blood Pump Flow Rate CVVH, CVVHD, CVVHDF (Range) | 0 to 4000 ml/hr | 0 to 4000 ml/hr |
| Pre-Blood Pump Accuracy | ± 30 ml/hr | ± 30 ml/hr |
| Effluent Pump Flow Rate (Range) | 0 to 10,000 ml/h, Depending on the therapy selected. | 0 to 10,000 ml/h, Depending on the therapy selected. |
| ECG Discharger | YES | YES |
| Therapies | SCUF, CVVH, CVVHD, CVVHDF | SCUF, CVVH, CVVHD, CVVHDF |
| Pumps | PBP solution, Replacement solution, Dialysate solution, Effluent, Blood | PBP solution, Replacement solution, Dialysate solution, Effluent, Blood |
| Scales | Dialysate, Replacement, Effluent, Pre blood (PBP) | Dialysate, Replacement, Effluent, Pre blood (PBP) |
| Trans Membrane Pressure Alarms (TMP CRRT) | User settable: +70 to +350 mmHg, Default: +350 mmHg | Default: +300 mmHg |
| Dialysate Conductivity and Temperature | Not controlled by Prismaflex | Not controlled by PrisMax |
| Patient Fluid Removal Performance (Range) | 0 to 2000 ml/hr | 0 to 2000 ml/hr |
| Patient Fluid Removal Performance (Increment) | 10 ml/hr | 5 ml/hr |
| Patient Fluid Removal Performance (Accuracy) | ± 30 ml/hr, ± 70 ml/3hr, ± 300 ml/24hr. Scales calibrated at ambient temperature at which they will be used. Ambient temperature change less than ±3 °C (5.4 °F) during treatment. | ± 30 ml/hr, ± 70 ml/3hr, ± 300 ml/24hr. Scales calibrated at ambient temperature at which they will be used. Ambient temperature change less than ±3 ℃ (5.4 °F) during treatment. |
| Access Pressure Sensor (Range) | -250 to +450 mmHg | -250 to +450 mmHg |
| Access Pressure Sensor (Accuracy) | ±15 mmHg | ±15 mmHg |
| Return Pressure Sensor (Range) | -50 to +350 mmHg | -50 to +350 mmHg |
| Return Pressure Sensor (Accuracy) | ±5 mmHg | ±5 mmHg |
| Filter Pressure Sensor (Range) | -50 to +450 mmHg | -50 to +450 mmHg |
| Filter Pressure Sensor (Accuracy) | ±15 mmHg | ±15 mmHg |
| Effluent Pressure Sensor (Range) | -350 to +400 mmHg (CRRT) | -350 to +400 mmHg (CRRT) |
| Effluent Pressure Sensor (Accuracy) | ±15 mmHg | ±15 mmHg |
| Control Unit Software | Version 7.10 | Version 1.0.6.0 |
Study Proving Device Meets Acceptance Criteria
The document states: "Performance testing was conducted on the PrisMax System to evaluate the functional performance of the system. The performance testing confirms PrisMax remains as safe and effective as Prismaflex and is substantially equivalent."
The nature of the "study" demonstrating this is predominantly nonclinical performance testing, verification, and validation against engineering and regulatory standards, and comparison to the predicate device's specifications.
Specifically, the document explicitly mentions:
- Design validation: The PrisMax design validation meets user needs and intended use and is substantially equivalent to the predicate.
- Compliance with IEC 60601-2-16 Hemodialysis Equipment: Testing confirmed by CSA, a recognized test laboratory, for essential performance.
- Electrical safety testing: According to IEC 60601-1 Edition 3.1. This includes reports for software, alarms, usability, safety, and performance.
- Electromagnetic compatibility (EMC) testing.
- Risk Assessment and risk control measures: Hazard analysis (therapy level, product level, process level) confirming the device does not perform in an unexpected or unsafe manner.
- Labeling, Software including cybersecurity, Human Factors: These have been successfully implemented.
- Verification and validation tests: These were performed subsequent to risk analysis and include Human Factors and Software Validation.
The key changes and their justification for not raising new safety/effectiveness concerns are footnoted in Table 3:
- Syringe Sizes (30ml removed): Due to infrequent use, device behavior unchanged.
- Dialysate Flow Rate / Replacement Solution Flow Rate Increment (50ml/hr to 10ml/hr): Allows for more precise settings, verified and validated to comply to updated specifications without new risks.
- Pre-Blood Pump Flow Rate (SCUF range clarification): Corrected the predicate's stated range to its actual operational range, showing PrisMax is equivalent. Verified and validated.
- Trans Membrane Pressure Alarms (Fixed default of +300 mmHg, removed user settable): Removes infrequent use case, reduces use-error risk, increases usability, lowers default to reduce risk. Verified and validated.
- Patient Fluid Removal Performance Increment (10ml/hr to 5ml/hr): Increases setting range, allows more precise setting. Verified and validated.
- The software update (version 1.0.6.0) was verified and validated subsequent to risk analysis and includes Human Factors and Software Validation.
Details based on the provided text:
-
2. Sample size used for the test set and the data provenance:
- Sample Size: Not explicitly stated in terms of patient count or device unit count for the validation tests. These are typically engineering performance tests, not clinical trials with "patients." The performance tests would use a relevant number of devices or test conditions to ensure specifications are met.
- Data Provenance: The testing appears to be internal "performance testing" and "verification and validation" conducted by Baxter Healthcare Corporation and by a recognized test laboratory (CSA) for specific standards like IEC 60601-2-16. This is non-clinical, laboratory-based data, not patient data from a specific country.
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3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable in the context of a 510(k) submission based on technical performance and equivalence to a predicate device, rather than a clinical diagnostic study requiring expert interpretation of results. The "ground truth" here is adherence to engineering specifications and safety standards.
-
4. Adjudication method for the test set:
- Not applicable, as this is not a study requiring human adjudication for diagnostic categorization. The "adjudication" is through engineering verification and validation processes against predefined technical specifications and standards.
-
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. This is a medical device for continuous renal replacement therapy, not an AI/diagnostic imaging device that would typically involve human readers. Therefore, an MRMC study is not relevant here.
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6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable in the way this question typically refers to AI algorithms. The device itself is a "standalone" system in its function, but its performance is verified through engineering tests against objective criteria, not an "algorithm only" performance separate from the device's integrated function. Its operation relies on physician prescription (human-in-the-loop for clinical application, but not for the device's technical performance evaluation).
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7. The type of ground truth used:
- Engineering Specifications and Performance Standards: The "ground truth" for this submission is compliance with established engineering specifications for flow rates, accuracy, pressure ranges, alarm settings, and adherence to international safety standards (e.g., IEC60601 series). Additionally, the predicate device's cleared performance serves as a comparative ground truth for equivalence.
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8. The sample size for the training set:
- Not applicable. This is not a machine learning or AI device that requires a "training set" in the conventional sense. The "training" for the device's development would be iterative engineering design and testing.
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9. How the ground truth for the training set was established:
- Not applicable, as there is no "training set" in the AI/ML context. The functional requirements for the device are derived from clinical needs, regulatory standards, and the performance of previous generations of such devices.
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(81 days)
PrismaSATE solutions are indicated for use as a dialysate in Continuous Renal Replacement Therapy.
PrismaSATE dialysis solutions are ready to use sterile dialysate solutions for use in Continuous Renal Replacement Therapy (CRRT) for the treatment of acute renal failure and in other cases necessitating fluid or solute removal, such as in the case of drug poisoning with dialyzable or filterable substances. The solutions are intended to be used with commercially available CRRT systems as dialysate. A physician prescribes the chemical composition of the solution to be used. The solutions are sterile, and packaged in flexible bags. The composition of the fluid used in renal therapies mirrors normal plasma water, since normalization of the blood is the objective.
PrismaSATE solutions, like other currently available dialysate solutions, consist of various quantities of the following chemicals: sodium chloride, potassium chloride, magnesium chloride, calcium chloride, dextrose, and a buffer of lactose and/or bicarbonate. The solution is prescribed by a physician; the physician selects the appropriate formulation based on the patient's blood electrolyte level and desired traits. PrismaSATE dialysate solutions are offered in a range of electrolyte concentrations which mirror the range of electrolytes in plasma. The solution may be buffered using lactate, bicarbonate using lactic acid as a pH adjustor, or bicarbonate using hydrochloric acid as a pH-adjusting excipient.
This document is a 510(k) premarket notification for a medical device called "PrismaSATE dialysis solutions" by Baxter Healthcare Corporation.
Based on the provided text, the device is the PrismaSATE dialysis solutions buffered with bicarbonate using hydrochloric acid as a pH-adjusting excipient, packaged in polyolefin primary packaging materials. The purpose of this 510(k) is to expand the existing PrismaSATE solution formulations into a different packaging material.
Here's an analysis of the acceptance criteria and the "study" (design verification in this case) that aims to prove the device meets these criteria:
1. A table of acceptance criteria and the reported device performance:
The document states: "Baxter Healthcare Corporation performed design verification for the modification. The result met its acceptance criteria, and supports that the proposed device is appropriately designed for its intended use." However, it does not explicitly list the acceptance criteria or specific numerical performance results of this "design verification".
Instead, it refers to the modification of packaging material. The acceptance criteria would likely relate to the integrity and compatibility of the solution with the new polyolefin packaging, and the maintenance of the solution's properties.
Based on the "Device Comparison Table" (Table 3) and the "Discussion of Nonclinical Tests," the implied performance criteria and the device's reported ability to meet them are:
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Same Indications for Use as Predicate Devices | "Same: PrismaSATE Solutions are indicated for use as a dialysate in Continuous Renal Replacement Therapy." |
| Sterile (Sterilization Assurance Level) | "Same: Steam sterilized, to a Sterilization Assurance Level of at least 10-6." |
| Non-Pyrogenic | "Same: Non-pyrogenic solution" |
| Single Use | "Same: Yes" |
| Solution Formulation (same as K120333) | "Same as predicate K120333" |
| Primary Packaging Material (same as K072908) | "Same as predicate K072908: Polyolefin" |
| Shelf Life (demonstrate equivalency to K072908 shelf life) | "Same as predicate K072908: 18 months" |
| No new risks identified from the combination | "No new risks were identified." (from risk analysis) |
| Appropriately designed for intended use with modification | "The result met its acceptance criteria, and supports that the proposed device is appropriately designed for its intended use." |
| No new materials introduced (for biocompatibility) | "No new materials are introduced in this Special 510(k)." |
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: "No performance data is included in this Special 510(k)." This implies that no new testing with a specific test set was conducted or provided in this submission to demonstrate performance with the new packaging. The submission relies on the substantial equivalence to predicate devices, where performance data would have been established for the individual components (solution formulation and packaging material).
Therefore, specific sample sizes, country of origin, or retrospective/prospective nature of the data for this specific submission are not provided. The "design verification" mentioned is described broadly without these details.
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. No new test set data is presented for which ground truth would need to be established by experts for performance evaluation. The "design verification" would likely involve internal company experts in engineering, quality, and manufacturing, but their specific roles or number are not specified for "ground truth" establishment in a performance study context.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. There is no mention of a performance study involving interpretation or scoring of data that would require an adjudication 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:
Not applicable. This device is a dialysis solution and its packaging, not an AI or imaging diagnostic device that would require an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This device is not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
Not applicable in the conventional sense of a clinical performance study for an AI or diagnostic device. The "ground truth" for this submission is effectively the established performance and safety profiles of the predicate devices. The "design verification" likely relied on manufacturing specifications, chemical analysis, stability testing, and packaging integrity tests, rather than a clinical "ground truth" established by external experts.
8. The sample size for the training set:
Not applicable. This is not a machine learning or AI device that would require a training set.
9. How the ground truth for the training set was established:
Not applicable.
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(111 days)
This device is a ceramic blank for fabrication of dental restoration in anterior and posterior locations. This device is used for fabricating copings, crowns, inlays, veneers and bridges.
The device is a strong and esthetic dental ceramic blank that is used by dental laboratories for fabrication of dental prosthetics such as copings, crowns and bridges. The device is comprised mainly of zirconium oxide powder and is used by dental CAD/CAM systems currently available in the market. The device is initially manufactured in a partially sintered state and is milled to specifications using standard CAD/CAM milling machines by dental technicians. The milled units are then sintered fully to the final state that is capable of being used in dental restoration procedures by dentists.
I am sorry, but the provided text does not contain the detailed information necessary to answer your request about acceptance criteria and the study proving the device meets them.
The document is a 510(k) premarket notification letter from the FDA to A&D Dental Innovations, LLC regarding their PRISM Zirconia device. It primarily focuses on:
- FDA's substantial equivalence determination: Stating that the device is substantially equivalent to a legally marketed predicate device (Prismatik™ Clinical Zirconia, K060104).
- Regulatory information: Such as trade name, regulation number, classification, and general controls.
- Indications for Use: What the device is intended for.
- Device Description: General information about the device's material and manufacturing process.
- Substantial Equivalence justification: Briefly mentioning that performance testing (flexural strength, thermal expansion, solubility) was performed to establish substantial equivalence.
However, the document does not elaborate on:
- Specific acceptance criteria values for the performance tests.
- The actual reported device performance values against those criteria.
- Details about the study design: Such as sample size for test sets, data provenance, number or qualifications of experts, adjudication methods, MRMC studies, standalone algorithm performance, or ground truth types.
- Information about training sets (sample size, ground truth establishment).
To answer your question thoroughly, I would need a more detailed study report or technical document that outlines the specific testing conducted, the quantitative results obtained, and the predefined acceptance criteria.
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(220 days)
The Prismaflex control unit is intended for: Continuous Renal Replacement Therapy (CRRT) for patients weighing 20 kilograms or more with acute renal failure and/or fluid overload. Therapeutic Plasma Exchange (TPE) therapy for patients weighing 20 kilograms or more with diseases where removal of plasma components is indicated. All treatments administered via the Prismaflex control unit must be prescribed by a physician.
Not Found
I am sorry, but the provided text does not contain the information needed to answer your request. The document is a 510(k) premarket notification letter from the FDA regarding the Prismaflex System 7.10, indicating it has been found substantially equivalent to a predicate device. It defines the device, lists its intended uses, and outlines regulatory requirements. However, it does not include any details about acceptance criteria, device performance studies, sample sizes, data provenance, expert ground truth establishment, adjudication methods, multi-reader multi-case studies, standalone algorithm performance, or ground truth types and establishment methods for training sets.
Therefore, I cannot populate the table or answer the specific questions about the device's performance study based on the provided text.
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