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510(k) Data Aggregation

    K Number
    K113433
    Date Cleared
    2012-04-04

    (135 days)

    Product Code
    Regulation Number
    866.2660
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    SIMPLEXA C. DIFFICILE UNIVERSAL DIRECT

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

    The Focus Diagnostics Simplexa™ C. difficile Universal Direct is a real-time polymerase chain reaction (PCR) assay and is intended for use on the 3M Integrated Cycler instrument for the detection of toxigenic Clostridium difficile toxin B gene (tcdB) in liquid or unformed stool samples from individuals suspected of C. difficile infection. This test aids in the diagnosis of Clostridium difficile associated disease (CDAD).

    Device Description

    The test is a real-time polymerase chain reaction (PCR) amplification system that utilizes bifunctional fluorescent probe-primers for the detection of C. difficile in liquid or unformed stool. The Simplexa™ C. difficile Universal Direct kit contains primes, buffers and controls. The assay is composed of two principal steps: (1) Heat treatment of stool samples, (2) Amplification of the C. difficile DNA and internal control DNA using bi-functional fluorescent probe-primers together with reverse primers. The DNA internal control is used to monitor potential presence of PCR inhibitors. The assay targets a sequence which is in a well conserved region of C. difficile toxin B gene (tcdB).

    AI/ML Overview

    1. Acceptance Criteria and Reported Device Performance

    Performance MetricAcceptance CriteriaReported Performance (Simplexa™ C. difficile Universal Direct Kit)
    Reproducibility
    Low Positive100% agreement expected100% (90/90)
    Medium Positive100% agreement expected100% (89/89)
    Positive Control100% agreement expected100% (90/90)
    High Negative>90% agreement expected98.9% (89/90)
    No Template Control (NTC)>90% agreement expected98.9% (89/90)
    Limit of Detection (LoD)Not explicitly stated as "acceptance criteria" but determined via study560.7 CFU/mL (1.12 CFU/PCR) for ATCC 43255, 76.3 CFU/mL (0.15 CFU/PCR) for NAP 1A
    Analytical Reactivity100% detection of tested strains100% (All 20 tested strains detected 3/3 replicates)
    Cross-ReactivityNo cross-reactivity expectedNo cross-reactivity observed (119 potential cross-reactants)
    InterferenceNo interference expectedNo interference observed (21 potentially interfering substances)
    Clinical SensitivityNot explicitly stated as "acceptance criteria" but compared to predicate devicesCompared to Direct Toxigenic Culture: 90.1% (95% CI: 83.8-94.1%)
    Compared to Enriched Toxigenic Culture: 79.6% (95% CI: 73.1-84.8%)
    Clinical SpecificityNot explicitly stated as "acceptance criteria" but compared to predicate devicesCompared to Direct Toxigenic Culture: 93.0% (95% CI: 91.0-94.5%)
    Compared to Enriched Toxigenic Culture: 95.8% (95% CI: 94.2-97.0%)

    Note: For clinical performance, the acceptance criteria are not explicitly stated as numerical targets within the document provided. Instead, the performance is reported and implicitly compared to predicate devices or considered acceptable for the intended use. The reproducibility acceptance criteria are inferred from the 100% or >90% agreement shown in the predicate device data section of the comparison table.

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

    • Reproducibility: A "panel" of contrived samples (high negative, medium positive) spiked with C. difficile bacterial stock was used. For each of the three sites, the Low Positive, Positive Control, High Negative, and No Template Control samples were tested in 30 replicates each (with 29 replicates for one medium positive sample at one site).
    • Limit of Detection (LoD): The LoD was determined using three replicates in an initial screening phase, followed by confirmation using twenty replicates for two C. difficile bacterial strains.
    • Analytical Reactivity: 20 different C. difficile strains were tested, each in triplicate.
    • Cross-Reactivity: A total of 119 potential cross-reactants were tested. Each cross-reactant and baseline sample was tested in multiple replicates (implied at least 3, as mentioned in the interference section that "One replicate reported as "Invalid"... in initial run of three replicates").
    • Interference: 21 potentially interfering substances were spiked into low positive C. difficile samples and tested. The results typically show 3/3 replicates detected for each substance and strain, with some exceptions tested in 5/5 or with repeat runs for invalid/not detected results.
    • Clinical Studies: A total of 970 prospectively collected stool specimens were obtained.
      • Data Provenance:
        • Site 1: Prospectively collected fresh specimens from the East Coast of the US.
        • Site 2: Prospectively collected fresh specimens (and performed toxigenic culture for all specimens, including those from other sites) from the East Coast of the US.
        • Site 3: Prospectively collected clinical specimens from the West Coast of the US and Upper Mid-West of the US.

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

    • Reproducibility, LoD, Analytical Reactivity, Cross-Reactivity, Interference: Ground truth for these analytical studies was established by preparing bacterial stocks and contrived samples with known concentrations and identities. This does not typically involve human experts in the same way clinical ground truth does. The experiments were likely designed and performed by trained laboratory personnel. The document does not specify the number or qualifications of these individuals.
    • Clinical Studies:
      • Ground Truth Method: "Toxigenic Culture" (Direct Culture + Toxin Assay and Enriched Culture + Toxin Assay) was used as the reference method. This is a laboratory-based method.
      • Experts: The document does not specify the number of experts or their qualifications for establishing the toxigenic culture results. It states that "Site 2 conducted all direct and enriched toxigenic culture testing for all specimens," implying trained laboratory personnel rather than a panel of clinical experts for interpretation.

    4. Adjudication Method for the Test Set

    • Analytical Studies (Reproducibility, LoD, Analytical Reactivity, Cross-Reactivity, Interference): Adjudication methods are not explicitly described for these laboratory experiments. The results are typically quantitative or categorical (detected/not detected) based on the assay's output. Any "invalid" results (e.g., in reproducibility and interference sections) led to retesting or were noted.
    • Clinical Studies: The reference method for clinical studies was "Toxigenic Culture." The document does not describe any specific adjudication process involving multiple experts for the toxigenic culture results. "Site 2 conducted all direct and enriched toxigenic culture testing."

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    • No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not performed. This study focuses on an in vitro diagnostic (IVD) assay (PCR) for detecting a pathogen, not on human readers interpreting images or data with or without AI assistance. Therefore, there is no effect size of human readers improving with AI assistance.

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

    • Yes, this study primarily assesses the standalone performance of the Simplexa™ C. difficile Universal Direct assay (an algorithm-based PCR method) without human interpretation as part of the primary diagnostic output. The device itself is an automated real-time PCR system. While human operators are involved in sample preparation and running the instrument, the result (detected/not detected) is generated automatically by the "detection techniques" of "Real time PCR with bi-functional fluorescent probe-primers using the 3M Integrated Cycler."

    7. The Type of Ground Truth Used

    • Analytical Studies: Ground truth was established through known concentrations of bacterial strains and contrived samples for LoD, analytical reactivity, cross-reactivity, and interference studies.
    • Clinical Studies: Ground truth for the clinical agreement study was established using Toxigenic Culture (Direct Culture + Toxin Assay and Enriched Culture + Toxin Assay). This is a laboratory-based gold standard for detecting toxigenic C. difficile.

    8. The Sample Size for the Training Set

    • The document describes premarket notification (510(k)) studies for a diagnostic device. It does not mention a "training set" in the context of machine learning. The studies described are validation studies (analytical and clinical) performed on the final device. Therefore, a specific sample size for a training set is not applicable in this context.

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

    • As a "training set" for machine learning is not applicable in this context, the method for establishing its ground truth is also not applicable.
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