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510(k) Data Aggregation
(80 days)
SYNERGY FOCUS DESKTOP VERSION; SYNERGY FOCUS LAPTOP VERSION
The Synergy Focus is intended for the acquisition, display, analysis, storage, reporting, and management of electrophysiological information from the human nervous and muscular systems including Nerve Conduction (NCS), Electromyography (EMG), Evoked Potentials (EP), Autonomic Responses and Intra-Operative Monitoring including Electroencephalography (EEG).
Evoked Potential (EP) includes Visual Evoked Potentials (VEP), Auditory Evoked Potentials (AEP), Somatosensory Evoked Potentials (SEP), Electroretinography (ERG), Electrooculography (EOG), P300, Motor Evoked Potentials (MEP) and Contingent Negative Variation (CNV). The Synergy Focus may be used to determine autonomic responses to physiologic stimuli by measuring the change in electrical resistance between two electrodes (Galvanic Skin Response and Sympathetic Skin Response). Autonomic testing also includes assessment of RR Interval variability. The Synergy Focus is used to detect the physiologic function of the nervous system, for the location of neural structures during surgery, and to support the diagnosis of neuromuscular disease or condition.
The listed modalities do include overlap in functionality. In general, Nerve Conduction Studies measure the electrical responses of the nerve; Electromyography measures the electrical activity of the muscle and Evoked Potentials measure electrical activity from the Central Nervous System.
The Synergy Focus is intended to be used by a qualified healthcare provider.
The Natus Synergy Focus (Synergy Focus) is designed for the acquisition, display, analysis, reporting, and management of electrophysiological information from the human nervous and muscular systems. The system is designed to perform nerve conduction studies (NCS), needle electromyography (EMG) testing, evoked potential (EP) testing, and intra-operative monitoring (IOM). Synergy Focus provides a variety of tests spanning the various modalities.
The Synergy Focus consists of the following major components:
- Console base unit with integrated control panel;
- Amplifier (with three non-switched amplifier channels);
- Desktop or laptop computer with a keyboard and mouse;
- Display monitor; and
- Synergy Software.
The Synergy Focus optional accessories/components consists of the following:
- Stimulator probes (RS 10 probe, Stimulus Probe with controls)
- Footswitches (triple)
- LED goggles
- Headphones or other auditory transducers
- Patient response button
- Cart
- Isolation transformer
- Printer.
The Natus Synergy Focus is an electromyograph (EMG) device intended for the acquisition, display, analysis, reporting, and management of electrophysiological information from the human nervous and muscular systems.
Here's an analysis of its acceptance criteria and the study that proves its performance:
1. Table of Acceptance Criteria and Reported Device Performance
The FDA clearance relies heavily on demonstrating substantial equivalence to predicate devices (K112052 CareFusion Nicolet EDX with Viking Software and K120979 CareFusion Nicolet EDX with Synergy Software). Therefore, the "acceptance criteria" are primarily defined by the performance characteristics of these predicate devices, and the "reported device performance" demonstrates that the Synergy Focus either matches or improves upon these characteristics, or where there are differences, they do not raise new questions of safety or effectiveness.
Characteristic | Predicate Device Performance | Natus Synergy Focus Performance | Discussion of Differences |
---|---|---|---|
General Characteristics | |||
Indications for Use | Same as predicate devices | Intended for the acquisition, display, analysis, storage, reporting, and management of electrophysiological information from the human nervous and muscular systems (NCS, EMG, EP, Autonomic Responses, IOM including EEG). Specific EPs listed (VEP, AEP, SEP, ERG, EOG, P300, MEP, CNV). Autonomic testing includes galvanic skin response, sympathetic skin response, and RR interval variability. | Identical to the Nicolet EDX with Viking and Synergy software. |
Warnings/Contraindications | Same as predicate devices | Same as predicate devices | Identical to the Nicolet EDX with Viking or Synergy software. |
General Systems Approach | Computer-based with dedicated hardware | Computer-based with dedicated hardware | Identical to the Nicolet EDX with Viking or Synergy software. |
User Input Device | Window mouse/keyboard driven graphic interface with dedicated control panel. | Window mouse/keyboard driven graphic interface with dedicated control panel. | Identical to the Nicolet EDX with Viking or Synergy software. |
User Output Device | Digital color display and commercial printers | Digital color display and commercial printers | Identical to the Nicolet EDX with Viking or Synergy software. |
Patient Inputs | 2 to 8 channel amplifier, isolated | 1 to 3 channel amplifier, isolated | Subset of the Nicolet EDX with Viking or Synergy software (fewer channels). This difference does not raise new questions of safety or effectiveness as it is a reduction in capability, not a change in fundamental operation. |
Signal Acquisition Sample Rate | 48kHz sample rate | 48kHz sample rate | Identical to the Nicolet EDX with Viking or Synergy software. |
Footswitch | Yes (various types) | Triple footswitch only | Triple footswitch only, identical to the triple footswitch in the Nicolet EDX with Viking or Synergy software. |
Operating System | Microsoft Windows | Microsoft Windows | Identical to the Nicolet EDX with Viking or Synergy software. |
Safety Standards | EN/IEC 60601-1, IEC 60601-1-1, IEC 60601-1-2, IEC 60601-2-40, ISO 10993-1, ISO 14971 | Compliance with all listed standards | Identical to the Nicolet EDX with Viking or Synergy software. |
Patient Circuitry Isolation | Optic/transformer | Optic/transformer | Identical to the Nicolet EDX with Viking or Synergy software. |
System Components | EDX base console including 2 electrical stimulators, auditory stimulator, trigger input/output, LED goggle interface; Control panel; Amplifier; Computer, monitor, keyboard, mouse, printer | Base console including 1 electrical stimulator, auditory stimulator, trigger input/output, LED goggle interface; Control panel; Amplifier; Computer, monitor, keyboard, mouse, printer | Equivalent to the Nicolet EDX with Viking or Synergy software with only 1 electrical stimulator. This is a reduction in quantity, not function. |
System - Computer Interface | USB | USB | Identical to the Nicolet EDX with Viking or Synergy software. |
System Power Supply | Mains (100–240 VAC) thru an isolation transformer | Mains (100–240 VAC) thru an isolation transformer | Identical to the Nicolet EDX with Viking or Synergy software. |
Amplifier Power Supply | 15 VDC from base console | 15 VDC from base console | Identical to the Nicolet EDX with Viking or Synergy software. |
Size (Base Console) | 35.6 x 34.3 x 8.6 cm | 39.3 x 34.2 x 7.6 cm | Similar in size to the Nicolet EDX with Viking or Synergy software. |
Weight (Base Console) | 3.5 kg | 3.3 kg | Similar in weight to the Nicolet EDX with Viking or Synergy software. |
Acquisition Characteristics | |||
Number of Channels | 2 to 8 | 1 to 3 | Identical to the Nicolet EDX with Viking or Synergy software |
CMMR | > 110 dB | > 110 dB | Identical to the Nicolet EDX with Viking or Synergy software. |
Noise | 1000 MΩ | >1000 MΩ | Identical to the Nicolet EDX with Viking or Synergy software. |
Low Filter | 0.05 Hz to 5 kHz | 0.05 Hz to 5 kHz | Identical to the Nicolet EDX with Viking or Synergy software. |
High Filter | 30 Hz to 20 kHz | 30 Hz to 20 kHz | Identical to the Nicolet EDX with Viking or Synergy software. |
Notch Filter | 50 / 60 selectable | 50 / 60 selectable | Identical to the Nicolet EDX with Viking or Synergy software. |
A/D Conversion | 24 bit | 24 bit | Identical to the Nicolet EDX with Viking or Synergy software. |
Sampling Rate (cumulative) | 384 kHz | 144 kHz | Per channel sample rate of 48 kHz is identical to the Nicolet EDX with Viking or Synergy software. The reduction in cumulative sampling rate is due to the reduced number of channels. |
Time Base Range | 0.01 to 5000 ms | 0.01 to 5000 ms | Identical to the Nicolet EDX with Viking or Synergy software. |
Impedance Meter | 500 Ω to 480 kΩ | 1 kΩ to 1,000 kΩ | Able to measure higher electrode impedance than the Nicolet EDX with Viking or Synergy software. (Improvement is acceptable). |
Stimulator Characteristics | |||
Electrical Stimulator Type | Constant Current or Constant Voltage | Constant Current | Identical to the Nicolet EDX with Viking or Synergy software, only constant current. (Reduction in type, not fundamental function). |
Electrical Stimulator Number | 1 or 2 | 1 | Identical to the Nicolet EDX with Viking or Synergy software with only 1 stimulator. (Reduction in quantity, not fundamental function). |
Electrical Stimulator Max Output | 100mA or 400V | 100mA | Identical to the Nicolet EDX with Viking or Synergy software, only constant current. (Relevant to the chosen type). |
Auditory Stimulator Tone Freq. | 125 to 8000 Hz (Synergy); 250 to 8000 Hz (Viking) | 125 to 8000 Hz | The Synergy Focus aligns with the CareFusion Nicolet EDX with Synergy System. (Allows broader range than original Viking). |
2. Sample Size Used for the Test Set and Data Provenance
The provided 510(k) summary does not explicitly state a sample size for a test set or data provenance in the context of clinical performance or AI/algorithm performance.
Instead, the submission relies on demonstrating substantial equivalence to its predicate devices (K112052 and K120979) through:
- Comparison of technical characteristics.
- Non-clinical performance testing (biocompatibility, software validation, electrical safety, EMC, and bench testing to applicable standards like IEC 60601-2-40).
- The explicitly stated conclusion that "Animal testing and clinical testing were not needed to demonstrate safety and effectiveness."
This indicates that there was no separate "test set" of patient data used for evaluating the performance of the Synergy Focus in a clinical or AI context, as its performance is considered equivalent due to identical or functionally equivalent hardware and software to already cleared devices.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Since no clinical or AI-specific test set was used requiring ground truth establishment by experts, this information is not applicable to this 510(k) submission.
4. Adjudication Method for the Test Set
As no test set involving human interpretation requiring adjudication was used, this information is not applicable.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
An MRMC comparative effectiveness study was not done. The submission explicitly states that "Animal testing and clinical testing were not needed to demonstrate safety and effectiveness," and the device is a diagnostic electromyograph, not an AI-assisted diagnostic tool in the sense of image interpretation. Therefore, there is no AI assistance improvement effect size to report.
6. Standalone (Algorithm Only) Performance Study
A standalone performance study focused on an algorithm's performance without human-in-the-loop was not done. The Synergy Focus is a hardware and software system for acquiring and displaying physiological signals, not a standalone algorithm providing diagnostic outputs. The software component, categorized as "MODERATE level of concern," underwent rigorous verification and validation during development, as noted in the "Software testing" section, but this is distinct from an AI algorithm's standalone performance study.
7. Type of Ground Truth Used
Given the nature of the device and the submission's focus on substantial equivalence through technical characteristics and non-clinical testing, there was no "ground truth" derived from expert consensus, pathology, or outcomes data in the context of evaluating the diagnostic accuracy of a new algorithm or clinical performance. The ground truth (or reference standard) in this submission relates to:
- Engineering specifications and standards: The device's performance was compared against the technical specifications of the predicate devices and national/international standards (e.g., IEC 60601-2-40 for safety and performance of electromyographs).
- Predicate device characteristics: The primary "ground truth" for demonstrating substantial equivalence was the established safety and effectiveness of the Nicolet EDX with Viking and Synergy software systems.
8. Sample Size for the Training Set
Since there is no mention of an AI algorithm or machine learning component in this submission that would require training data, information regarding the sample size for a training set is not applicable. The software validation focused on standard software development lifecycle testing (verification and validation of pre-determined specifications), not on training a model.
9. How the Ground Truth for the Training Set Was Established
As there was no training set for an AI algorithm, the question of how its ground truth was established is not applicable.
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