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510(k) Data Aggregation

    K Number
    K231573
    Manufacturer
    Date Cleared
    2024-01-18

    (232 days)

    Product Code
    Regulation Number
    892.5050
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    ThinkQA (Edition 2)

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

    ThinkQA Edition 2 software is used to verify that the dose distribution calculated by a treatment planning system for external beam radiation therapy is consistent with treatment plan parameters.

    Based on read-in treatment plan data, ThinkQA Edition 2 re-calculates a dose distribution in a three-dimensional representation of a patient or a phantom and provides dose-volume indicators which compare it to the initial dose distribution calculated by the treatment planning system.

    ThinkQA Edition 2 is not a treatment planning system. It is a Quality Assurance software only to be used by qualified and trained radiation therapy personnel.

    Device Description

    ThinkQA Edition 2 is a standalone software device used within a radiation therapy clinic which is designed to perform secondary dose calculation based on DICOM RT treatment plan data provided by a treatment planning system.

    ThinkQA Edition 2 is only meant for quality assurance purpose. It cannot define or transmit any instructions to a delivery device, nor does it control any other medical device.

    ThinkQA Edition 2 performs dose calculation verifications for radiation therapy plans by doing an independent calculation of dose distribution in a three-dimensional representation of a phantom. Dose distribution is initially calculated by a treatment planning system which is a software tool that allows to define and transmit treatment plan parameters that will further be used for treatment delivery. Based on treatment plan parameters, ThinkQA Edition 2 re-calculates dose distributions using a proprietary Collapsed Cone Convolution algorithm. It uses CT images (real patient anatomy) to perform dose computation with Collapsed Cone Convolution.

    ThinkQA Edition 2 compares the reference TPS dose distribution with its own calculation using specific indicators such as 3D gamma agreement index on significant volumes. ThinkQA Edition 2 computes Gamma Passing Rate for automatic dose areas and anatomical structures: Planning Target Volumes (PTVs) and Organs at Risk (OARs).

    Based on these indicators, ThinkQA Edition 2 displays a pass/fail status that informs the user whether or not the acceptance criteria that he has defined are met. The acceptance criteria does not give in any way information that could be used to determine whether or not the treatment plan is clinically relevant. It just evaluates the consistency between treatment plan parameters and the dose distribution computed by the TPS.

    ThinkQA Edition 2 has been designed to be compatible with radiotherapy adaptative workflows. This includes a number of mandatory features:

    • User interface design, grouping verifications for adaptive plans under a single primary plan verification; .
    • . Automatic computation upon reception of DICOM data from the TPS;
    • Sufficient speed of computation, compatible with adaptive workflow with patient waiting on couch.

    The performance of ThinkQA Edition 2 makes it suitable for the following photon treatment delivery techniques: Static beams, IMRT Step & Shoot, Dynamic IMRT with fixed gantry and Rotational IMRT (VMAT).

    In order to guaranty the independence of the secondary dose check, the beam models are not intended to be adjusted to match the user's reference TPS. The user only provides its actual measured dose rate in reference conditions and HU-density conversion table.

    ThinkQA Edition 2 runs on workstations or virtual machines with Linux CentOS 7 operating system. Its web interface is accessible from any system supporting the specified in chapter ThinkQA Edition 2 web application. ThinkQA Edition 2 is able to communicate with other equipment installed on the network complying with the DICOM and DICOM RT industry standards.

    AI/ML Overview

    The FDA 510(k) summary for ThinkQA (Edition 2) describes a software device for quality assurance in radiation therapy. The document outlines comparisons to a predicate device (MU2net) and evidence for substantial equivalence, including performance evaluations.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a formal "acceptance criteria" table with specific quantitative thresholds that the device had to meet for its performance evaluation, nor does it provide detailed numerical outputs beyond qualitative statements. However, it implicitly defines a performance expectation related to dosimetric evaluation:

    Acceptance Criteria (Implicit)Reported Device Performance
    Agreement with measured data for beam models (per AAPM WG 219 recommendations)."The agreement between ThinkQA Edition 2, the primary TPS and the measured data was found to be excellent in terms of beam shape and absolute dose."
    Dosimetric evaluation on varied plans using tight gamma index tolerance (2%/2mm, global, 95% passing rate)."The dosimetric evaluation was performed on a large variety of plans with a growing complexity and a tight gamma index tolerance (2%/2mm, global, 95% of passing rate). The overall performance of ThinkQA Edition 2 in terms of beam modelling was found to be satisfactory for the three beam models, with all the tested plans respecting the gamma tolerances. An exception should be noted for a few number of Elekta Unity 7 MV FFF plans sensitive to the electron return effect."
    Consistency with predicate device's decision-making on plan validation/rejection."The same set of plans were evaluated with the predicate MU2net with the recommended relative tolerance of 5% dose difference with reference dose. ThinkQA Edition 2 and MU2net supported the same decision on whether to validate or reject the evaluated plans. Additionally for situations where MU2net control was inconclusive (e.q. prescription point located outside of the irradiated volume) the full 3D gamma evaluation provided by ThinkQA Edition 2 allowed a decision making."
    Mitigation of cybersecurity threats and vulnerabilities."The system tests demonstrate that product outputs have met the product input requirements with a mitigation of threats and vulnerabilities as far as possible."

    2. Sample Size for the Test Set and Data Provenance

    • Test Set Sample Size: The document refers to "a large variety of plans" for the dosimetric evaluation, but a specific number is not provided. For the beam modeling unique to this submission, there were "three beam qualities (6 MV, 6 MV FFF and Elekta Unity 7 MV FFF) and two primary TPS (RayStation and Monaco)."
    • Data Provenance: The document does not specify the country of origin for the data or whether the studies were retrospective or prospective. It implies the data was generated internally for testing and evaluation purposes. The "measured depth dose curves and profiles" suggest real-world or phantom measurements were performed.

    3. Number of Experts and Qualifications

    • Number of Experts: Not explicitly stated. The studies were likely conducted by the manufacturer's internal team, including physicists and engineers specialized in medical physics and radiation therapy.
    • Qualifications of Experts: Not explicitly stated, but the context implies expertise in radiation oncology physics, treatment planning systems, and dose calculation algorithms ("qualified and trained radiation therapy personnel"). The mention of "AAPM working group 219" recommendations suggests adherence to professional standards in radiation oncology physics.

    4. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable in the traditional sense of human interpretation of results. The device's performance was evaluated against physical measurements and established dosimetric metrics (e.g., gamma index passing rate, dose difference). The comparison to the predicate device acted as a form of "adjudication" for decision consistency.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • MRMC Study: No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed. This device is a quality assurance software that performs an objective, mathematical comparison of dose distributions rather than aiding human readers in diagnosis or interpretation that would necessitate an MRMC study. Its purpose is to verify consistency based on defined parameters, not to improve human diagnostic performance.

    6. Standalone (Algorithm Only) Performance

    • Standalone Performance: Yes, the described performance evaluation (dosimetric evaluation, beam modeling) is a standalone assessment of the algorithm's ability to calculate dose distributions and compare them to reference data. The device's output (gamma passing rate, pass/fail status) is based solely on its internal calculations and comparisons, without human intervention in the calculation or the determination of the result itself. Human users then interpret this output.

    7. Type of Ground Truth Used

    • Ground Truth Type:
      • Measured Data: For beam modeling, the ground truth was "corresponding measured depth dose curves and profiles," indicating physical measurements.
      • Reference Treatment Planning System (TPS) Dose Distribution: For the clinical performance evaluation and comparison, the ground truth was implicitly the dose distribution calculated by the "reference TPS" (RayStation and Monaco), against which ThinkQA's calculations were compared using metrics like the gamma index.
      • Predicate Device Output: For consistency checks, the "decision" (validation or rejection) of the predicate device (MU2net) served as a comparative ground truth.

    8. Sample Size for the Training Set

    • Training Set Sample Size: The document does not explicitly discuss a separate "training set" in the context of a machine learning model, as the dose calculation for ThinkQA Edition 2 is based on a "proprietary Collapsed Cone Convolution algorithm" and beam models, rather than a data-driven machine learning approach that would necessitate a distinct training phase with labeled data in the same way. The beam modeling process involves systematic adjustments and evaluations, which could be considered an iterative tuning or "training" specific to dose calculation, but a specific "training set size" is not applicable in the typical AI/ML sense.

    9. How Ground Truth for the Training Set Was Established

    • Ground Truth for Training Set Establishment: Since the core dose calculation algorithm (Collapsed Cone Convolution) is a physics-based model, it does not rely on labeled training data in the way a machine learning algorithm would. The "beam modeling process" involved:
      • Comparison of computed depth dose curves and profiles against "measured depth dose curves and profiles." These physical measurements serve as the ground truth for calibrating and validating the accuracy of the beam models within the CCC algorithm for different beam qualities and TPS.
      • The goal was for the beam models to be independently accurate and not necessarily "adjusted to match the user's reference TPS" to maintain calculation independence.
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