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510(k) Data Aggregation
(160 days)
Ultimate rTMS
The Ultimate rTMS is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medications in the current episode.
The Ultimate rTMS is a repetitive transcranial magnetic stimulation (rTMS) system. This computerized medical device produces non-invasive, repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex for the treatment of Major Depressive Disorder.
It can be used in patient care institutions, diagnostics centers, neurosurgical hospitals and experimental laboratories of research institutions.
The Ultimate rTMS principle of operation is based on the discharge of high voltage capacitor through stimulation coil; the pulsed magnetic field generated by the discharge current penetrates through neuromuscular tissues nearby to induce electrical currents in cortical neurons.
Area of the brain to be simulated for MDD treatment is Left Dorsolateral Prefrontal Cortex.
This 510(k) clearance letter details the substantial equivalence of the Ultimate rTMS device to its predicate devices, Mag Vita TMS Therapy System. The provided information primarily focuses on non-clinical performance and technological comparisons, rather than a clinical trial with human subjects. Therefore, some information requested in your prompt regarding clinical study elements (like sample size for test sets, ground truth establishment for test sets, expert adjudication, or MRMC studies) is not explicitly detailed or applicable in the provided document.
Here's the breakdown of the acceptance criteria and the study (non-clinical performance tests) that proves the device meets them, based on the provided text:
Acceptance Criteria and Reported Device Performance
The acceptance criteria are not explicitly listed in a separate table, but rather implied through the "Equivalence Comments" in the "Technological Comparison" and the "Non-clinical and/or Clinical Tests Summary & Conclusions" sections. The core acceptance criterion is substantial equivalence to the predicate devices, meaning the Ultimate rTMS device performs similarly and does not raise new safety or effectiveness concerns.
Here's a table summarizing the key performance metrics and their comparison to predicates, which serve as the "acceptance criteria" through equivalence:
Criteria | Acceptance Criteria (Equivalent to Predicate) | Reported Ultimate rTMS Performance |
---|---|---|
Magnetic Field Intensity (SMT units) | Comparable to predicate (e.g., 0-2.1 to 0-2.4 SMT range, with 1 SMT achieved at similar % intensity settings). | BY90A, BF90A, BY90B Coils: 0 – 2.4 SMT (41% intensity → 1 SMT). |
(Predicate MagVita: 0 – 2.1 SMT, 47% intensity → 1 SMT). | ||
Comment: Slightly lower intensity setting needed for Ultimate rTMS to achieve same induced current, indicating favorable performance. | ||
Waveform | Biphasic sinusoid. | Biphasic sinusoid. |
Active Pulse Width (µs) | Comparable to predicate (e.g., 290 µs ± 5% for MagVita) within typical variations among cleared TMS devices. | BY90A, BF90A, BY90B Coils: 320 µs ± 10%. |
(Predicate MagVita: 290 µs ± 5%). | ||
Comment: Difference is comparable to other cleared devices. Higher pulse width means lower intensity needed to reach MT, aligned with SMT comparison. | ||
Max Magnetic Field Strength 2 cm (T) | Comparable values to predicate across intensity settings, with equivalent slope and intercept values. | At 25% Intensity: BY90A: 0.172 T, BF90A: 0.182 T, BY90B: 0.117 T. |
At 50% Intensity: BY90A: 0.291 T, BF90A: 0.287 T, BY90B: 0.244 T. | ||
At 75% Intensity: BY90A: 0.403 T, BF90A: 0.395 T, BY90B: 0.369 T. | ||
At 100% Intensity: BY90A: 0.498 T, BF90A: 0.494 T, BY90B: 0.481 T. | ||
(Predicates values provided for comparison). | ||
Comment: Values are in a narrow range and show equivalent behavior despite slight differences. | ||
Max Initial dB/dt (kT/s) (near/2cm from coil) | Sufficiently close to predicate values. | Near Coil (z=0cm): BY90A: 13.44, BF90A: 13.76, BY90B: 12.10. |
2cm from Coil (z=2cm): BY90A: 3.59, BF90A: 4.27, BY90B: 6.78. | ||
(Predicates values provided for comparison). | ||
Comment: Considered equivalent; differences compensated by differing % power for 120% MT. | ||
Output Intensity Stability within Burst | Max change |
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(160 days)
Ultimate rTMS for OCD (M-series)
The Ultimate rTMS for OCD is intended to be used as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder(OCD).
The Ultimate rTMS for OCD is a repetitive transcranial magnetic stimulation (rTMS) system. This computerized medical device produces non-invasive, repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex for the treatment of Obsessive-Compulsive Disorder (OCD).
It can be used in patient care institutions, diagnostics centers, neurosurgical hospitals and experimental laboratories of research institutions.
The Ultimate rTMS principle of operation is based on the discharge of high voltage capacitor through stimulation coil; the pulsed magnetic field generated by the discharge current penetrates through neuromuscular tissues nearby to induce electrical currents in cortical neurons.
Area of the brain to be simulated for ODC treatment is the Dorsomedial Prefrontal Cortex.
The provided FDA 510(k) clearance letter and summary for the "Ultimate rTMS for OCD (M-series)" device focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance characteristics, rather than a clinical study evaluating the device's efficacy in treating OCD. Therefore, it does not contain the detailed information about clinical acceptance criteria, study design (sample size, data provenance, expert adjudication, MRMC, standalone performance, ground truth for test/training sets) that would typically be found in a clinical trial report.
The document primarily shows that the new device's technical specifications and physical/magnetic properties are comparable to a previously cleared device. It asserts that the proposed device does not introduce new safety concerns and has equivalent performance characteristics based on bench testing.
Here's an attempt to answer the questions based on the provided text, with many fields marked as "Not Applicable" or "Not Provided" due to the nature of the submission:
1. Table of acceptance criteria and the reported device performance
The acceptance criteria are implicitly defined by the demonstration of substantial equivalence to the predicate device (MagVenture TMS Therapy system K193006) through close matching of technological characteristics and non-clinical performance (bench testing) according to FDA guidance. The "reported device performance" are the measured values for the Ultimate rTMS for OCD (M-series) in comparison to the predicate.
Criteria (Implicit Acceptance based on Predicate Equivalence) | Proposed Device Ultimate rTMS for OCD Performance (Reported) | Predicate Device MagVenture TMS Therapy system (K193006) Performance (Reported) | Equivalence Comments (Context of Acceptance) |
---|---|---|---|
Intended Use | Treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD) | Treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD) | Identical |
Treatment Protocol (Magnetic Field Intensity, Frequency, Train/Inter-train duration, Pulses/Session, Session Duration, Sessions/week, Treatment Schedule, Area of brain to be stimulated) | All match predicate values | All specified | Identical |
Coil Configuration | Double-cone coil | Double-cone coil | Identical |
Coil Materials of Construction | Copper tubing (GIS-C1100), Polycarbonate (Covestro Makrolon PC 2805) | Copper tubing (unknown), Polycarbonate (unknown) | Equivalent, no additional concerns for safety and effectiveness. |
Core material | Air core | Air core | Identical |
Cooling | Liquid cooling | Liquid cooling | Identical |
Coil for MT determination | Used for both MT determination and treatment. | Used for both MT determination and treatment. | Identical |
Number of Turns/Wing | 8 (Upper: 4, Lower: 4) | 7 (Upper: 4, Lower: 3) | Equivalent (See Note A for explanation). |
Inner/Outer Diameter of Winding | Inner: 50 mm, Outer: 105 mm | Inner: 67 mm, Outer: 95 mm | Equivalent (See Note A for explanation). |
Amplitude in SMT units | 0-2.22 SMT (45% intensity → 1 SMT) | 0-2.38 SMT (42% intensity → 1 SMT) | Comparable, within variations seen across cleared TMS devices (See Note B). |
Waveform | Biphasic sinusoid | Biphasic sinusoid | Identical |
Active pulse width (μs) | Measured: 308.6 (spec: 300 ±5%) | Measured: 302.2 (spec: 290 ±5%) | Equivalent, compensated by MT settings (See Note C). |
Max magnetic field strength 3 cm from coil (T) | At 25%: 0.147; 50%: 0.225; 75%: 0.297; 100%: 0.380 | At 25%: 0.119; 50%: 0.212; 75%: 0.301; 100%: 0.391 | Equivalent, narrow range, similar slope and intercept. Compensated by MT settings (See Note D). |
Max initial dB/dt (kT/s) near coil surface (z=0 cm) | 21.4 | 21.9 | Sufficiently close, compensated by MT settings (See Note E). |
Max initial dB/dt (kT/s) 3 cm from coil surface (z=3 cm) | 7.73 | 8.12 | Sufficiently close, compensated by MT settings (See Note E). |
Coil temperature exceed auto-disable | 40°C (104°F) | 41°C (106°F) | Slightly enhanced safety for proposed device. |
Frequency range (Hz) | 0.1 - 100 | 0.1 - 30 or 0.1 - 100 (model dependent) | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
Pulse train duration range (s) | Up to 2000 pulses in train | Up to 1000 pulses in train | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
Inter-train interval range (s) | 0-60s | 0-120s | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
Maximum trains per session | 250 | 500 | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
Maximum number of pulses per session | 500,000 | 500,000 | Identical maximum. |
Electrical safety | Complies with IEC 60601-1, IEC 60601-1-2 | Complies with IEC 60601-1, IEC 60601-1-2 | N/A |
ISO Standards met | ISO 13485:2016, ISO 14971 | ISO 13485:2016 | N/A |
2. Sample size used for the test set and the data provenance
- Sample size: Not applicable. The submission is based on non-clinical (bench) testing of the device's physical and magnetic characteristics rather than a clinical test set of patients.
- Data provenance: Not applicable. The data arises from engineering measurements and comparative bench testing of the physical device components (coils, stimulator output).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of experts: Not applicable. Ground truth for clinical efficacy or diagnosis using patient data is not established in this non-clinical submission.
- Qualifications of experts: Not applicable. Engineering and technical experts would have conducted and verified the bench tests.
4. Adjudication method for the test set
- Adjudication method: Not applicable. This was a non-clinical (bench) testing comparison, not a clinical study requiring adjudication of patient outcomes or diagnoses.
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
- MRMC study: No. This is not an AI-assisted diagnostic or therapeutic device that involves human "readers" or image interpretation. It is a TMS system for direct treatment.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone performance: Not applicable. This is a medical device, not a software algorithm in the context of interpretation. Its "standalone" performance is assessed by its physical and magnetic output characteristics in bench tests.
7. The type of ground truth used
- Type of ground truth: The "ground truth" in this context is the measured physical and electromagnetic properties of the new Ultimate rTMS device compared to the established properties of the predicate MagVenture TMS Therapy system, as well as adherence to recognized safety standards (IEC, ISO). The substantial equivalence is built upon the premise that if the new device behaves physically like the predicate, and the predicate is known to be safe and effective, then the new device is also considered safe and effective for the stated indications.
8. The sample size for the training set
- Sample size for training set: Not applicable. This is a conventional medical device whose performance is characterized by its engineering specifications and bench test results. It does not involve machine learning or AI that requires a "training set."
9. How the ground truth for the training set was established
- Ground truth for training set: Not applicable (as above).
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(181 days)
Ultimate rTMS; Yingchi rTMS
The Ultimate rTMS is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
The Ultimate rTMS is composed of stimulation generator and stimulation coil. The stimulation generator contains a high voltage energy storage capacitor charging and discharging system, an auxiliary power supply, a microcomputer control system, and a cooling system. The stimulation coil is composed of a stimulation coil, a cooling system, a data collection system, and a communication system.
- Magnetic Stimulator
- Cooling unit
- Coils
- Coil Figure-of-eight coil (BF90A)
- Coil Figure-of-eight coil (BY90A)
- Coil Figure-of-eight coil-With angle 120°(BY90B)
- Trolley (optional)
- Coil holder (optional)
- PC (optional)
- PC keyboard (optional)
The provided text describes a 510(k) premarket notification for the Brain Ultimate, Inc. Ultimate rTMS device. The main purpose of a 510(k) submission is to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving the device meets specific acceptance criteria through a full clinical study with acceptance criteria.
Therefore, the document does not contain an acceptance criteria table from a clinical trial, nor does it describe a study specifically designed to prove device performance against such criteria. Instead, it focuses on non-clinical performance data and a comparison to predicate devices to establish substantial equivalence.
Here's an analysis of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
This information is not provided in the document as it is a 510(k) submission primarily focused on demonstrating substantial equivalence to predicate devices, not on proving performance against a specific set of clinical acceptance criteria for a new clinical indication. The document presents a side-by-side comparison of the Ultimate rTMS with predicate devices, outlining technical specifications and treatment parameters, not clinical acceptance criteria.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not applicable/provided as the submission states: "CLINICAL PERFORMANCE DATA: Not applicable. Clinical performance data was not relied upon to demonstrate substantial equivalence." The testing described is non-clinical performance data related to electrical safety, electromagnetic compatibility, biocompatibility, software verification/validation, risk management, and magnetic field characteristics. These tests do not involve human subjects or clinical data sets in the traditional sense of a "test set" for performance evaluation.
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 information is not applicable/provided. Since no clinical performance data was relied upon and no "test set" with ground truth established by experts is mentioned, this information is not relevant to this 510(k) submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not applicable/provided. No clinical test set requiring adjudication is described.
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 information is not applicable/provided. The device is an rTMS system for Major Depressive Disorder treatment, not an AI-assisted diagnostic or interpretative device that would typically involve human readers or MRMC studies.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable/provided. The Ultimate rTMS is a physical medical device (repetitive transcranial magnetic stimulation system), not a standalone algorithm. Its software is mentioned as undergoing verification and validation, but this refers to the software controlling the device, not a standalone performance evaluation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
This information is not applicable/provided. As stated, "Clinical performance data was not relied upon to demonstrate substantial equivalence." Non-clinical tests were performed against established standards (e.g., IEC 60601-1, ISO 10993-1, ISO 14971) and against the characteristics of predicate devices. "Ground truth" in the context of clinical performance is not discussed.
8. The sample size for the training set
This information is not applicable/provided. No machine learning or AI algorithm requiring a training set is described for performance evaluation in the supplied text.
9. How the ground truth for the training set was established
This information is not applicable/provided. As no training set is described, the method for establishing its ground truth is also not applicable.
Summary of the Study and Device Proof of Meeting Criteria (based on provided text):
The document describes a 510(k) premarket notification for the Ultimate rTMS device. The "study" referenced is a combination of non-clinical performance testing and a comparison to legally marketed predicate devices to demonstrate substantial equivalence, not to prove the device meets specific clinical acceptance criteria in a de novo clinical trial.
The non-clinical performance data included:
- Electrical safety and electromagnetic compatibility testing: Compliance with IEC 60601-1:2012 and IEC 60601-1-2: 2014.
- Biocompatibility evaluation: The positioning cap meets ISO 10993-1:2018 standards.
- Software verification and validation testing: Demonstrated that the software performs as intended and in accordance with specifications, following FDA software guidelines.
- Risk management: Identified and evaluated potential risks in compliance with ISO14971:2019, with risks determined acceptable or addressed.
- Magnetic field characteristics testing: Conducted in accordance with FDA's "Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS) Systems." This included testing linearity of output levels, magnetic field strength gradients, output waveform, and magnetic field spatial distribution for the Ultimate rTMS coils against a predicate device.
The demonstration of meeting "acceptance criteria" is primarily centered on showing that the Ultimate rTMS is substantially equivalent to predicate devices (MagVita TMS Therapy System, K171481, and Rapid² Therapy System, K143531). This equivalence is based on:
- Identical intended use/indication for use: Treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
- Identical treatment parameters: Recommended standard treatment (Magnetic Field Intensity, Frequency, Train duration, Inter-train interval, Number of trains, Magnetic Pulses per Session, Sessions/week, Treatment Schedule, Area of brain to be stimulated).
- Similar technological characteristics: Both use the same mechanism of action (electromechanical instrument producing pulsed magnetic fields to induce electrical currents in the prefrontal cortex).
- Comparison of coils: All coils share the same figure-of-eight transducer design and air core material. Differences in coil dimensions, windings, and cooling mechanisms were analyzed and deemed not to impact safety or effectiveness.
- Comparison of machine output parameters: Amplitude, waveform (biphasic sinusoid for all), active pulse width, pulse amplitude, max magnetic field strength, and max initial dB/dt were compared and deemed substantially equivalent, with minor differences not impacting safety or effectiveness. For instance, the Ultimate rTMS has a slightly lower intensity setting to achieve the same induced current as the predicate device, which is compensated for by adjusting intensity settings for 120% MT treatment. Coil temperature safety shut-off (40°C for Ultimate rTMS vs 41°C for predicate) was considered a slightly enhanced safety feature.
- Compliance with relevant standards: ISO 13485, ISO 10993-1, ISO 14971, IEC 60601-1, and IEC 60601-1-2.
The conclusion is that based on the non-clinical testing and side-by-side comparison, the Ultimate rTMS is substantially equivalent and does not introduce new safety concerns compared to the predicate devices.
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