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510(k) Data Aggregation
(68 days)
The EasyPlus Self-Monitoring Blood Glucose System is used by individuals with diabetes. It is for the quantitative measurement of glucose levels in fresh capillary whole blood from fingerstick, as an aid in monitoring the effectiveness of diabetes management in the home and in clinical settings.
The EasyPlus Self Monitoring Blood Glucose System is comprised of the EasyPlus Blood Glucose Meter, EasyPlus Glucose Test Strips, Auto Lancet, Check strip, code card and control solutions.
Here's an analysis of the acceptance criteria and study detailed in the provided 510(k) summary for the EasyPlus Self Monitoring Glucose Test System:
Acceptance Criteria and Device Performance
The provided document does not explicitly state formal "acceptance criteria" with predefined thresholds that the device had to meet. Instead, it presents performance characteristics (precision, linearity, method comparison) and implies that these characteristics are acceptable because they are comparable to a predicate device and align with general guidelines (e.g., ISO 15197:2003, though the specific clauses for acceptance aren't detailed).
However, based on the performance data presented, here's a table summarizing the reported device performance, with an interpretation of what would generally be considered acceptable for a blood glucose monitor. Please note that the "Acceptance Criteria" column is a general interpretation based on industry standards for glucose meters, as the document itself does not explicitly list these as formal acceptance criteria.
Category | Performance Metric | Reported Device Performance (EasyPlus) | Interpreted Acceptance Criteria (General for BGMs) |
---|---|---|---|
Analytical Performance | |||
Precision (Within-run) | CV (%) for various glucose ranges | 30-50 mg/dL: 6.2% | |
51-110 mg/dL: 4.5% | |||
111-150 mg/dL: 4.2% | |||
151-250 mg/dL: 2.7% | |||
251-400 mg/dL: 2.8% | |||
401-550 mg/dL: 2.2% | Typically ≤ 10% for concentrations 0.98, slopes close to 1, small y-intercepts. | ||
Detection Limit/Reportable Range | 30-550 mg/dL | Clearly defined and clinically appropriate range. | |
Method Comparison | Linear regression (Patient vs. YSI) | y = 0.95x + 7.41, r² = 0.976 | r² > 0.95, slopes close to 1, small y-intercepts. Typically, error grid analysis is used for clinical acceptance. |
Linear regression (HCP vs. YSI) | y = 0.95x + 7.91, r² = 0.971 | r² > 0.95, slopes close to 1, small y-intercepts. | |
Linear Regression (EasyPlus vs. Predicate) | Not explicitly detailed, but stated: "EasyPlus vs. predicate device: The linear regression was not explicitly stated, but it says "And compare with predicate device, the linear regressions was as follows:" implying a comparison was done. | Assumed to be very similar to the predicate device. |
Study Information
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Sample size used for the test set and the data provenance:
- Precision (Within-run): Total 1200 tests (6 glucose levels x 200 tests each for N). Data provenance is not specified, but the study was conducted internally by EPS Bio Technology Corp. (Taiwan, R.O.C.). It's a prospective internal lab study.
- Precision (Day-to-day): Total 1200 measurements (3 control solutions x 400 measurements each for n). Data provenance not specified; prospective internal lab study.
- Linearity: 630 tests (7 glucose ranges x 10 meters x 3 strip lots assumed, based on the text "among the seven glucose ranges per each strip lot."). This is an internal lab study.
- Method Comparison: 205 people with diabetes. Data provenance not specified, but given the company location, likely Taiwan, R.O.C. This is a prospective clinical study involving actual patient samples.
- Interference Testing: Not explicitly stated how many samples per interferent, but conducted internally.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Precision and Linearity: The ground truth or reference method was the preparation of specific glucose concentrations in blood samples. This does not involve human experts establishing ground truth in the traditional sense, but rather laboratory techniques with reference standards (NIST Traceability mentioned).
- Method Comparison: The YSI Glucose Analyzer was used as the reference method (ground truth) for blood glucose measurements. The YSI is a laboratory reference instrument, not a human expert.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- No human adjudication method was used for establishing ground truth in these analytical performance studies. The ground truth was established by laboratory reference methods (YSI glucose analyzer, NIST traceable standards).
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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:
- No MRMC comparative effectiveness study was done. This device is a self-monitoring blood glucose system, which measures glucose levels directly, rather than relying on human interpretation of images or other subjective data that would necessitate an MRMC study.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Yes, the performance studies presented (precision, linearity, detection limit, analytical specificity) are all standalone performance evaluations of the device's accuracy and reliability in measuring glucose. The method comparison also evaluates the device's standalone performance against a gold standard (YSI). While a healthcare professional also used the device, this was to compare their use to the YSI, and the patient use was also standalone. The device is designed for independent use.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For precision, linearity, and analytical specificity, the ground truth was established using known concentrations of glucose (often prepared using NIST traceable standards) in blood or control solutions.
- For method comparison, the ground truth was established using a laboratory reference method, specifically the YSI Glucose Analyzer. The YSI is a highly accurate and widely accepted laboratory instrument for measuring blood glucose, often considered a "gold standard" for such comparisons.
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The sample size for the training set:
- The document does not explicitly mention a "training set" in the context of machine learning or AI models. This device is an electrochemical biosensor. Its "training" is inherent in its design and calibration, not in a separate software training phase with a distinct dataset. The performance characteristics studies are for validation of the device, not for training.
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How the ground truth for the training set was established:
- As there's no mention of a traditional "training set" for an AI/ML algorithm, this question isn't directly applicable. The device's calibration would be based on known glucose concentrations using highly accurate reference methods, presumably traceable to international standards (NIST traceability is mentioned for the device itself).
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