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510(k) Data Aggregation
(253 days)
EmbryoGen® is for fertilization and culture until the 2-8 cell stage. EmbryoGen® can also be used for embryo transfer at day 2 or 3.
EmbryoGen® is designed to provide physiological conditions for the embryo from fertilization to Day 3 at the time when the embryo under in vivo conditions would be transported through the oviduct. EmbryoGen® is based on the FDA-cleared culture media EmbryoAssist™(K080473) supplemented with Leukine (sargramostim) GM-CSF. EmbryoGen is supplied in sterilized transparent glass bottles with polypropylene screw top closure in a volume of either 3 mL or 5 mL. The media is colorless, sterile and ready to use by professionals for assisted reproduction. EmbryoGen is quality control tested before release for pH, sterility, Mouse Embryo Assay, endotoxin, osmolality, GM-CSF concentration (by ELISA), GM-CSF potency (TF-1 cell assay) and HSA concentration (by ELISA).
Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Acceptance Criteria and Device Performance
The provided document focuses on demonstrating substantial equivalence to a predicate device, rather than explicit acceptance criteria with pre-defined thresholds for performance metrics. The primary "acceptance criteria" here are implicitly tied to proving that EmbryoGen® is as safe and effective as the predicate device, EmbryoAssist™ (K080473), with the added benefit of GM-CSF.
The study aimed to demonstrate a 25% relative increase in ongoing implantation rate at gestational week 7 as its primary hypothesis. While this was the initial goal, the overall study results did not meet this specific statistical significance for the general population. However, the device's performance within a specific subgroup did show a significant improvement.
Here's a table summarizing the implicit acceptance criteria and the device's reported performance within the context of substantial equivalence:
| Acceptance Criteria (Implicit, based on substantial equivalence and study goals) | Reported Device Performance (EmbryoGen® with GM-CSF) | Control Device Performance (EmbryoAssist™) | Statistical Significance (p-value) | Notes |
|---|---|---|---|---|
| Primary Endpoint: Overall Ongoing Implantation Rate (Gestational Week 7) - Demonstrate a 25% relative increase. | 23.5% | 20.0% | p=0.17 | Not statistically significant for the overall unselected population. |
| Secondary Endpoint: Overall Ongoing Implantation Rate (Gestational Week 12) - Not explicitly defined as a target, but evaluated. | 23.0% | 18.7% | p=0.02 | Statistically significant for the overall unselected population. |
| Secondary Endpoint: Overall Live Birth Rate - Not explicitly defined as a target, but evaluated. | 28.9% | 24.1% | p=0.03 | Statistically significant for the overall unselected population, attributed primarily to suboptimal performance of the control with low HSA. |
| Subgroup Performance: Ongoing Implantation Rate (Gestational Week 7) in women with at least one previous miscarriage. | 24.5% | 17.0% | p=0.001 | Statistically significant in this subgroup, regardless of HSA concentration. |
| Subgroup Performance: Live Birth Rate in women with at least one previous miscarriage. | 29.6% | 23.1% | p=0.02 | Statistically significant in this subgroup. |
| Safety: No unacceptable clinical risks (miscarriages, abnormalities/malfunctions). | No indications of unacceptable clinical risks; equivalent to control. | Equivalent to test. | Not applicable (safety assessment). | Study with 369 babies born showed no worse outcomes than control in terms of miscarriages and abnormalities. Chromosomal constitution also not worse. |
| Embryo Quality/Quantity: No negative effect on number of top quality embryos or normally developed Day 3 embryos. | No effect found. | Not applicable (comparison). | Not applicable (no effect). |
Study Details
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Sample Size used for the test set and the data provenance:
- Test Set Sample Size:
- Enrolled/Randomized (ITT): 1,332 subjects
- Per-Protocol (PP) Population: 1,149 subjects
- Interim Analysis (PP population with embryo transfer & Day 7 data): 301 women
- Final PP population (Primary Endpoint): The 23.5% vs 20.0% is based on the PP population, which was 1,149 subjects.
- Subgroup (Previous Miscarriage): 289 patients with embryo transfer.
- Total Babies Born: 369
- Data Provenance: Multicenter, randomized, parallel group, double-blind, placebo-controlled clinical study. Follow-up data was retrieved from the Danish National Board of Health Register (93%) and supplemented by patient/couple questionnaires (7% for birth data). This indicates a prospective study primarily conducted in Denmark (given the mention of the Danish National Board of Health Register) across 14 study centers.
- Test Set Sample Size:
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- The document does not specify the number or qualifications of experts used to establish "ground truth" for the test set.
- The primary endpoint (ongoing implantation rate at gestational week 7) was evaluated by ultrasound scan. Secondary endpoints (embryo quantity/quality) were judged against predefined classification. Follow-up for live birth and health characteristics relied on national registries and questionnaires.
- While medical professionals (e.g., sonographers, clinicians, embryologists) would have been involved in data collection, their specific roles in establishing a "ground truth" for the study endpoints (beyond standard medical practice) are not detailed.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- The document does not explicitly describe an adjudication method (like 2+1 or 3+1).
- The double-blind, placebo-controlled, multicenter design suggests efforts to minimize bias. The use of national registries for a large portion of follow-up data implies a standardized, albeit external, source of truth rather than a specific internal adjudication process for every case.
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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, a MRMC comparative effectiveness study was not done. This study is evaluating a medical device (culture medium), not an AI or imaging diagnostic tool. Therefore, the concept of "human readers improve with AI" is not applicable here.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No, this is not an AI-driven device. It's a culture medium. The concept of "standalone algorithm" is not applicable.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for the primary and secondary endpoints consisted of clinical outcomes data and standard clinical assessments:
- Ongoing implantation rate: Evaluated by ultrasound scan.
- Live Birth: Confirmed through the Danish National Board of Health Register and patient/couple questionnaires.
- Abnormalities/Malfunctions: Retrieved from the Danish National Board of Health Register and questionnaires.
- Embryo quantity and quality parameters: Judged against predefined classifications, likely by embryologists.
- The "ground truth" for the primary and secondary endpoints consisted of clinical outcomes data and standard clinical assessments:
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The sample size for the training set:
- Not applicable. This study is a clinical trial for a medical culture medium, not a machine learning model. There is no concept of a "training set" in this context.
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How the ground truth for the training set was established:
- Not applicable. As a clinical trial for a culture medium, there is no training set or ground truth establishment method for such a set.
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