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510(k) Data Aggregation
(29 days)
VariSeed is intended for use as a software application used by medical professionals to plan, guide, optimize, and document low dose rate brachytherapy and procedures based on template guided needle insertion.
VariSeed is indicated for use as a treatment planning software application used by medical professionals to plan, guide, optimize and document low-dose-rate brachytherapy procedures and for use as a biopsy procedure tracking software application used by medical professionals to plan, guide, and document biopsy procedures based on template guided needle insertion. VariSeed may be used on any patient considered suitable for this type of treatment and is intended to be used outside of the sterile field in an operating room environment or in a normal office environment.
VariSeed 10 is a free-standing PC based treatment planning software designed for preoperative and intraoperative planning of LDR implants, tracking of the implant procedure, and postoperative evaluation of completed implants. VariSeed also provides tools for supporting intraoperative template guided biopsy and using those results to guide future treatment.
The provided text is an FDA 510(k) clearance letter for Varian Medical Systems' VariSeed (v10) device. It states that the device is substantially equivalent to a legally marketed predicate device (VariSeed v9.0).
However, the core of your request is to describe the acceptance criteria and the study that proves the device meets those criteria, specifically concerning a study that evaluates device performance through quantitative measures, such as accuracy metrics, and details about the test set, expert involvement, and ground truth establishment.
The provided FDA letter explicitly states: "No clinical tests have been included in this pre-market submission." and "Verification testing was performed to demonstrate that the performance and functionality of the VariSeed v10 treatment planning software meets the design input requirements. Validation testing was performed on production equivalent devices, under clinically representative conditions and by qualified personnel."
This indicates that the clearance was based on non-clinical performance data and verification/validation testing against design requirements, rather than a clinical study evaluating the device's diagnostic performance (e.g., accuracy against ground truth in a clinical setting).
Therefore, I cannot provide the detailed information you requested about acceptance criteria and a study that proves the device meets the acceptance criteria in the context of clinical performance, sample sizes, expert involvement, or ground truth for a clinical test set, because such a study was not included in this submission as per the document.
The "acceptance criteria" referred to in the document are implicitly the design input requirements and the successful completion of verification and validation against those requirements.
Here's a breakdown of what can be inferred from the document and why most of your requested points cannot be answered:
1. A table of acceptance criteria and the reported device performance:
- Acceptance Criteria (Implied): The device meets its design input requirements and performs its intended functions (planning, guiding, optimizing, and documenting low dose rate brachytherapy and biopsy procedures, including support for PET and MR images).
- Reported Device Performance: "Verification testing was performed to demonstrate that the performance and functionality of the VariSeed v10 treatment planning software meets the design input requirements." And "Validation testing was performed on production equivalent devices, under clinically representative conditions and by qualified personnel."
- Quantitative Metrics: The document does not provide specific quantitative performance metrics (e.g., accuracy, sensitivity, specificity, or error margins) often seen in studies evaluating AI or diagnostic devices. This implies the focus was on functional verification and validation against engineering specifications, not clinical outcomes or diagnostic accuracy.
2. Sample size used for the test set and the data provenance:
- Not specified. Since no clinical tests were included, there is no information about a "test set" in the context of clinical data. The validation was likely performed on synthetic, phantom, or previously acquired (non-patient-identifiable) data to test software functionality and accuracy of calculations, rather than on a true patient "test set" for clinical performance evaluation.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. No clinical ground truth establishment process is described given the lack of clinical study data.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable.
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:
- No. The document explicitly states "No clinical tests have been included in this pre-market submission." Therefore, no MRMC study or AI assistance evaluation was performed as part of this submission. The device is described as "treatment planning software," not an AI-driven diagnostic assistance tool in the way you might expect. The "AI" implied in your question (human readers improving with AI assistance) is not detailed or alluded to in this context.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The software itself operates "stand-alone" in the sense that it performs its calculations and functions without constant human input for each step once initiated. However, its intended use is "by medical professionals to plan, guide, optimize, and document," implying it's a tool used by a human, not a fully autonomous diagnostic device. The document does not describe "algorithm only" performance in the context of clinical decision-making or diagnosis.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not specified. For internal verification and validation of a treatment planning system, ground truth would typically refer to known geometric properties of phantoms, known dose distributions from physical measurements, or validated computational models. It would not typically involve pathology or outcomes data for this type of software clearance.
8. The sample size for the training set:
- Not applicable. This section does not describe an AI/ML device that requires a distinct "training set" for model development. It's a software application following a traditional software development lifecycle, not a deep learning model requiring vast amounts of labeled training data.
9. How the ground truth for the training set was established:
- Not applicable.
In summary, the FDA clearance for VariSeed (v10) was based on its substantial equivalence to its predicate device (VariSeed v9.0) and on "non-clinical data," specifically "verification and validation" against "design input requirements" under "clinically representative conditions." It was not based on a clinical study demonstrating performance against a diagnostic ground truth with human experts and patient data.
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