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510(k) Data Aggregation
(113 days)
PJB
Genesis MNS is intended to navigate compatible magnetic devices through tissue to designated target sites in the right and left heart and coronary vasculature, neurovascular and peripheral vasculature by orienting the device tip in a desired direction.
The Cardiodrive® Catheter Advancement System (CAS) is intended to automatically advance and retract compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart when used in conjunction with a Stereotaxis MNS.
The Cardiodrive® system is not intended to advance the EP mapping and ablation catheters through the coronary vasculature or the coronary sinus.
The Cardiodrive® system is not intended to advance or retract non-compatible catheters and/or other non-compatible devices into the neurovasculature.
Stereotaxis Genesis RMN® with Navigant™ Workstation (NWS) and Cardiodrive® System (Genesis MNS) is an interventional workstation for the intravascular navigation of appropriately equipped, magnetically adapted, devices (e.g., catheters or guidewires) through tissue to designated target sites using computer-controlled permanent magnets to orient or steer the tip of a magnetic device and remotely advance and retract only compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart. Genesis MNS incorporates software that determines the direction the magnetic field should be applied based on physician interaction with the user interface devices.
Here's a summary of the acceptance criteria and study information for the Stereotaxis Genesis RMN with Navigant Workstation (NWS) and Cardiodrive System (Genesis MNS) based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Special Control) | How Special Control Has Been Met (Reported Performance) |
---|---|
Non-clinical mechanical performance testing (without catheter connected): | Magnetic field performance testing (robotic field accuracy survey, reduced field mode angular resolution, isocenter offset) demonstrated that field characteristics (strength, direction, position, accuracy) meet the same requirements as the predicate Niobe, and these tests passed. |
Non-clinical mechanical performance testing (with compatible catheters connected): | Deflection testing, accuracy testing with target phantom, and anatomical position testing with a plastic heart model were performed. Subject Genesis system performed at the same level with compatible devices as predicate Niobe System. |
(A) Side-by-side remote control and manual comparisons of catheter manipulation: | The subject Genesis system performed at the same level with compatible devices as the predicate Niobe System. The subject device generates the same magnetic fields as the predicate device. Compatible catheter performance testing results identical to Niobe. |
(B) Evaluation of accuracy and function of all device control safety features: | Testing of four primary safety controls (physical movement of magnet positioners, movement of covers toward patient, continuous advancement of catheter, motion e-stops) was conducted on the proposed device, and all passed. User testing of safety controls was the same between Niobe and Genesis. |
Simulated-use testing in a bench anatomic model or animal model: | Validation testing included use testing of clinical workflows in a bench model. An animal study was performed employing typical clinical workflows (compatibility with mapping system, CardioDrive, fluoroscopy). Clinical workflow testing for Genesis with compatible devices was the same as Niobe, substantiating substantial equivalence. |
Non-clinical electrical testing (EMC, electrical safety, thermal safety, electrical system performance): | EMC and Electrical safety testing showing conformance with IEC 60601 were performed by TuV for the reference Niobe device. EMC testing for the proposed device hardware demonstrating conformance with IEC 60601-1-2 was performed by Intertek, and all tests passed. Electrical safety testing on the proposed device demonstrating compliance with IEC 60601, and IEC 60601-1-2 was performed by Intertek. |
(A) Electrical performance of system with compatible catheters connected (Side-by-side remote control and manual comparisons of catheter manipulation): | Both predicate and proposed devices tested according to IEC 60601-1-2 standards by Nationally Recognized Testing Labs; all tests passed. |
(B) Evaluation of accuracy and function of all device control safety features: | Electrical safety testing on the proposed device demonstrating compliance with IEC 60601, and IEC 60601-1-2 was performed by Intertek. |
Electrical safety between device and ablation catheter system and with other electrical equipment: | Proposed system tested for compatibility with specific x-ray, ablation generators, and mapping systems. Electrical isolation and emissions testing performed by Intertek. |
In vivo testing (Manipulation and Positioning): | Animal study conducted with compatible devices showed that catheters were directed to predefined targets, and suitable contact was demonstrated. In vivo testing was conducted with the subject device, and all compatible catheters functioned similarly to the predicate device. |
In vivo testing (Safety - device-related and major procedural complication rate): | 7 Day Major Complication Rate: |
- ATTRAC: 7/182 (3.8%)
- ATTRAC II: 1/80 (1.3%)
- HEART Study: 7/129 (5.4%)
- VERSATILE: 5/120 (4.2%)
- Total: 20/511 (3.9%) |
| In vivo testing (Efficacy - ablation success): | Acute Success RMN: - ATTRAC: 175/182 (96.2%)
- ATTRAC II: 71/75 (94.7%)
- HEART Study: 108/121 (89.3%)
- VERSATILE: 119/120 (99.2%)
- Total: 473/498 (95.0%)
90 day success RMN: - ATTRAC: 145/147 (98.6%)
- ATTRAC II: 51/54 (94.4%)
- HEART Study: 82/87 (94.3%)
- VERSATILE: Not reported
- Total: 278/288 (96.5%) |
| User assessment of device remote controls and safety features: | Same user assessment testing (device remote controls and safety features) as the predicate device was performed, and all safety features passed. |
| Sterility of sterile disposable components: | Genesis System is not provided in sterile form. CardioDrive includes single-use disposable (QuikCAS) which underwent sterilization testing, resulting in a PASS. |
| Shelf life of sterile disposable components: | Genesis System is not provided in sterile form. CardioDrive's single-use disposable (QuikCAS) underwent shelf-life/packaging and sterilization testing. All testing resulted in a PASS, and each component was validated for a shelf life of 3 years. |
2. Sample Size Used for the Test Set and Data Provenance
The "test set" for clinical performance appears to be a collection of existing clinical studies that used the predicate device (Niobe MNS) and compatible components.
- Sample Size: A total of 511 patients were enrolled across 4 studies.
- Data Provenance: Clinical data from retrospective analyses of previously submitted studies to the FDA. These studies were sponsored by Stereotaxis. The specific countries of origin are not explicitly stated within the provided text, but these were part of FDA submissions (P050029, K071029, K140804) suggesting they are likely from clinical trials conducted in regions that align with FDA regulatory standards (e.g., US or international sites that adhere to similar clinical trial practices).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document does not specify the number of experts used to establish the ground truth for the clinical outcomes (adverse events, acute success, 90-day success) in these studies, nor their specific qualifications. It mentions that "Clinical data to support the safety of the Magnetic Navigation System... was reviewed" and that "The DSM adjudicated these events to be possibly and probably related to the procedure, respectively" in the VERSATILE study. This suggests that a Data Safety Monitoring board or similar expert body was involved in reviewing adverse events.
4. Adjudication Method for the Test Set
For the VERSATILE study, adverse events were "adjudicated" by the DSM (Data Safety Monitoring board). The specific adjudication method (e.g., 2+1, 3+1) is not detailed, but it indicates an expert review process.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No MRMC comparative effectiveness study is mentioned in the document. The comparative effectiveness assessment for the Genesis MNS is primarily against its predicate device (Niobe MNS) and historical clinical data for both the MNS system and manual ablation.
- Effect Size of Human Readers Improvement with AI vs. Without AI Assistance: Not applicable, as this is a robotic navigation system, not an AI-assisted diagnostic or interpretative device that augments human readers. The clinical studies compare outcomes of the magnetic navigation system to historical data or literature on manual ablation. The document states:
- "More than 8,000 patients were reported in the literature using the MNS System with a major complication rate of 0.72% compared to a manual rate of 2.1%." (This implies a lower complication rate for MNS compared to manual.)
- "Acute success rates and long-term success rates were similar in both the MNS and manual groups."
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
The device itself is a "Steerable Cardiac Ablation Catheter Remote Control System" and "Magnetic Navigation System," which is inherently designed for human-in-the-loop operation (a physician interacts with the user interface to control the magnetic field and system). Therefore, a standalone (algorithm only) performance study of the entire system as a diagnostic or interventional tool would not be relevant. The performance data presented focuses on the mechanical and electrical performance of the system and its clinical outcomes when used by an operator.
7. The Type of Ground Truth Used
The ground truth used for the clinical performance assessment consists primarily of:
- Clinical Outcomes Data: Major complication rates, acute success rates, and 90-day success rates, as recorded and adjudicated in the patient studies (ATTRAC, ATTRAC II, HEART, VERSATILE). These outcomes intrinsically serve as the "ground truth" for safety and efficacy in a clinical setting.
8. The Sample Size for the Training Set
The document does not explicitly mention a "training set" in the context of machine learning or AI. This device is a robotic system, and its development would typically involve engineering design, bench testing, and clinical validation rather than a distinct machine learning training phase. The "data" used for demonstrating its safety and effectiveness are the results from the various tests (mechanical, electrical, animal, and clinical studies of the predicate device).
9. How the Ground Truth for the Training Set Was Established
As there is no explicitly defined "training set" in the context of AI/ML, this question doesn't directly apply. The establishment of "ground truth" related to the device's design and operation would have been through engineering specifications, physics principles governing magnetic fields, and established clinical endpoints for cardiac ablation procedures (e.g., successful ablation, absence of major complications).
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(30 days)
PJB
The Niobe System is intended to navigate compatible magnetic devices through tissue to designated target sites in the right and left heart and coronary vascular and peripheral vasculature by orienting the device tip in a desired direction.
The Cardiodrive Catheter Advancement System (CAS) is intended to automatically advance and retract compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart when used in conjunction with a Stereotaxis MNS.
The Cardiodrive system is not intended to advance the EP mapping and ablation catheters through the coronary vasculature or the coronary sinus.
The Cardiodrive system is not intended to advance or retract non-compatible catheters and/or other non-compatible devices into the neurovasculature.
The Stereotaxis Niobe Magnetic Navigation System (MNS) with Navigant Workstation (NWS) and Cardiodrive (a.k.a. the Niobe System) is an interventional workstation for the intravascular navigation of appropriately equipped. magnetically adapted, devices (e.g., catheters or guidewires) through tissue to designated target sites. The Niobe System uses computer-controlled permanent magnets for orientating the tip of a magnetic device and employs magnetic fields only to orient or steer the tip of a magnetic device and remotely advance and retract only compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart. The Niobe System incorporates software that determines the direction the magnetic field should be applied based on physician interaction with the user interface devices.
This FDA 510(k) clearance letter for the Stereotaxis Niobe Magnetic Navigation System (MNS) with Navigant Workstation (NWS) and Cardiodrive (K192775) primarily references existing data from prior submissions and does not detail a new standalone clinical study. The submission relates to software modifications to an already cleared device, thus "special controls" testing and leveraging existing clinical data were used to demonstrate continued safety and effectiveness.
Here’s a breakdown of the acceptance criteria and the study information as presented in the document:
1. Table of Acceptance Criteria and Reported Device Performance
The document frames its "acceptance criteria" through how the device addresses a set of "Special Controls" established by the FDA for this class of device. The response to each control serves as the demonstration of meeting the criteria.
Special Control (Acceptance Criteria) | How Special Control Has Been Met (Reported Device Performance) |
---|---|
1) Non-clinical mechanical performance testing must demonstrate that the device performs as intended under anticipated conditions of use. Includes: | Magnetic field performance testing: Uses a THM-7025 Hall Effect tesla meter to measure applied field strength and accuracy in cardinal directions (at 0.08T and 0.1T - worst-case). |
Manual Control Performance Testing (leveraged from predicate): Deflection testing, accuracy with target phantom, anatomical position testing with plastic heart model. Results provide mechanical performance for reference device. | |
Remote Control Performance Testing (proposed device): Demonstrates equivalent mechanical performance between subject and reference device. | |
Evaluation of accuracy/function of safety features: Testing of four primary safety controls related to physical motion (magnet positioners, cover movement, continuous catheter advancement, e-stops). All passed. | |
Simulated-use testing: Four non-GLP animal validation studies performed using iterations of software after the reference device was cleared, testing features like sheath visualization, zone mapping, Auto NaviLine, single step NaviLine, targeting, point and line ablation, and integration of Acutus AcQMap system. | |
2) Non-clinical electrical testing must include validation of electromagnetic compatibility (EMC), electrical safety, thermal safety, and electrical system performance. | EMC and Electrical safety testing: Conformance with IEC 60601 performed by TuV for the reference device and the proposed device. All tests passed. |
Electrical safety between device/ablation catheter system and other electrical equipment: Tested for compatibility with specific X-ray, ablation generators, mapping systems. Electrical isolation and emissions testing performed by TuV. All tests passed. | |
3) In vivo testing must demonstrate that the device performs as intended under anticipated conditions of use, including an assessment of the system impact on the functionality and performance of compatible catheters, and documentation of the adverse event profile associated with clinical use. Includes: | i. Manipulation and Positioning: The VERSATILE Study (K141530) and in vivo animal testing (K071029 for Cardiodrive) demonstrated ability to manipulate compatible catheters to pre-specified cardiac locations. |
ii. Safety: Clinical data from four Stereotaxis-sponsored studies (ATTRAC, ATTRAC II, HEART, VERSATILE) totaling 511 patients reviewed. Overall 7-day major complication rate was 20/511 (3.9%). Specific adverse events reported (cardiac tamponade, thrombi, groin complication, etc.). | |
iii. Efficacy: Data from the same four studies (ATTRAC, ATTRAC II, HEART, VERSATILE) reviewed. Acute success rates: 473/498 (95.0%). 90-day success rates: 278/288 (96.5%). | |
iv. User assessment of device remote controls and safety features: Performance impressions documented on physician feedback forms during evaluations for Navistar RMT, Celsius RMT, and Helios II. Documentation included in reports. | |
4) Post-market surveillance (PMS) must be conducted and completed in accordance with FDA agreed upon PMS protocol. | Not warranted due to extensive clinical data. Safety and efficacy monitored through literature and PMS program. Major adverse event rate in submitted studies: 3.9%. Major complication rate in literature (>8,000 patients): 0.72% (vs. 2.1% manual). Acute and long-term success rates similar to manual. |
5) A training program must be included with sufficient educational elements for safe use. | Company representatives train physicians and staff. Niobe ES User's Manual provides detailed operating instructions. Information reviewed during simulation and phantom training. |
6) Performance data must demonstrate sterility of the sterile disposable components of the system. | Niobe System is not sterile and has no sterile disposable components. Cardiodrive includes a single-use disposable (QuikCAS) which underwent sterilization testing and passed. |
7) Performance data must support shelf life by demonstrating continued sterility, package integrity, and device functionality over the requested shelf life. | Niobe System is not sterile, so shelf life for sterility is not applicable. QuikCAS disposable underwent shelf-life/packaging and sterilization testing, passing all with a validated 3-year shelf life. |
8) Labeling must include appropriate instructions, warnings, cautions, limitations, and information. | Niobe ES User's Manual includes: Compatible Catheters, Indications for Use, Warnings, Safety Controls. Instructions for assembly (catheter-CAS interface), modes/states, controls/inputs/outputs, safety features. Cleaning instructions for non-reusable magnet pods included. Detailed summaries of mechanical compatibility testing (compatible catheters listed with pass/fail results) and in vivo testing (compatible catheters listed, adverse events, study outcomes, fluoroscopy times). |
2. Sample Sizes Used for the Test Set and Data Provenance
The document does not describe a novel "test set" in the context of typical AI/ML validation studies (i.e., a dedicated, novel set of cases exclusively for the purpose of algorithm validation). Instead, it relies heavily on retrospective clinical data from previously submitted studies and non-clinical engineering tests to demonstrate substantial equivalence for software modifications.
- Clinical Data (leveraged from prior submissions):
- Total Patients: 511 patients (across 4 studies: ATTRAC, ATTRAC II, HEART Study, VERSATILE)
- Attrition Data within Studies:
- ATTRAC: 182 enrolled patients, 175/182 for acute success, 145/147 for 90-day success.
- ATTRAC II: 80 enrolled patients, 71/75 for acute success, 51/54 for 90-day success.
- HEART Study: 129 enrolled patients, 108/121 for acute success, 82/87 for 90-day success.
- VERSATILE: 120 enrolled patients, 119/120 for acute success, "Not reported" for 90-day success.
- Data Provenance: The studies were Stereotaxis-sponsored clinical trials, previously submitted to the FDA for other clearances (P050029, K071029, K140804). The country of origin for these studies is not specified in this document. These are prospective studies given the "enrolled patients" context and "7-day major complication rate".
- Non-Clinical Data (specific to this submission):
- Software Verification and Validation: This involved internal testing by Stereotaxis under design controls. No specific "sample size" of software test cases is provided but it implies thorough testing.
- Animal Studies: Four non-GLP animal validation studies were conducted. The number of animals is not specified, but these are prospective studies to validate specific software features and integration.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
Not applicable in the traditional sense of image-based AI ground truth. The "ground truth" for the clinical efficacy and safety data primarily comes from the patient outcomes and procedural data recorded during the clinical trials themselves, which would be managed by the clinical investigators (physicians) and study staff.
For user assessment of device remote controls and safety features, it mentions "physician feedback forms." This implies physicians were the "experts," but the number and their specific qualifications are not detailed.
4. Adjudication Method for the Test Set
For the clinical studies, adverse events were generally reported and reviewed, and in the VERSATILE Study, it explicitly states that the "DSM adjudicated these events to be possibly and probably related to the procedure, respectively." DSM typically refers to a Data Safety Monitoring Board, which is an independent committee of experts (e.g., clinicians, biostatisticians) that monitors patient safety and treatment efficacy data during clinical trials. This suggests an adjudication method, at least for some adverse events.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size of AI vs. Without AI Assistance
No MRMC study is mentioned. This submission is for a device that assists with navigation, not for an AI that interprets images or diagnoses conditions in a way that would typically involve multiple readers assessing cases. The device itself is the "AI" (automated navigation based on software). Comparative effectiveness is primarily drawn from historical controls or comparisons to manual procedures mentioned in the PMS section (e.g., complication rates vs. manual rates).
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
The device is a "Steerable Cardiac Ablation Catheter Remote Control System." Its core function is to automate or assist in catheter navigation, inherently requiring a human operator (physician) to interact with the system. Therefore, a standalone (algorithm only) performance study without human-in-the-loop is not directly relevant or performed for the primary function of controlling the catheter. However, the mechanical and electrical performance tests (Special Controls 1 & 2) represent isolated system performance without a human in the loop, validating individual components of the system.
7. The Type of Ground Truth Used
- Clinical Studies: Patient outcomes (acute success, 90-day success, complication rates) serve as the ground truth for safety and efficacy. This is primarily outcomes data, determined by clinical follow-up and assessments from physicians.
- Non-Clinical Studies: Ground truth for mechanical and electrical performance is established via measurement against engineering specifications and validated standards (e.g., THM-7025 Hall Effect tesla meter, IEC 60601 conformance).
- Animal Studies: The success of specific software features in animal models (e.g., successful targeting, ablation) serves as the ground truth. This is a form of experimental outcome data.
8. The Sample Size for the Training Set
This document does not describe the Niobe System as an AI/ML device in the modern sense (e.g., a deep learning model requiring a large training dataset of images or other raw data). The "software modifications" refer to updates to the control system. Therefore, there's no mention of a traditional "training set" size for an AI algorithm. The development of software would involve internal testing and validation, but not "training data" in the AI/ML context.
9. How the Ground Truth for the Training Set Was Established
As no specific AI/ML training set is described, this question is not applicable. The traditional software development and verification/validation processes would have established "ground truth" through requirements documentation, test specifications, and expected outputs.
Ask a specific question about this device
(309 days)
PJB
The Niobe System is intended to navigate compatible magnetic devices through tissue to designated target sites in the right and left heart and coronary vascular and peripheral vasculature by orienting the device tip in a desired direction.
The Cardiodrive Catheter Advancement System (CAS) is intended to automatically advance and retract compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart when used in conjunction with a Stereotaxis MNS.
The Cardiodrive system is not intended to advance the EP mapping and ablation catheters through the coronary vasculature or the coronary sinus.
The Cardiodrive system is not intended to advance or retract non-compatible catheters and/or other non-compatible devices into the neurovasculature.
The Stereotaxis Niobe Magnetic Navigation System (MNS) with Navigant Workstation (NWS) and Cardiodrive (a.k.a. the Niobe System) is an interventional workstation for the intravascular navigation of appropriately equipped, magnetically adapted, devices (e.g., catheters or guidewires) through tissue to designated target sites. The Niobe System uses computer-controlled permanent magnets for orientating the tip of a magnetic device and employs magnetic fields only to orient or steer the tip of a magnetic device and remotely advance and retract only compatible magnetic electrophysiology (EP) mapping and ablation catheters inside the patient's heart. The Niobe System incorporates software that determines the direction the magnetic field should be applied based on physician interaction with the user interface devices.
The provided text describes the acceptance criteria and the studies that demonstrate the Stereotaxis Niobe® Magnetic Navigation System (MNS) with Navigant™ Workstation (NWS) and Cardiodrive® meets these criteria. The information is extracted from a 510(k) premarket notification.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are derived from the "Special Controls" section, and the reported performance is from "How Special Control Has Been Met."
Acceptance Criteria (Special Control) | Reported Device Performance |
---|---|
1) Non-clinical mechanical performance testing: | |
i. Mechanical performance of the system (without catheter connected) | Magnetic field performance testing using a THM-7025 Hall Effect tesla meter measured applied field strength and accuracy in cardinal directions at 0.08T and 0.1T (worst-case positions). |
ii. Mechanical performance of the system with compatible catheters connected to verify no impact on catheter function/performance (side-by-side remote control and manual comparisons, all ranges of motion, worst-case; evaluation of accuracy/function of safety features) | Manual Control Performance Testing: Deflection testing, accuracy testing with target phantom, and anatomical position testing with a plastic heart model were performed for the reference Niobe device. |
Remote Control Performance Testing: The proposed device demonstrated equivalent mechanical performance to the reference device. | |
Safety Features: Testing of four primary safety controls (magnet positioner movement, cover movement toward patient, continuous catheter advancement, motion e-stops) was conducted on the proposed device, and "All four safety controls passed the test." | |
iii. Simulated-use testing in a bench anatomic model or animal model | Four non-GLP animal validation studies were conducted after the reference device was cleared to test software iterations (Navigant 4.4, 5.0.1, 5.0.2, 5.0.3) features like ablation lesion assessment, sheath visualization, zone mapping, NaviLine, targeting, and point/line ablation. |
2. Non-clinical electrical testing: | |
i. Electrical performance of the system with compatible catheters connected (Side-by-side remote control and manual comparisons, worst-case; evaluation of accuracy/function of safety features) | Manual Control Performance Testing: EMC and electrical safety testing confirming conformance with IEC 60601 were performed by TuV for the reference device. |
Remote Control Performance Testing: EMC testing for the proposed device hardware demonstrating conformance with IEC 60601 was performed by TuV. "All tests passed." | |
Safety Features: Electrical safety testing on the proposed device demonstrating compliance with IEC 60601 was performed by TuV. "All tests passed." | |
ii. Electrical safety between the device and ablation catheter system and with other electrical equipment in cath lab/OR | The proposed system has been tested for compatibility with specific x-ray, ablation generators, mapping systems. Electrical isolation and emissions testing have been performed by TuV. "All tests passed." |
3. In vivo testing: | |
i. Manipulation and Positioning: Ability to manipulate compatible catheters to pre-specified cardiac locations and conform proper anatomic placement and tissue contact | The VERSATILE Study (K141530) and in vivo animal testing (K071029 for Cardiodrive) demonstrated the ability to manipulate compatible catheters to pre-specified cardiac locations. |
ii. Safety: Assess device-related complication rate and major procedural complication rate vs. literature/manual comparison group | Clinical data from 4 Stereotaxis-sponsored studies (ATTRAC, ATTRAC II, HEART, VERSATILE) involving 511 patients using the Niobe System (MNS, Cardiodrive, Magnetic Ablation Catheter, Navigant Software) showed an overall 7-day Major Complication Rate of 3.9% (20/511). Individual study rates ranged from 1.3% to 5.4%. Complications included cardiac tamponade, new focal wall abnormality, change in LVEF, vena cava thrombi, groin complication, prolonged hospitalization, pseudoaneurysm, bleeding, anemia, dementia, pericardial effusion, heart block, pulmonary embolisms, AV fistula, and arrhythmia recurrence. Several events were adjudicated as possibly/probably related to the procedure, with some explicitly stated as non-device related. |
iii. Efficacy: Assess ablation success vs. literature/manual comparison group | Clinical data from the same 4 Stereotaxis-sponsored studies (ATTRAC, ATTRAC II, HEART, VERSATILE) involving 511 patients showed an overall Acute Success Rate of 95.0% (473/498) and a 90-day Success Rate of 96.5% (278/288). Individual study acute success rates ranged from 89.3% to 99.2%, and 90-day success rates from 94.3% to 98.6%. The VERSATILE study did not report 90-day success. |
iv. User assessment of device remote controls and safety features | Performance impressions were documented on physician feedback forms during evaluations for Navistar RMT, Celsius RMT, and Helios II, where the Navigant system was used to steer the catheter. |
4. Post-market surveillance (PMS) | "A post market surveillance study is not warranted." This is based on: |
- "Overwhelming evidence" from four submitted studies (3.9% major adverse event rate, 95.0% acute success, 96.5% 90-day success).
- More than 8,000 patients reported in literature using MNS with a major complication rate of 0.72% (compared to manual rate of 2.1%).
- Acute and long-term success rates were similar in MNS and manual groups in literature.
Stereotaxis proposes continued monitoring through literature and Post Marketing Surveillance program. |
| 5. Training program for clinical and supporting staff | Representatives from the company train physicians and staff. The Niobe ES User's Manual provides operating instructions. Information is reviewed during simulation sessions and phantom training with the actual system. |
| 6. Performance data for sterility of sterile disposable components | The Niobe System is not sterile and not required to be sterilized. The Cardiodrive includes a single-use disposable (QuikCAS) (sterile component). Sterilization testing for QuikCAS resulted in a PASS. |
| 7. Performance data for shelf life (sterility, package integrity, functionality) | The Niobe System is not sterile and thus shelf life for system components is not applicable. The Cardiodrive includes a single-use disposable (QuikCAS) (sterile component). Shelf-life/packaging and sterilization testing for QuikCAS resulted in a PASS, and each component was validated for a shelf life of 3 years. |
| 8. Labeling requirements (Instructions, warnings, cautions, limitations, training, compatibility, testing summaries, technical parameters, expiration) | The Niobe ES User's Manual includes compatible catheters, indications for use, warnings, and safety controls. It has instructions for procedure room components, system positions, table-side magnet controller, power up, cover force sensor, navigation position assistance, software info, Cardiodrive CAS user interface, and activation codes. It explicitly states the Niobe System doesn't have reusable components requiring reprocessing/disinfection. Cleaning instructions for magnet pods are provided. A list of compatible catheters (Biosense Webster Navistar RMT, Navistar RMT Thermocool, Celsius RMT, Celsius RMT Thermocool; Stereotaxis Helios II) and mechanical performance testing is included. Summaries of in vivo testing, adverse events, procedure-related complications, study outcomes, and endpoints are summarized. Fluoroscopy times are reported. Relevant warnings based on complaints and clinical studies have been included. The system generates a directional 0.08T or 0.1T magnetic field within a 6-inch diameter navigation volume. Not applicable for system expiration date/shelf life; for QuikCAS, it is 3 years. |
2. Sample Size Used for the Test Set and the Data Provenance
- Test Set (Clinical Data):
- Sample Size: A total of 511 patients across 4 clinical studies (ATTRAC, ATTRAC II, HEART Study, VERSATILE).
- Data Provenance: The data comes from Stereotaxis-sponsored clinical studies that were previously submitted to the FDA for other regulatory approvals (P050029, K071029, K140804). The location of these studies (e.g., country of origin) is not explicitly stated in the provided text.
- Retrospective/Prospective: All four studies were prospective in nature.
3. 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 of experts used to establish ground truth for the clinical outcomes (e.g., major complications, acute success, 90-day success).
- However, it does mention that:
- For the VERSATILE study, the DSM (Data Safety Monitoring) adjudicated these events (referring to cardiac tamponade events). This implies expert review of adverse events, but the number and qualifications of DSM members are not provided.
- Physician feedback forms were used for "User assessment of device remote controls and safety features," suggesting clinical expert input on device usability.
4. Adjudication Method for the Test Set
- For adverse events in the VERSATILE study, the DSM (Data Safety Monitoring) was involved in adjudication. The specific method (e.g., 2+1, 3+1) is not detailed.
- For other clinical endpoints like acute and 90-day success, the adjudication method is not described in detail, though it would typically involve clinical follow-up and determination by clinicians/investigators within the study protocols.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, What Was the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance
- The provided text describes a medical device (a robotic catheter navigation system), not an AI-powered diagnostic or interpretive tool. Therefore, the concept of a "multi-reader multi-case (MRMC) comparative effectiveness study" focusing on human readers improving with AI assistance is not applicable here. The device assists the physician in physically performing a procedure.
- The document does mention a comparison to "manual rates" for major complications and similar success rates in the literature between the MNS and manual groups, indicating some level of comparative safety and efficacy analysis against conventional methods. However, this is not an MRMC study comparing human reader performance with and without AI assistance for interpretation.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- This question is not applicable to this device. The Niobe System is an interventional workstation designed to be operated with a human-in-the-loop (a physician) to navigate catheters. It is not an algorithm performing a task independently.
7. The Type of Ground Truth Used
- Clinical Outcomes Data: For the in-vivo efficacy and safety studies, the ground truth was based on:
- Major Complication Rates: Clinically diagnosed complications within 7 days post-procedure.
- Ablation Success: Acute success (immediate outcome of the ablation procedure) and 90-day success (long-term absence of arrhythmia recurrence). These are definitive clinical endpoints.
- Manipulation and Positioning: Demonstrated ability to reach pre-specified cardiac locations and achieve proper anatomical placement.
- Bench Testing Data: For mechanical, electrical, and sterility testing, ground truth was established by:
- Measurements: Using instruments like a Hall Effect tesla meter for magnetic field strength.
- Conformance to Standards: Meeting established engineering and safety standards (e.g., IEC 60601-1, ISO 62304, ISO 14971).
- Pre-determined Requirements: The testing "demonstrated that the Niobe System met pre-determined requirements."
- Animal Model Data: For simulated-use testing, the animal studies likely provided physiological and anatomical ground truth for the performance of the system and software features.
8. The Sample Size for the Training Set
- The document refers to "software verification and validation activities" and "non-GLP animal validation studies" for specific software versions (Navigant 4.4, 5.0.1, 5.0.2, 5.0.3). These can be considered part of the development and testing process, but the document does not specify a distinct "training set" sample size in the context of an AI/machine learning model. The clinical studies (511 patients) would be considered the main validation or test set for clinical performance.
9. How the Ground Truth for the Training Set Was Established
- As mentioned above, the concept of a "training set" in the context of AI/machine learning is not directly applicable here. For the non-clinical and animal studies used in development and validation:
- Non-clinical (bench) testing: Ground truth was established through direct physical measurements, adherence to engineering specifications, and compliance with recognized standards.
- Animal Validation Studies: The ground truth would have been established through controlled experimental conditions, physiological measurements, and post-procedure analysis (e.g., ablation lesion assessment).
In summary, this submission focuses on a mechanical-robotic system, not an AI diagnostic, thus many aspects related to AI performance metrics are not applicable. The core of the evidence relies on thorough non-clinical engineering validation and prospective human clinical trials demonstrating safety and efficacy.
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The Amigo™ Remote Catheter System (RCS) is intended to facilitate manipulation, positioning and control of compatible percutaneous electrophysiological ablation catheters that deliver RF energy in the right atrium. Use of Amigo RCS should also be in accordance with the indications for use of compatible ablation catheters. The Amigo RCS should only be used with the Boston Scientific catheters (with the Blazer" " handle) and/or the Biosense Webster catheters (with the EZ Steer® handle) in the right atrium.
The Amigo™ Remote Catheter System (Amigo RCS) is designed to facilitate the manipulation, positioning and control of compatible cardiac electrophysiological catheters. It is designed to remotely control Boston Scientific catheters (with the Blazer™ handle) and Biosense Webster catheters (with the EZ STEER® handle).
The Amigo RCS consists of four (4) main reusable, non-sterile components including the remote catheter system (sled, track, and turret), a hard-wired remote control, 100 ft extension cable, and a bridge support with rail and frame. In addition, the Amigo RCS includes three (3) sterile, single-use disposable kits including the docking station and spreader) to interface with the compatible ablation catheter, and a sterile cover kit (sled cover, turret cover, nose sleeve and side covers) and track kit (track and nosecone) used to maintain a sterile field during device use. The Amigo RCS is intended to attach to the rails of an IEC 60601-1 compliant EP bed system.
The Amigo RCS only interfaces with the catheter's handle such that the Amigo RCS connects to and operates the manual handle of the compatible steerable cardiac ablation catheter to remotely control its advancement, retraction, rotation, and deflection.
Here's a breakdown of the acceptance criteria and the study details for the AMIGO REMOTE CATHETER SYSTEM based on the provided text:
Acceptance Criteria and Reported Device Performance
For non-clinical mechanical performance testing:
Acceptance Criteria | Reported Device Performance |
---|---|
(1) Ability to attach catheter handle and maintain mechanical attachment to docking station. | Not explicitly quantified, but included in "Mechanical testing included evaluation of the following acceptance criteria" and implied by successful animal study. |
(2) Deflection of the catheter with Amigo RCS is equivalent to manual deflection (less than or equal to 1° difference in catheter handle throw) over the range of functional clinical application. | Not explicitly quantified, but included in "Mechanical testing included evaluation of the following acceptance criteria." |
(3) Catheter and spreader remains in the track and the catheter extends, retracts, and rotates in both directions through the spreader and articulates correctly. | Not explicitly quantified, but included in "Mechanical testing included evaluation of the following acceptance criteria" and implied by successful animal study. |
(4) Improper configuration of Amigo RCS/docking station does not result in overstressing the catheter. | Not explicitly quantified, but included in "Mechanical testing included evaluation of the following acceptance criteria." |
Amigo RCS does not impact catheter function and performance (all ranges of motion of catheter, tip deflection, and mapping). | Achieved (demonstrated in animal study and mechanical performance testing). |
Accuracy and function of all device mechanical controls for proper tip placement within the chambers of the heart. | Achieved (evaluated in animal study). |
For non-clinical electrical performance testing:
Acceptance Criteria | Reported Device Performance |
---|---|
Amigo RCS does not impact catheter function and performance (all ranges of motion of catheter, tip defection, and mapping). | Achieved (demonstrated in animal study and mechanical performance testing). |
Accuracy and function of all device electrical controls for proper tip placement within the chambers of the heart. | Achieved (evaluated in animal study). |
For clinical performance (three prospective cohort studies):
Acceptance Criteria | Reported Device Performance |
---|---|
Safety: Device-related, serious AEs comparable to manual ablation. | No device-related, serious AEs reported. |
Safety: Major procedural complications comparable to literature/manual ablation. | Procedure-related major vascular access complication: 1/85 (1.2%). |
Efficacy: Acute procedural success. | 84/85 (98.8%) subjects achieved acute procedural success. |
Efficacy: Chronic success. | 62/63 (98.4%) of subjects achieved chronic success (at 6 or 12 months, depending on the study). |
Operator fluoroscopy time reduction. | Decreased by 71% for typical AFL ablation and by 81% for AVNRT ablation by using Amigo RCS compared with manual ablation. |
Procedural parameters (procedural time, total fluoroscopy time for patient) comparable to manual ablation. | Comparable in one study with a matched control group. |
Study Details
1. Sample Size and Data Provenance
- Clinical Studies:
- Sample Size: 85 patients in total across three clinical studies.
- Data Provenance: Not explicitly stated, but likely from the US where FDA approval is sought. The studies were described as "3-center study" and "single-center studies," implying medical centers where the procedures were performed. The studies were prospective.
- Non-Clinical (Animal) Study:
- Sample Size: Not specified.
- Data Provenance: Not specified, but generally conducted by the manufacturer or a contract research organization.
2. Number of Experts Used to Establish Ground Truth and Qualifications
- Clinical Studies:
- The document implies that acute procedural success and chronic success were assessed by the treating physicians and follow-up clinical assessments. There's no mention of a separate panel of experts establishing "ground truth" for the outcomes in the same way one might for diagnostic imaging interpretation. The outcomes (absence of arrhythmia recurrence, procedural success) are clinical endpoints based on established diagnostic criteria.
- Non-Clinical Studies:
- Not applicable in the same way as clinical or diagnostic studies. Performance was measured against engineering specifications and observed by testing personnel/engineers.
3. Adjudication Method
- Clinical Studies:
- No specific adjudication method (e.g., 2+1, 3+1) is mentioned for the clinical outcomes (acute/chronic success, adverse events). The text notes "limited rigor in adverse event detection, documentation and adjudication," suggesting that a highly structured adjudication process by independent experts may not have been a primary component of these studies.
- Non-Clinical Studies:
- Not applicable.
4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC study was not explicitly conducted for the Amigo RCS. The clinical studies compared Amigo RCS-controlled ablation to manual ablation, but largely focused on patient outcomes and operator fluoroscopy time. There is no mention of a "multi-reader multi-case" design typical for evaluating diagnostic performance where multiple readers interpret cases for a ground truth.
- Effect Size of Human Readers Improvement with AI vs Without AI Assistance: Not applicable, as this device is a robotic catheter control system, not an AI-assisted diagnostic tool for human readers. Its benefit to the human operator is reduced radiation exposure, not improved diagnostic accuracy.
5. Standalone Performance
- Yes, a standalone (algorithm only without human-in-the-loop performance) was done for the mechanical and electrical tests. The device's mechanical and electrical functionalities were tested independently and in conjunction with compatible catheters to ensure it met performance specifications. The "Amigo RCS does not impact catheter function and performance" and "Accuracy and function of all device electrical controls" were assessed in non-clinical settings.
6. Type of Ground Truth Used for Test Set
- Clinical Studies:
- Acute/Chronic success: Clinical endpoints (e.g., absence of arrhythmia recurrence based on follow-up evaluations using standard clinical diagnostic methods for arrhythmias).
- Adverse events: Clinical diagnosis and documentation of events by medical staff and follow-up.
- Non-Clinical Studies:
- Mechanical/Electrical Performance: Engineering specifications, measured physical parameters (e.g., 1° difference in catheter throw).
- Animal Studies: Observed functionality, performance, and tip placement in an in vivo model.
7. Sample Size for Training Set
- The document does not specify a separate "training set" sample size in the context of device development or machine learning. This is a robotic control system, not a machine learning model that is "trained" on data in the same way. The development and refinement of the system would have involved iterative design, bench testing, and animal studies, which are analogous to a development/validation process but not a "training set" in the common AI sense.
8. How Ground Truth for Training Set Was Established
- As above, the concept of a "training set" in the context of a machine learning model isn't directly applicable here. The "ground truth" during the development phase would have been established by engineering specifications, performance targets, and preclinical testing results informing the design and functionality of the robotic system.
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