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510(k) Data Aggregation

    K Number
    K190047
    Manufacturer
    Date Cleared
    2019-10-31

    (295 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K904409/A, K920567, K982902, K000852

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.

    Device Description

    The StimRouter Neuromodulation System consists of two main parts - the implantable lead, and the external (to the body) accessories for the StimRouter include a clinician programmer with software (CPS), a patient programmer, disposable hydrogel electrode patch, external pulse transmitter (EPT), and an EPT stimulation tester (EPTT).

    The Bioness StimRouter Neuromodulation System is intended to provide electrical stimulation via an implanted lead to a target peripheral nerve, for aid in the management of severe, intractable, chronic pain of peripheral nerve origin in adults, as an adjunct to other modes of therapy (e.g. medications). The StimRouter is not intended to treat pain in the craniofacial region.

    The complete StimRouter System consists of three kits: A Lead and Lead Introducer Kit, a Clinician Kit and User Kit. The Lead Kit contains the StimRouter implantable multielectrode lead with integrated receiver, used for peripheral nerve stimulation. The Lead receives an electrical signal transmitted transcutaneously by the EPT which is mounted on an electrode patch on the skin and delivers that electrical signal down the lead's length to a target peripheral nerve. The Lead is supplied in Lead Loader that is used during intraoperative testing of the lead and to verify proper placement during implantation.

    The Lead and lead Introducer Kit consists of two stimulation probes, two stimulation cables, and introducer set, a lead adapter, a Tunneling Needle and a Tunneling Needle Stylet. The included tools and components allow for insertion of the StimRouter Lead and confirmation of optimal location of the stimulation electrode contacts of the StimRouter Lead.

    The Clinician Kit is used for the programming of the StimRouter patient programmer and the EPT. The components of the Clinician Kit are a tablet PC with programming software and the accessories for connecting to the Patient Programmer and the EPT.

    The User Kit contains the patient-use components of the StimRouter System. The components are the Patient Programmer and the EPT. After the EPT is programmed, the StimRouter electrode interfaces with the EPT and function to delivery stimulation to the implanted lead receiver.

    AI/ML Overview

    This document is a 510(k) Premarket Notification from Bioness Inc. for their StimRouter Neuromodulation System. It's a submission to the FDA requesting clearance to market a modified version of an already cleared device. Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are focused on demonstrating substantial equivalence to a predicate device, rather than proving clinical efficacy from scratch as one might for a novel AI device or drug.

    Based on the provided text, the device is a neuromodulation system for pain management, not an AI/ML diagnostic tool. Therefore, the questions related to AI/ML specific criteria (number of experts, MRMC studies, ground truth for training/test sets, effect size of human readers with/without AI, standalone performance) are not directly applicable.

    However, I can extract information related to the device's technical specifications and the testing performed to demonstrate its safety and effectiveness, which are the "acceptance criteria" in the context of a 510(k) submission for a medical device modification.


    Device: StimRouter Neuromodulation System (modified version)

    Type of Submission: 510(k) Premarket Notification for a modification to a previously cleared device (K142432).

    Key Goal of the Study: To demonstrate substantial equivalence of the modified StimRouter Neuromodulation System to its predicate device (original StimRouter, K142432) in terms of safety and effectiveness. This is achieved by showing that the modifications do not raise new questions of safety or effectiveness and that the device performs as intended.


    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implicitly defined by the safety and performance standards expected for an implanted peripheral nerve stimulator and the comparison to the predicate device. The "reported device performance" is demonstrated through various verification and validation activities and comparison of technical characteristics.

    Acceptance Criteria (Implicit from 510(k) Process)Reported Device Performance (as demonstrated by comparison and testing)
    Functional Equivalence to Predicate DeviceMost technical characteristics are "Same" as the predicate (e.g., intended use, manufacturer, lead design, number of electrodes, electrode shape, materials, lead length, body diameter, implantation method, stimulation probe, cables, introducer set, lead adaptor, gel electrodes, EPT power source, EPT location, EPT communication, EPT pulse frequency, EPT pulse width, waveform, stimulation modality, patient programmer programs, patient selectable programs, programmer communication, software driven, multiple stim modes, GUI, StimRouter Electrodes)
    Safety of Modified Components/Parameters:
    - Packaging (consolidation of kits, material change)Similar; New packaging is consolidation; PETE (new material) confirmed equivalent through qualification, has better impact resistance than PETG (old material).
    - Tray Lid AdhesiveSimilar; New adhesive confirmed equivalent through qualification.
    - Increased Maximum Charge per Pulse (Lead) & Maximum Charge Density (Lead)Similar; Safety maintained because of limits on max current (30mA) and max pulse duration (500µsec). Values are lower than other similar devices and comply with safety requirements. Detailed comparison table shows values are within safe ranges of reference predicate devices (Medtronic PNS, Renew System).
    - Tunneling Needle Material (removal of nickel plating)Similar; Safety maintained; Nickel was previously used for soldering ease, but adequate soldering without nickel was confirmed by the vendor for the subject device. Addresses nickel allergy warning.
    - Clinician's Programmer Hardware (new off-the-shelf tablet)Similar; Physically larger but runs substantially equivalent software (recompiled).
    - Clinician Programmer Operating System (Windows Mobile 5 to Windows 10 Home)Similar; Same code can run in Windows 10 Home.
    - Clinician Programmer GUI (adjusted to fit larger screen)Similar; Same GUI contents.
    - Added Stimulation Frequencies (12, 15 Hz)Similar; New frequencies are within the original stimulation range.
    - Patient Log Export Function (software enhancement)Similar; Minor change that just adds a function.
    - Miscellaneous Clinician Software Enhancements (obsolete buffering, co-installation)Similar; Minor enhancements to code that do not change function.
    - Ramp Down Feature (EPT)Similar; Provides smooth transition for patient comfort. Expected to have same paresthesia effect.
    - Maximum Compliance Voltage (EPT: 90V to 100V)Similar; Safety maintained because of limits on max current (30mA) and max EPT external temperature (41°C). Aims to treat patients with high skin impedance or requiring higher current.
    - Charge per Phase Limit (EPT: 10 µC to 15 µC due to rechargeable batteries)Similar; Safety maintained because of limits on max current (30mA) and max pulse duration (500µsec). The previous 10 µC limit was due to non-rechargeable battery needs, which are no longer supported.
    - Miscellaneous EPT Software Enhancements (transistor disconnection, impedance)Similar; Updates provide better detection of conditions and unnecessary termination of stimulation.
    - Miscellaneous Patient Programmer Software Enhancements (interfering EPTs, buggy RF channels)Similar; Software updates improve reliability of connection with EPT.
    Verification & Validation Testing ComplianceRisk Analysis methods were used to assess impact of modifications and determine required V&V activities. Extensive bench tests were conducted, including: Bioburden, Sterilization & Shelf-life, Biocompatibility, Shelf Life, Shipping Validation, Package Integrity (Bubble Leak, Seal Strength), Functional V&V, Label Validation, Printing Verification, MRI Compatibility, Implant Heating, and Software V&V Testing.

    2. Sample Size Used for the Test Set and the Data Provenance:

    • Sample Size: Not explicitly stated as a number of devices/patients for a clinical trial. For a 510(k) modification where substantial equivalence is demonstrated through bench testing and comparison, the "sample size" refers to the number of units tested for each specific bench test (e.g., a certain number of devices for shelf-life testing, a certain number for functional testing). These specific numbers are not provided in this summary.
    • Data Provenance: The document does not specify a country of origin for any human data (as no clinical trial data is summarized). The data primarily comes from bench testing and technical comparisons against historical predicate device data and reference devices. The submission indicates that these tests were "originally developed under the design control process of the StimRouter Neuromodulation System cleared in K142432," suggesting these are in-house engineering and lab tests. The nature of the submission (Special 510(k)) indicates that new clinical data is generally not required if performance is demonstrated through other means.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:

    • This is not applicable as the submission relates to a physical medical device modification, not an AI/ML algorithm requiring expert annotation for ground truth. Ground truth for device performance is established through engineering specifications, material science, and safety standards, not subjective expert assessment of images or clinical outcomes in the same way as an AI diagnostic.

    4. Adjudication Method for the Test Set:

    • Not applicable for a device modification validated through bench testing and technical comparison. Clinical study adjudication methods (e.g., 2+1, 3+1) are for human-in-the-loop diagnostic studies or clinical outcome studies.

    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:

    • Not applicable. This is a medical device (neuromodulation system) and not an AI-assisted diagnostic tool. No MRMC study was conducted or required for this type of submission.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    • Not applicable. This is not an AI algorithm. Its "standalone performance" is related to its physical and functional operation as a stimulator, which is evaluated through the listed bench tests.

    7. The Type of Ground Truth Used:

    • The "ground truth" for this submission are the performance specifications, safety limits (e.g., charge density, current limits), and accepted medical device standards (e.g., biocompatibility standards, sterilization standards, electrical safety standards).
    • For the comparative analysis, the performance characteristics of the cleared predicate device (K142432) and other reference devices (Medtronic PNS, Renew System) serve as the "ground truth" or benchmark for substantial equivalence.

    8. The Sample Size for the Training Set:

    • Not applicable. This is not an AI/ML algorithm requiring a training set.

    9. How the Ground Truth for the Training Set Was Established:

    • Not applicable.
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    Why did this record match?
    Reference Devices :

    K152178, K934065, K883780, K000852

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The trial devices are solely used for trial stimulation (no longer thank 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System (also referred to as the "Nalu System") is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Nalu Neurostimulation system incorporates a miniature implanted neurostimulator, powered by an externally worn Therapy Disc device. Similar to the predicate StimQ, the Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on the peripheral nerves to inhibit the transmission of pain signals to the brain. The Nalu System may be implanted following a successful trial period using the Nalu Neurostimulation trial system.

    The Nalu Neurostimulation System is comprised of 5 elements:

    1. Nalu Implantable Pulse Generator: The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads to the desired peripheral nerve. The IPG is available in two different implant architectures: an “integrated" system with pre-attached leads and a "ported" system where leads may be attached, via connector ports. In addition, both of these versions are available in single or dual lead configurations. The hermetic IPG housing includes a ceramic enclosure and a feedthrough connected internally to a printed circuit board assembly. Wires leaving the IPG are encapsulated in polyurethane and a silicone over mold forms the final biocompatible surface of the IPG for direct patient tissue contact.
    2. Leads: Leads are implantable and are designed to deliver electrical pulses to the peripheral nerve via an array of eight cylindrical electrodes at the distal end. Leads may be integrated with or connected to the IPG. Both Trial and Permanent Implant leads are available for use. The leads use polyurethane insulation with Pt/Ir electrodes. The leads may be secured in place with the Nalu Lead Anchor.
    3. Surgical and Trial Tools: Implantation of the Nalu IPG and lead components for Peripheral Nerve Stimulation (PNS) is performed via standard PNS surgical techniques. The desired implant location is accessed via needle placement, followed by lead placement through an introducer. The leads are anchored and the IPG is placed in a subcutaneous pocket. Patient contacting materials include medical grade stainless steel, thermoplastic elastomers, ABS, silicone, and Urethane.
    4. Externally worn Therapy Discs: Two types of Therapy Disc are available. One is to be used during the trial phase (Trial Therapy Disc), and one is to be used after permanent IPG implantation (Therapy Disc). Both devices are worn by the patient using one of the Nalu-provided options The Therapy Discs house a rechargeable lithium ion battery, and electronics including a microcontroller running software for therapy control, patient interaction and communication with Nalu's Clinician Programmer and Remote Control devices. The Therapy Disc used to power and command the implant does so wirelessly using Radio Frequency (RF) and is held in place by an adhesive clip applied to the skin or a belt/cuff worn over clothing.
    5. Clinician Programmer and Remote Control: A Clinician Programmer Application is provided to configure the Trial Therapy Disc and Therapy Disc devices during surgery and programming. A Patient Remote Control Application is available to provide the patient with a convenient secondary option to control their system in addition to built-in controls on the Therapy Disc. The Clinician Programming Application runs on an Android tablet and communicates over a secure Bluetooth Low Energy link with the Trial Therapy Disc and Therapy Disc devices. The programmer is responsible for configuring the devices to deliver therapy according to clinician defined levels and patient preferences, and for managing patient and session records. The Patient Remote Control Application runs on iOS and Android platforms and offers basic control of the Trial Therapy Disc and Therapy Disc through a secure Bluetooth Low Energy link. The controls include selecting between clinician-defined therapy options (programs), turning stimulation on and off, and managing alerts.
    AI/ML Overview

    The provided text is a 510(k) premarket notification for the Nalu Neurostimulation System for Peripheral Nerve Stimulation. It describes the device, its intended use, and a comparison to predicate devices to demonstrate substantial equivalence. However, it explicitly states that no clinical performance data was deemed necessary for this submission.

    Therefore, I cannot provide a table of acceptance criteria and reported device performance from a clinical study, nor details about sample sizes, expert ground truth establishment, adjudication, MRMC studies, or standalone algorithm performance, as these were not part of the documented submission process for this device.

    The section "5.9. Clinical Performance Data" clearly states:
    "Nalu Medical determined that bench and non-clinical testing are sufficient to demonstrate that the Nalu Neurostimulation System is as safe and effective as the predicate device. Note that the predicate device did not need clinical evidence to obtain a determination of substantial equivalence."

    Based on the provided document, the device's acceptance was based on non-clinical performance (bench testing, animal studies, and compliance with standards).

    Here's a breakdown of what can be extracted from the document regarding the device's safety and effectiveness without clinical data:

    1. A table of acceptance criteria and the reported device performance:

    As no clinical study was performed for this submission, there are no "acceptance criteria" related to a clinical performance study with human subjects, nor "reported device performance" in terms of clinical outcomes. The device's performance was evaluated through non-clinical testing to demonstrate substantial equivalence to predicate devices.

    Table: Performance Evaluation based on Non-Clinical Testing and Substantial Equivalence

    Acceptance Criteria Category (based on Non-Clinical Testing)Reported Device Performance (Nalu Neurostimulation System)
    Functional and Electrical PerformanceVerified to meet target specifications over a range of operating and storage conditions through electrical testing.
    Mechanical PerformanceVerified to meet target specifications over a range of operating and storage conditions through mechanical testing.
    Software Verification & ValidationDemonstrated to perform as intended in the specified use conditions.
    BiocompatibilityDemonstrated to be biocompatible based on testing (cytotoxicity, sensitization, irritation/intracutaneous reactivity, systemic toxicity, implant studies, chemical characterization) according to ISO 10993-1:2009 and FDA guidance. This included testing for implant devices (IPG, Leads, Anchor, Extension: permanent contact), externally communicating devices (Needles, Sheaths, surgical tools: limited contact), and surface devices (Therapy Discs, adhesive clip: permanent intact skin contact).
    Sterilization ValidationValidated using Ethylene Oxide (ISO 11135-1:2014).
    Human Factors & UsabilityTesting performed on the device to ensure it met user needs as reflected in the functional specification, adhering to IEC 60601-1-6:2010+A1:2013 and IEC 62366-1:2015, and FDA guidance.
    Animal Study Findings (Pre-clinical Validation)Six (6) Nalu Neurostimulation IPGs and Lead systems implanted in a porcine model for 90 days. All devices performed as expected without incident. No device- or procedure-related complications or premature deaths. Data collected at 30, 60, and 90-day intervals. This study covered surgical usability, RF communication and stimulation, implanted device stability, and tissue response.
    Compliance with StandardsCompliance demonstrated with relevant standards (e.g., ISO 14708-1:2014, ISO 14708-3:2017, IEC 60601-1:2005:A2012, IEC 60601-1-11:2015, IEC 60601-1-2:2014, IEC 62304:2015, ISO 14971:2012/2007, ISO 11607-1/2:2006, CISPR 11, and FDA guidance on Cybersecurity).
    Substantial Equivalence to PredicateAll physical and therapeutic attributes are within or equivalent to the parameters of the StimQ Peripheral Nerve Stimulator (PNS) System (K171366) and other reference devices (Medtronic Mattrix, Medtronic Xtrel, ANS Renew). Differences in lead length, diameter, electrode array length, number of electrodes, electrode surface area, lead extension, anchor, configurations, software platforms, and transmit frequency were deemed not to affect safety and effectiveness of the intended use, based on engineering analysis and comparison to a range of previously cleared devices.

    2. Sample size used for the test set and the data provenance:

    • Test Set (Non-clinical):
      • Animal Study: 6 Nalu Neurostimulation IPGs and Lead systems were implanted. Data provenance is a pre-clinical study conducted by Nalu Medical (presumably in the USA, as it's an FDA submission for a US company). It's a prospective study.
      • Bench Testing: Quantities of devices or components used for electrical, mechanical, biocompatibility, sterilization, and human factors testing are not specified in numerical terms within this document. The provenance is internal testing by Nalu Medical.
    • Training Set (Not applicable for this submission method): No training set data is referenced, as this is a 510(k) based on substantial equivalence to predicates, not a de novo clearance requiring clinical studies or algorithmic training data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable for clinical ground truth. For the animal study, the "ground truth" was the observed performance of the device in a living model and tissue response, assessed by the study investigators. The qualifications of these experts are not detailed in the document.
    • For engineering and performance testing, the ground truth is established by the design specifications, validated test methods, and industry standards, implemented and evaluated by qualified engineers and testers.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • Not applicable for clinical studies. For the non-clinical and animal studies, methods like peer review of study protocols, data analysis, and report generation would be in place, but a "2+1" or "3+1" adjudication method typically refers to radiologist consensus in image-based AI studies, which is not relevant here.

    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, an MRMC comparative effectiveness study was not done. This type of study would be relevant for AI-powered diagnostic devices, which is not the case for this neurostimulation system.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • Not applicable. This device is a neurostimulation system, not an AI algorithm for diagnosis or interpretation. Its software controls the device's function, and its performance is evaluated in the context of device operation, not as a standalone diagnostic tool. The software was subject to verification and validation tests as per IEC 62304.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • For the animal study: The ground truth was based on direct observation of device performance, surgical usability, stability, tissue response, and lack of complications in the porcine model.
    • For bench testing: Ground truth was based on established engineering specifications, validated test methods, and compliance with national and international standards.

    8. The sample size for the training set:

    • Not applicable. This submission is based on substantial equivalence and non-clinical data, not on an algorithm trained with a specific dataset.

    9. How the ground truth for the training set was established:

    • Not applicable. (See point 8).
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    K Number
    K183047
    Manufacturer
    Date Cleared
    2019-03-22

    (140 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K141399, K934065, K883780, K000852

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Nalu Neurostimulation System is indicated as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral or bilateral pain.

    The trial devices are solely used for trial stimulation (no longer thank 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation system (also referred to as the "Nalu System") is used for spinal cord stimulation to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral or bilateral pain. The Nalu Neurostimulation system incorporates a miniature implanted neurostimulator, powered by an externally worn device. Similar to the predicate Stimwave system, the Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system.

    The Nalu Neurostimulation System is comprised of 5 elements: Nalu Implantable Pulse Generator, Leads, Surgical and Trial Tools, Externally worn Therapy Discs, and Programmer, Remote.

    AI/ML Overview

    This document is a 510(k) premarket notification for the Nalu Neurostimulation System, indicating that clinical performance data was not required for substantial equivalence. Therefore, there is no study described in this document that proves the device meets specific acceptance criteria based on human clinical data.

    The acceptance criteria described in the document relate to non-clinical performance testing (bench testing, biocompatibility, and animal testing) to demonstrate safety and effectiveness relative to a predicate device.

    Here's an breakdown of the information requested, based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    Since no clinical acceptance criteria or performance metrics were provided in the document due to the nature of a 510(k) without clinical studies, I will summarize the general approach to substantial equivalence and the scope of non-clinical testing.

    General Acceptance Criteria (Implied for 510(k) clearance): The Nalu Neurostimulation System is substantially equivalent to the predicate device (Stimwave Freedom SCS System K170141) in terms of:

    • Intended Use
    • Technological Characteristics
    • Principles of Operation

    Reported Device Performance (Non-Clinical):

    Acceptance Criteria CategoryReported Device PerformanceJustification/Outcome
    Substantial Equivalence (Overall)Nalu Neurostimulation System vs. Stimwave Freedom SCS System (K170141)No significant differences in physical and therapeutic attributes that would raise new questions of safety or effectiveness. Differences exist but do not alter intended therapeutic use or affect safety/effectiveness.
    BiocompatibilityCompliance with ISO 10993-1:2009Components categorized by contact type (Implant, Externally Communicating, Surface) and duration, and subjected to testing including cytotoxicity, sensitization, irritation/intracutaneous reactivity, systematic toxicity, implant studies, and chemical characterization. Biocompatibility was demonstrated.
    Animal StudyEvaluation in porcine model over 90 daysSix Nalu Neurostimulation IPGs and Lead systems implanted. Evaluated surgical usability, RF communication/stimulation, implanted device stability, and tissue response. All devices performed as expected with no device- or procedure-related complications or premature deaths. Preliminary validation of safety and use.
    Electrical, Mechanical, Software PerformanceVerification TestingDevice met target specifications over a range of operating and storage conditions.
    Usability/Human FactorsValidation and Usability TestingDevice demonstrated to meet user needs as reflected in the functional specification.
    SterilizationEthylene Oxide sterilization validationPerformed to ISO 11135-1:2014 standards.
    Software Life Cycle ProcessesCompliance with IEC 62304:2015Processes followed for medical device software. (Software Level of Concern: Moderate)
    Risk ManagementCompliance with EN ISO 14971:2012, ISO 14971:2007Application of risk management to medical devices.
    PackagingCompliance with ISO 11607-1:2006/Amd 1:2014 and -2:2006/Amd 1:2014Packaging for terminally sterilized medical devices.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Test Set (Non-Clinical):
      • Animal Study: Six Nalu Neurostimulation IPGs and Lead systems were used in a porcine model. This was a prospective animal study. The specific country of origin for the animal study is not mentioned.
      • Bench Testing: The document does not specify exact sample sizes for each bench test (electrical, mechanical, software), but it implies sufficient testing was conducted to meet relevant international standards and guidance documents. This is typically prospective testing conducted in a laboratory setting.
      • Biocompatibility Testing: The number of samples for biocompatibility testing is not specified but would follow established protocols for ISO 10993. This is typically prospective testing.

    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)

    • Not applicable for clinical studies. For the non-clinical tests described:
      • Animal Study: The study was conducted by researchers/veterinary staff, but the "ground truth" was established by direct observation and measurement of device performance, tissue response, and lack of complications in the porcine model. No external experts for ground truth establishment were specifically mentioned in this context.
      • Bench/Biocompatibility/Software Testing: Ground truth is established by engineering specifications, validated test methods, and compliance with recognized standards. Expertise would come from internal design and quality engineers, and potentially third-party testing laboratories, but not in the "expert medical consensus" sense.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable for clinical studies. For the non-clinical tests described, adjudication methods like 2+1 or 3+1 are not used. Results are based on objective measurements and compliance with predefined specifications and standards.

    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 MRMC comparative effectiveness study was done. The document explicitly states: "Nalu Medical determined that bench and non-clinical testing are sufficient to demonstrate that the Nalu Neurostimulation system is as safe and effective as the predicate device. Note that the predicate device did not need clinical evidence to obtain a determination of substantial equivalence." This is a premarket notification (510(k)) that established substantial equivalence based on non-clinical data, not clinical performance or AI assistance for human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not applicable. The Nalu Neurostimulation System is an implantable medical device for pain relief, not an AI or imaging diagnostic tool. Therefore, standalone algorithm performance is not relevant to this submission.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    • Non-Clinical Ground Truth:
      • Bench Testing: Engineering specifications, validated test methods, and compliance with national and international standards (e.g., ISO 14708, IEC 60601 series, ISO 11135, CISPR 11).
      • Biocompatibility Testing: Standards-based evaluation (ISO 10993-1) of material interactions with biological systems.
      • Animal Study: Direct observation of surgical usability, RF communication, device stability, and histopathological tissue response in the porcine model, as interpreted by veterinary and scientific experts.

    8. The sample size for the training set

    • Not applicable. This device is hardware for neurostimulation, not an AI/ML algorithm that requires a training set.

    9. How the ground truth for the training set was established

    • Not applicable. As stated above, this device does not use an AI/ML algorithm with a training set.
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    Why did this record match?
    Reference Devices :

    K011702, K022241, K991784, K000852

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Smartpatch Peripheral Nerve Stimulation (PNS) System is indicated for up to 30 days in the back and/or extremities for:

    • · Symptomatic relief of chronic, intractable pain, post-surgical and post-traumatic acute pain;
    • · Symptomatic relief of post-traumatic pain;
    • · Symptomatic relief of post-operative pain.

    The Smartpatch PNS System is not intended to treat pain in the craniofacial region.

    Device Description

    The Smartpatch PNS System is comprised of a percutaneous electrode placed via an introducer needle in proximity to a target peripheral nerve associated with a painful area and a wearable external stimulator that delivers stimulation therapy to the percutaneous electrode. The Smartpatch PNS System provides peripheral nerve stimulation (PNS) therapy to relieve pain. The percutaneous electrode is a sterile, flexible, coiled, stainless steel wire designed to be percutaneously inserted through the skin via an introducer needle and remain indwelling for the duration of the therapy (up to 30 days). The diameter of the wire is 0.26mm. The wire is provided in two lengths (20cm, 40cm) with a maximum placement depth of approximately 10cm.

    AI/ML Overview

    The provided document outlines the substantial equivalence of the Smartpatch PNS System to a predicate device and does not contain detailed acceptance criteria or a dedicated study proving performance against such criteria. The document focuses on comparing the Smartpatch PNS System's characteristics to existing devices to establish its safety and effectiveness for market entry.

    However, based on the information provided regarding performance data and clinical studies, we can infer some aspects related to effectiveness, even if not explicitly defined as acceptance criteria.

    Inferred Acceptance Criteria and Reported Device Performance (based on available information):

    Acceptance Criteria (Inferred)Reported Device Performance (from document)
    Safety: Minimal adverse eventsClinical studies demonstrated the safety of the therapy. Adverse events reported included skin irritation, erythema, a blister, or a mild skin tear. The majority of adverse events resolved with little to no intervention and resolved within a few days, and none were classified as serious.
    Effectiveness (Symptomatic Relief of Pain): Improvement in pain symptoms (implied)While the document states that "no effectiveness data are required to demonstrate substantial equivalence," it mentions that "clinical testing includes multiple completed and ongoing studies on chronic or intractable pain, post-surgical pain, and post-traumatic pain. These studies have demonstrated safety of the therapy." It also states, however, that "A randomized controlled trial failed to show that the Smartpatch was effective for post-stroke shoulder pain." The general statement about demonstrating safety of therapy for the pain indications implies some level of positive output from these studies, even if detailed effectiveness metrics are not presented as formal acceptance criteria within this 510(k) summary. The failure to show effectiveness for post-stroke shoulder pain indicates a specific limitation or negative finding in one particular application of the device.
    Biocompatibility: No adverse tissue reactionNonclinical testing included biocompatibility testing. (Implicitly, this testing would have met certain standards, indicating no unacceptable adverse tissue reactions.)
    Electrical Safety & Performance: Meets electrical standardsNonclinical testing included electrical testing (safety and electromagnetic compatibility) and system performance testing. (Implicitly, these tests met relevant standards for electrical safety and device functionality.)
    Software Functionality: Verified and validated softwareNonclinical testing included software verification and validation. (Implicitly, the software performs as intended to control the device.)

    Study Information (as provided within the document):

    1. Sample Size Used for the Test Set and Data Provenance:

      • Test Set Sample Size: Not explicitly stated for specific clinical studies. The document refers to "multiple completed and ongoing studies."
      • Data Provenance: Not explicitly stated (e.g., country of origin). The studies appear to be clinical trials conducted by the applicant, SPR Therapeutics, LLC. Whether they are retrospective or prospective is not specified, but the term "ongoing studies" implies prospective elements for some trials.
    2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications: Not applicable. The document discusses clinical studies for safety and effectiveness in pain relief, which typically rely on patient-reported outcomes or objective physiological measures rather than expert consensus on images or diagnostic classifications.

    3. Adjudication Method for the Test Set: Not applicable. As the studies focus on pain relief, adjudication in the sense of expert review of data for ground truth establishment is not described.

    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study: No. This type of study is relevant for diagnostic imaging devices where human readers interpret cases. The Smartpatch PNS System is a therapeutic device for pain relief.

    5. Standalone (Algorithm Only) Performance Study: Not applicable. The Smartpatch PNS System is a physical medical device (a peripheral nerve stimulator) with human interaction in its application and use, not an algorithm operating in isolation. Its performance is intrinsically linked to patient-device interaction and physiological response.

    6. Type of Ground Truth Used: The clinical studies mentioned would have used patient-reported pain scores (e.g., VAS, NRS), functional assessments, and observation of adverse events to assess safety and effectiveness. This aligns broadly with outcomes data and patient-reported outcomes.

    7. Sample Size for the Training Set: Not applicable. The context of a "training set" is typically for machine learning algorithms. The provided document details a medical device (a nerve stimulator), not an AI/ML algorithm.

    8. How the Ground Truth for the Training Set Was Established: Not applicable, as there is no "training set" in the context of this device and document.

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