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510(k) Data Aggregation

    K Number
    K091409
    Date Cleared
    2010-07-06

    (419 days)

    Product Code
    Regulation Number
    866.1640
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K033415,K042357

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

    The LightCycler® MRSA Advanced Test is a qualitative in vitro diagnostic test for the direct detection of nasal colonization with methicillin-resistant Staphylococcus aureus (MRSA) to aid in the prevention and control of MRSA infections in healthcare settings. The test is performed on the LightCycler® 2.0 Instrument with nasal swab specimens from patients suspected of colonization, uses swab extraction and mechanical lysis for specimen preparation followed by polymerase chain reaction (PCR) for the amplification of MRSA DNA, and fluorogenic target specific hybridization probes for the detection of the amplified DNA.

    The LightCycler® MRSA Advanced Test is not intended to diagnose, guide or monitor treatment for MRSA infections. Concomitant cultures are necessary to recover organisms for epidemiology typing or for further susceptibility testing.

    Device Description

    The LightCycler® MRSA Advanced Test relies on 3 major processes: (1) specimen preparation by mechanical lysis of the bacterial cell walls, (2) PCR amplification of target DNA and detection by specific hybridization probes, and (3) automated result generation after melting peak analysis.

    A nasal specimen is collected and transported to the laboratory in either BBL™ CultureSwab™ Liquid Stuart or Copan Venturi Transystem™ Liquid Stuart, BBL™ CultureSwab™ plus Amies gel with charcoal or Copan Venturi Transystem™ plus Amies gel with charcoal or BBL™ CultureSwab™ plus Amies gel without charcoal or Copan Venturi Transystem™ plus Amies gel without charcoal. Swab heads are cut into lysis tubes and subjected to heating to inactivate specimens. Subsequently lysis tubes are transferred in the MagNA Lyser Instrument where mechanical lysis of bacterial cell walls occurs, resulting in crude lysate preparations. After a brief centrifugation step to spin down glass beads and swab fibers, the processed specimen are subjected to PCR analysis using the LightCycler® MRSA Advanced Test.

    The processed samples and the amplification mixture containing hot-start Tag polymerase are placed in LightCycler® Capillaries (20uL) in which PCR amplification will occur. Each LightCycler® MRSA Advanced Test reaction contains an internal control, which is designed to control for specimen inhibition, and to monitor reagent integrity. Also present in each LightCycler® MRSA Advanced Test is the AmpErase (uracil-N-glycosylase) enzyme. It recognizes and catalyzes the destruction of DNA strands containing deoxyuridine, but not DNA containing deoxythymidine. Since amplicons produced with the LightCycler® MRSA Advanced Test contain deoxyuridine, potential amplicon contaminants are eliminated during a prolonged heating step performed prior to the start of PCR amplification.

    A target sequence in a plasmid is simultaneously amplified in the Positive Control. The Positive Control is intended to monitor for reagent failure and is included into each run. Each run also includes a Negative Control used to detect reagent or environmental contamination by MRSA DNA.

    MRSA and Internal Control amplicons are detected by fluorescence using a specific pair of hybridization probes. The probes attach to a specific internal sequence in the amplified fragment and are positioned in a closed proximity to one another. Upon excitation, these bound probes emit a fluorescence signal of a specific wavelength using a process called Fluorescence Resonance Energy Transfer (FRET). The emitted light is measured by the Light ycler® 2.0 Instrument. MRSA or internal control specific amplicons are detected in parallel in two different detection channels and thus can be differentiated.

    After completion of the real-time PCR process, a melting peak analysis is performed automatically by the LightCycler® 2.0 Instrument. Single stranded DNA amplicons with bound hybridization probes are subjected to increasing temperatures. When the PCR products reach a specific temperature one of the two bound hybridization probes melts off, resulting in a loss of fluorescence signal. The decrease in the fluorescence signal occurs at a specific temperature and results in melting peaks which are used to identify and distinguish MRSA- and Internal Controlspecific amplicons.

    After a visual identification of the melting peaks is performed using Tm Bars in the LightCycler® Software, test results are transferred to a dedicated interpretation tool (the Micro Analysis Software) and a report is generated.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study details for the LightCycler® MRSA Advanced Test, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly state 'acceptance criteria' in a formal table format with specific numerical targets before presenting the results. Instead, it presents the performance characteristics and implies that these results were deemed acceptable for substantial equivalence. The predicate device's performance is listed as a point of comparison (Sensitivity: 92.5%, Specificity: 96.4% using an enriched culture method).

    Therefore, the table below reflects the reported performance of the LightCycler® MRSA Advanced Test in its clinical evaluation against the specified ground truths, which implicitly served as the demonstration of meeting the required performance for market clearance.

    Performance MetricAcceptance Criteria (Implied by Predicate/Demonstrated Performance)Reported Device Performance (LightCycler® MRSA Advanced Test)Ground Truth Used
    Analytical Sensitivity (LoD)Not explicitly stated (predicate not shown for this)240 CFU/swab (95% confidence)Quantified MRSA cultures
    Analytical InclusivityHigh percentage of MRSA isolates detected99.3% (136/137) of NARSA strains detected; 95% (1561/1643) of additional isolatesWell-characterized MRSA isolates (NARSA Program, clinical sites)
    Analytical Specificity (Exclusivity)High percentage of non-MRSA organisms showing no cross-reactivity98.9% of tested organisms showed no cross-reactivityIdentified bacterial, viral, fungal species, human DNA
    PPA vs. Direct Chromogenic CultureComparable to predicate (92.5%)*95.2% (91.1%, 97.8% CI)Direct Chromogenic Culture
    NPA vs. Direct Chromogenic CultureComparable to predicate (96.4%)*96.4% (95.2%, 97.4% CI)Direct Chromogenic Culture
    PPA vs. Second FDA-Cleared NAATNot explicitly stated (used as comparison, not a target)71.7% (65.9%, 77.0% CI)Second FDA-Cleared NAAT
    NPA vs. Second FDA-Cleared NAATNot explicitly stated (used as comparison, not a target)98.2% (97.2%, 98.9% CI)Second FDA-Cleared NAAT
    PPA vs. Broth CultureNot explicitly stated (broth is more sensitive benchmark)89.8% (84.8%, 93.5% CI)Broth Culture
    NPA vs. Broth CultureNot explicitly stated (broth is more sensitive benchmark)96.8% (95.6%, 97.7% CI)Broth Culture
    ReproducibilityHigh agreement across lots, sites, daysNegative: 98-100%; Below LoD: 41-58%; Weak Positive: 99-100%; Positive: 98-100%Spiked samples with known concentrations

    *Note on Predicate Comparison: The predicate device's performance was reported using an enriched culture method as its ground truth, while the LightCycler® MRSA Advanced Test was initially compared to direct chromogenic culture. Discrepancy analysis also suggested the LightCycler® test might be more sensitive than direct chromogenic culture alone. The "substantial equivalence" claim hinges on the overall body of evidence.

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

    • Clinical Performance (Method Comparison):
      • Initial samples collected: 1,620 nasal swab specimens.
      • Eligible for statistical analysis: 1,402 specimens.
      • Data Provenance: Multi-site prospective investigational study at 5 institutions across the United States.
    • Analytical Inclusivity (Epidemiological Clones):
      • NARSA strains: 137 isolates.
      • Additional isolates: 1,643 isolates (65% Europe, 35% U.S.).
      • Data Provenance: NARSA Program (NIAID/NIH contract) and clinical sites in the U.S. and Europe.
    • Analytical Specificity (Exclusivity):
      • Cross-reactivity panel: 13 viral, 66 bacterial, 7 fungal species, human DNA (total 87 distinct species/DNA).
      • Additional strains: 117 methicillin-resistant coagulase-negative staphylococci, 104 methicillin-sensitive coagulase-negative staphylococci, 100 methicillin-sensitive Staphylococcus aureus.
      • Data Provenance: Not explicitly stated, but likely laboratory-sourced or reference strains from various locations.

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

    The ground truth for the clinical performance study was established by culture methods (direct chromogenic culture and broth culture), not by human experts interpreting results. The text does not mention any experts for establishing ground truth for the primary clinical study endpoint.

    However, for the discrepancy analysis, further investigation was performed, including "testing for mecA mediated Oxacillin resistance using cefoxitin disk diffusion methodology, fem- and mecA-specific PCR, and sequencing of SCCmec regions." This implies expert laboratory analysis to confirm the presence or absence of MRSA, but the number and specific qualifications of those experts are not provided.

    4. Adjudication Method for the Test Set:

    For the clinical performance study, the primary ground truth was established by culture methods (direct chromogenic culture and broth culture). The results were compared against these predefined culture outcomes.

    • No explicit "adjudication method" involving multiple human readers/experts is described for the primary comparison.
    • Discrepancy Analysis: When discordance occurred between the LightCycler® MRSA Advanced Test and the culture ground truth (or between the LightCycler test and the second FDA-cleared NAAT), further confirmatory molecular testing was used to resolve these discrepant results. This served as a form of "adjudication" based on advanced laboratory techniques.

    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:

    No. This device is a fully automated in-vitro diagnostic test (nucleic acid amplification test) for direct detection of MRSA. It does not involve human readers interpreting images or data where AI assistance would be applicable in the sense of improving human reader performance. Therefore, an MRMC comparative effectiveness study of this nature was not conducted.

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

    Yes, the entire clinical performance study and analytical studies represent a standalone performance evaluation of the LightCycler® MRSA Advanced Test. The device provides "automated result generation after melting peak analysis" (page 4), and results are transferred to a "dedicated interpretation tool (the Micro Analysis Software)" to generate a report (page 4). The performance metrics provided (PPA, NPA, sensitivity, specificity, inclusivity, exclusivity) are a direct measure of the device's accuracy without human interpretation influencing the final call. The human interaction is limited to specimen preparation and loading, and the machine-generated result is the standalone output.

    7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.):

    • Clinical Performance (Method Comparison):
      • Direct Chromogenic Culture: Used as a primary comparator.
      • Broth Culture: Used as a more sensitive comparator.
      • Discrepancy Analysis: Advanced molecular testing (mecA mediated Oxacillin resistance, fem- and mecA-specific PCR, SCCmec region sequencing) was used to confirm MRSA presence in discrepant samples. This represents a more definitive, complex laboratory-based ground truth.
    • Analytical Sensitivity (LoD): Quantified MRSA cultures.
    • Analytical Inclusivity: Well-characterized MRSA isolates (epidemiological clones).
    • Analytical Specificity (Exclusivity): Identified bacterial, viral, fungal species, and human DNA.
    • Reproducibility: Spiked samples with known concentrations of MRSA and MSSE.

    8. The Sample Size for the Training Set:

    The document does not explicitly describe a separate "training set" in the context of machine learning or AI algorithm development. This device is a molecular diagnostic test governed by predefined PCR assays and melting curve analysis, not a learning algorithm that requires a separate training phase. The analytical and clinical studies described evaluate the performance of the fully developed test.

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

    As there is no described training set for an AI/machine learning algorithm, this question is not applicable to the information provided. The ground truths for the various analytical and clinical studies (LoD, inclusivity, exclusivity, clinical comparison) were established as described in point #7.

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