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510(k) Data Aggregation

    K Number
    K113377
    Manufacturer
    Date Cleared
    2012-12-14

    (394 days)

    Product Code
    Regulation Number
    866.5750
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K052439

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

    The a-Gliatest® IgA is intended for the semi-quantitative determination of IgA antibodies directed against gliadin in human serum. The assay is an aid in the diagnosis of celiac disease and should be used in conjunction with other serological tests and clinical findings.

    The a-Gliatest® IgG is intended for the semi-quantitative determination of IgG antibodies directed against gliadin in human serum. The assay is an aid in the diagnosis of celiac disease and should be used in conjunction with other serological tests and clinical findings.

    The a-GliaPep® IgA is intended for the semi-quantitative determination of IgA antibodies directed against deamidated gliadin peptide in human serum. The assay is an aid in the diagnosis of celiac disease and should be used in conjunction with other serological tests and clinical findings.

    The a-GliaPep® IgG is intended for the semi-quantitative determination of IgG antibodies directed against deamidated gliadin peptide in human serum. The assay is an aid in the diagnosis of celiac disease and should be used in conjunction with other serological tests and clinical findings.

    Device Description

    Each test kit for a-Gliatest® IgA, a-Gliatest® IgG, a-GliaPep® IgA, and a-GliaPep® IgG consists of one (1) microtiter plate (12 strips of 8 microwells coated with purified a-gliadin antigen or deamidated gliadin peptide antigen), assay controls (positive and negative), a ready-to-use set of five (5) calibrators, Horseradish Peroxidase (HRP) goat anti-human IgA or IgG conjugate, serum diluent, Tetramethylbenzidine (TMB) enzyme substrate, stop solution, and washing solution required for the assay.

    AI/ML Overview

    The provided document describes the Grifols USA, Inc. a-Gliatest® IgA, a-Gliatest® IgG, a-GliaPep® IgA, and a-GliaPep® IgG devices, which are intended for the semi-quantitative determination of IgA/IgG antibodies directed against gliadin or deamidated gliadin peptide in human serum as an aid in the diagnosis of celiac disease.

    Here's an analysis of the acceptance criteria and the studies performed, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally implied through comparison with a predicate device (Aeskulisa® Glia A/G (K052439)) and through performance metrics like precision, linearity, and detection limits. The method comparison and clinical studies aim to demonstrate substantial equivalence and adequate diagnostic performance.

    Below is a summary of the reported performance for each device, with implied acceptance criteria based on the context of 'substantial equivalence' to the predicate and satisfactory clinical utility. The document does not explicitly state pre-defined acceptance criteria for the clinical or method comparison studies in terms of specific percentages, but rather presents the results. For analytical performance, the studies demonstrate what is considered acceptable.

    Metric (Implied Acceptance Criteria)α-Gliatest® IgA Performanceα-Gliatest® IgG Performanceα-GliaPep® IgA Performanceα-GliaPep® IgG Performance
    Analytical Performance
    Intra-assay Precision (CV%)Range: 2.7-7.7%Range: 2.4-5.4%Range: 3.3-9.8%Range: 3.6-7.1%
    Inter-run Precision (CV%)Range: 3.3-17.3%Range: 1.6-16.9%Range: 2.3-14.9%Range: 2.2-9.6%
    Inter-lot Precision (CV%)Range: 0.9-10.1%Range: 1.4-4.1%Range: 2.1-8.1%Range: 1.2-10.2%
    Linearity Range (AU/mL)1.1 - 1002.5 - 99.41.1 - 1001.1 - 100
    Claimed Limit of Detection (LoD)1.1 AU/mL2.4 AU/mL1.1 AU/mL1.1 AU/mL
    Method Comparison Study (vs. Predicate)
    Positive Agreement89.7% (95% C.I. 78.8%-96.1%)78.8% (95% C.I. 67.0%-87.9%)72.0% (95% C.I. 57.5%-83.8%)79.4% (95% C.I. 67.3%-88.5%)
    Negative Agreement85.0% (95% C.I. 77.3%-90.9%)88.6% (95% C.I. 82.0%-93.5%)91.5% (95% C.I. 85.3%-95.7%)88.4% (95% C.I. 81.9%-93.2%)
    Overall Agreement86.5% (95% C.I. 80.6%-91.2%)85.4% (95% C.I. 79.6%-90.0%)86.0% (95% C.I. 80.1%-90.8%)85.6% (95% C.I. 79.9%-90.1%)
    Clinical Study Performance
    Sensitivity69.3% (95% C.I. 60.1%-77.5%)79.6% (95% C.I. 71.8%-86.0%)79.6% (95% C.I. 69.9%-87.2%)90.5% (95% C.I. 83.2%-95.3%)
    Specificity75.7% (95% C.I. 67.9%-82.3%)88.5% (95% C.I. 82.2%-93.2%)93.2% (95% C.I. 87.9%-96.7%)85.1% (95% C.I. 78.4%-90.4%)

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

    • α-Gliatest® IgA:
      • Method Comparison Test Set: 178 clinical samples. Provenance: Includes clinically-diagnosed celiac positive (clinical history and/or biopsy) and negative samples (healthy blood donors, IBD, IBS, food intolerances, autoimmune disorders, infectious diseases, Type 1 diabetes patients). Retrospective.
      • Clinical Study Test Set: 262 clinical samples (114 celiac positive, 148 negative from disease controls). Provenance: Celiac patient samples diagnosed with clinical findings and/or confirmed with biopsy. Negative samples from disease control patients (autoimmune disorders, infectious diseases, IBD, IBS, Type 1 diabetes). Also, 196 healthy blood donor samples. Retrospective.
    • α-Gliatest® IgG:
      • Method Comparison Test Set: 198 clinical samples (51 celiac positive, including 10 IgA-deficient celiac patients; negative samples from healthy blood donors, IBD, IBS, food intolerances, autoimmune disorders, infectious diseases, Type 1 diabetes patients). Retrospective.
      • Clinical Study Test Set: 285 clinical samples (127 celiac positive, 10 IgA-deficient celiac patients; 148 negative from disease controls). Provenance: Celiac patient samples diagnosed with clinical findings and confirmed with biopsy. Negative samples from disease control patients (autoimmune disorders, infectious diseases, IBD, IBS, Type 1 diabetes). Also, 196 healthy blood donor samples. Retrospective.
    • α-GliaPep® IgA:
      • Method Comparison Test Set: 179 clinical samples. Provenance: Clinically-diagnosed celiac positive (clinical history and/or biopsy) and negative samples (healthy blood donors, IBD, IBS, food intolerances, autoimmune disorders, infectious diseases, Type 1 diabetes patients). Retrospective. The samples were within the linearity range of the assay.
      • Clinical Study Test Set: 241 clinical samples (93 celiac positive, 148 negative from disease controls). Provenance: Celiac patient samples diagnosed with clinical findings and confirmed with biopsy. Negative samples from disease control patients (autoimmune disorders, infectious diseases, IBD, IBS, Type 1 diabetes). Also, 145 healthy blood donor samples. Retrospective.
    • α-GliaPep® IgG:
      • Method Comparison Test Set: 201 clinical samples (57 celiac positive, including 10 IgA-deficient celiac patients; 146 negative samples recruited similarly to other assays). Provenance: Clinically-diagnosed celiac positive (clinical history and/or biopsy) and negative samples (healthy blood donors, IBD, IBS, food intolerances, autoimmune disorders, infectious diseases, Type 1 diabetes patients). Retrospective. The samples were within the linearity range of the assay.
      • Clinical Study Test Set: 253 clinical samples (95 celiac positive, including 10 IgA-deficient celiac patients; 148 negative from disease controls). Provenance: Celiac patient samples diagnosed with clinical findings (31.6%) and confirmed with biopsy (68.4%). Negative samples from disease control patients (autoimmune disorders, infectious diseases, IBD, IBS, Type 1 diabetes). Also, 145 healthy blood donor samples. Retrospective.

    For all studies, data provenance is global/not specified, and the data is retrospective.

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

    The document does not explicitly state the number of experts or their specific qualifications (e.g., radiologist with X years of experience) used to establish the ground truth for the test sets. It mentions that celiac positive samples were "clinically-diagnosed celiac positive (clinical history and/or biopsy)" and "diagnosed with clinical findings and confirmed with biopsy." This implies that the ground truth was established by medical professionals, likely gastroenterologists or pathologists, based on established diagnostic criteria for celiac disease, including clinical presentation and histological findings from biopsy. However, the specific number and formal qualifications of these experts are not provided.

    4. Adjudication Method for the Test Set

    The document does not describe a formal adjudication method (e.g., 2+1, 3+1) for resolving discrepancies in ground truth determination or in the interpretation of clinical findings and biopsies for the test set. The ground truth seems to be implicitly accepted based on the "clinical findings and/or biopsy" diagnosis.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of Human Readers Improve with AI vs. Without AI Assistance

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. These devices are in vitro diagnostic (IVD) assays, not imaging interpretation algorithms where human readers would typically be involved in interpreting results. The studies compare the performance of the device itself to a predicate device or to clinical ground truth, not to human reader performance with or without AI assistance.

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

    Yes, the studies conducted are standalone performance evaluations of the assay devices. The "method comparison studies" and "clinical studies" evaluate the performance of each assay (α-Gliatest® IgA, α-Gliatest® IgG, α-GliaPep® IgA, α-GliaPep® IgG) in isolation, comparing its output to a predicate device's output or to the clinical ground truth. There is no human-in-the-loop component described for the operation or interpretation of these assays beyond standard laboratory procedures.

    7. The Type of Ground Truth Used

    The ground truth for celiac positive samples was established based on:

    • Clinical findings: Clinical history and presentation consistent with celiac disease.
    • Biopsy: Histological confirmation from intestinal biopsy, which is a gold standard for celiac disease diagnosis.

    For negative samples, the ground truth was based on:

    • Healthy blood donors.
    • Patients with other relevant conditions (IBD, IBS, autoimmune disorders, infectious diseases, Type 1 diabetes) who would not be expected to have celiac disease.

    This can be categorized as a combination of expert consensus (clinical findings) and pathology (biopsy).

    8. The Sample Size for the Training Set

    The document primarily describes validation studies (test sets) and does not explicitly mention a separate "training set" for the development of these IVD assays. IVD products are typically developed through iterative processes of antigen/antibody selection and optimization, with assay parameters being refined, but these development phases are not usually referred to as "training sets" in the same way machine learning models are. The calibrators and controls are formulated from pooled sera, and new lots are calibrated against original calibrators, which involves testing (effectively a form of internal "training" or standardization) against:

    • Original calibrators
    • Normal human sera
    • Clinical samples
    • Internal standards

    However, a specific "training set" size for algorithm development (as would be typical for AI/ML devices) is not applicable or stated for this type of immunoassay.

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

    As noted above, a distinct "training set" for an algorithm in the AI/ML sense is not applicable to these IVD assays. Instead, the assay's operational parameters (like calibrator values) are established using:

    • Pooled sera with known anti-gliadin antibody levels from celiac patients.
    • Normal human sera.
    • Clinical samples.
    • Internal standards.

    The ground truth for these calibrators and controls would stem from the clinical diagnoses (clinical findings and/or biopsy) of the patient populations from which the sera were obtained. The document states, "Calibrators are dilutions of pooled sera with anti-gliadin antibody from patients with celiac disease." This implies that the ground truth for these pooled sera was established through the diagnosis of celiac disease in the donor patients.

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