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510(k) Data Aggregation
(18 days)
syngo.CT Applications is a set of software applications for advanced visualization, measurement, and evaluation for specific body regions.
This software package is designed to support the radiologists and physicians from emergency medicine, specialty care, urgent care, and general practice e.g. in the:
- · Evaluation of perfusion of organs and tumors and myocardial tissue perfusion
- · Evaluation of bone structures and detection of bone lesions
- · Evaluation of CT images of the heart
- · Evaluation of the coronary lesions
- · Evaluation of the mandible and maxilla
- · Evaluation of dynamic vessels and extended phase handling
- · Evaluation of the liver and its intrahepatic vessel structures to identify the vascular territories of sub-vessel systems in the liver
- · Evaluation of neurovascular structures
- Evaluation of the lung parenchyma
- · Evaluation of non-enhanced Head CT images
- · Evaluation of vascular lesions
The syngo.CT Applications are syngo based post-processing software applications to be used for viewing and evaluating CT images provided by a CT diagnostic device and enabling structured evaluation of CT images.
The syngo.CT Applications is a combination of thirteen (13) former separately cleared medical devices which are now handled as features / functionalities within syngo.CT Applications. These functionalities are combined unchanged compared to their former cleared descriptions; however, some minor enhancements and improvements are made for the application syngo.CT Pulmo 3D only.
The provided document is a 510(k) summary for syngo.CT Applications, which is a consolidation of thirteen previously cleared medical devices. The document explicitly states that "The testing supports that all software specifications have met the acceptance criteria" and "The result of all testing conducted was found acceptable to support the claim of substantial equivalence." However, it does not explicitly define specific acceptance criteria (e.g., target accuracy, sensitivity, specificity values) for the device's performance or detail the specific studies that prove these criteria are met. Instead, it relies on the premise that the functionalities remain unchanged from the previously cleared predicate devices, with only minor enhancements to one application (syngo.CT Pulmo 3D).
Therefore, based on the provided text, I cannot fill in precise quantitative values for acceptance criteria or specific study results for accuracy, sensitivity, or specificity. The information provided heavily emphasizes software verification and validation, risk analysis, and adherence to consensus standards, rather than detailing a comparative effectiveness study or standalone performance metrics against a defined ground truth.
Here's a breakdown of the available information and what is missing:
1. Table of acceptance criteria and the reported device performance:
Acceptance Criteria (Specific metrics, e.g., sensitivity, specificity, accuracy targets) | Reported Device Performance (Specific values achieved in studies) |
---|---|
Not explicitly stated in the document. The document indicates that all software specifications met acceptance criteria, but these criteria are not detailed. | Not explicitly stated in the document. The document refers to the device's functionality remaining unchanged from previously cleared predicate devices. |
2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
- Sample Size for Test Set: Not specified in the document.
- Data Provenance: Not specified in the document.
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):
- Number of Experts: Not specified in the document.
- Qualifications of Experts: Not specified in the document.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Adjudication Method: Not specified in the document.
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:
- MRMC Study Done: No. The document does not mention any MRMC comparative effectiveness study where human readers' performance with and without AI assistance was evaluated. The submission focuses on the consolidation of existing, cleared applications.
- Effect Size of Improvement: Not applicable, as no MRMC study is reported.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Standalone Study Done: Yes, implicitly. The document states, "The testing supports that all software specifications have met the acceptance criteria," suggesting that the software's performance was verified and validated independent of human interpretation to ensure its functionalities (visualization, measurement, evaluation) behave as intended. However, specific metrics (e.g., accuracy of a measurement tool compared to a gold standard) are not provided. The phrase "algorithm only" might not be fully accurate here given the device is a visualization and evaluation tool for human use, not an autonomous diagnostic AI.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Type of Ground Truth: Not explicitly specified. Given the nature of visualization and evaluation tools, it would likely involve comparisons to known values, measurements, or expert-reviewed datasets, but the document does not detail this.
8. The sample size for the training set:
- Training Set Sample Size: Not applicable/Not specified. The document describes the device as a consolidation of existing, cleared software applications with "minor enhancements and improvements" only to syngo.CT Pulmo 3D. It does not indicate that new machine learning models requiring large training sets were developed for this specific submission; rather, it refers to the performance of existing, cleared applications.
9. How the ground truth for the training set was established:
- How Ground Truth for Training Set was Established: Not applicable/Not specified, for the same reasons as point 8. The document does not describe a new AI model training process for this submission.
Summary of Device Rationale:
The core of this 510(k) submission is the consolidation of thirteen previously cleared syngo.CT applications into a single "syngo.CT Applications" product. The applicant, Siemens Medical Solutions USA, Inc., states that the functionalities within this combined product are "unchanged compared to their former cleared descriptions" with only "minor enhancements and improvements" in syngo.CT Pulmo 3D (specifically regarding color assignments for lobe borders).
The document asserts that "The performance data demonstrates continued conformance with special controls for medical devices containing software." It also states, "The risk analysis was completed, and risk control implemented to mitigate identified hazards. The testing results support that all the software specifications have met the acceptance criteria. Testing for verification and validation of the device was found acceptable to support the claims of substantial equivalence."
This implies that the "acceptance criteria" largely revolve around the continued functional performance and adherence to specifications of the already cleared individual applications, plus verification of the minor changes to syngo.CT Pulmo 3D, and the successful integration into a single software package. However, quantitative performance metrics for the device against specific clinical tasks are not provided in this 510(k) summary document, as the submission focuses on the substantial equivalence of the consolidated product to its predicate devices, rather than presenting new clinical efficacy data.
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(72 days)
syngo.CT Extended Functionality is intended to provide advanced visualization tools to prepare and process medical images for diagnostic purpose. The software package is designed to support technicians and physicians in qualitative and quantitative measurements and in the analysis of clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners.
An interface shall enable the connection between the syngo.CT Extended Functionality software package and the interconnected CT Scanner system.
Result images created with the syngo.CT Extended Functionality software package can be used to assist trained technicians or physicians in diagnosis.
syngo.CT Extended Functionality is a software bundle consisting of previously cleared unmodified and modified post-processing applications that offer tools to support special clinical evaluations. syngo.CT Extended Functionality can be used to create advanced visualizations and measurements on clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners.
Depending on the clinical question, the user can select functionality which supports the explicit clinical fields as listed below. The syngo.CT Extended Functionality software package is designed to operate on the most recent version syngo-compatible postprocessing platform, which currently supports the following four tools:
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- Preparation of Vascular Case for Reading Physician
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- Preparation of Oncology Case for Reading Physician
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- Preparation of Osteo Case for Reading Physician
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- Preparation of Neuro DSA Bone Subtraction for Reading Physician
The supported functionality can be used on any CT data if basic requirements are met (e.g. spiral or sequence scan, reconstruction kernel). The supported functionality will check to ensure the basic requirements are met and will not allow its execution or will provide a warning or info message to the user if appropriate. This check also allows combination of functionality of different clinical fields, (e.q. a vascular case can be prepared also on Neuro DSA bone subtracted data or on the same case as Lung CAD computation, etc.). Afterwards, any tool can be accessed as long as the data and viewing type allows it. For example, an evaluation of a ROI defined by a contour and two HU thresholds can be used to measure a certain area. No specific sequential workflow is required.
The original clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners will not be modified in any form. The results of the syngo.CT Extended Functionality can be stored as additional DICOM images if needed as kev images or range or images. The subject device syngo.CT Extended Functionality is designed to operate on a syngo compatible host system (e. g. syngo.via VB20 software platform or higher).
The provided text describes the 510(k) premarket notification for "syngo.CT Extended Functionality." However, it does not contain the specific details required to fully address all parts of your request regarding acceptance criteria and a detailed study proving device performance. The information provided is high-level and focuses on regulatory compliance and substantial equivalence to predicate devices, rather than a specific clinical performance study.
Here's a breakdown of the available information and what's missing:
1. A table of acceptance criteria and the reported device performance
The provided document does not include a specific table of acceptance criteria with corresponding performance metrics for the syngo.CT Extended Functionality as a whole, or for its individual modified components. It generally states:
- "All verification and validation testing has been completed and meets Siemens acceptance criteria." (Page 7)
- "The testing results support that all the software specifications have met the acceptance criteria." (Page 7)
- "The results of these tests demonstrate that the subject device performs as intended." (Page 7)
- "The results of all conducted testing was found acceptable to support the claim of substantial equivalence." (Page 7)
This is a general statement of compliance, not a detailed report of specific performance metrics against defined acceptance criteria.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify the sample size used for any test sets, nor does it provide information about the provenance of the data (country of origin, retrospective or prospective).
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)
The document does not mention the use of experts to establish ground truth for any test set or their qualifications.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
The document does not describe any adjudication methods used for a test set.
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
The document does not mention an MRMC comparative effectiveness study, nor does it discuss improvements in human reader performance with or without AI assistance. The device is described as providing "advanced visualization tools to prepare and process medical images for diagnostic purpose" and assisting "trained technicians or physicians in diagnosis," but not as an AI-powered diagnostic tool in the sense of comparing human performance with and without its specific assistance.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The document does not describe any standalone algorithm performance studies. The device is explicitly intended to "assist trained technicians or physicians in diagnosis," implying human-in-the-loop usage.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The document does not specify the type of ground truth used for any testing.
8. The sample size for the training set
The document does not mention a training set or its sample size. This is consistent with the device being a "software bundle consisting of previously cleared unmodified and modified post-processing applications," rather than a novel AI/ML algorithm that requires a dedicated training phase reported in this context.
9. How the ground truth for the training set was established
As no training set is mentioned, information on how its ground truth was established is also absent.
Summary of what is present in the document regarding testing:
The document focuses on "Non-Clinical Testing Summary" (Page 7) to demonstrate substantial equivalence, rather than detailed clinical performance studies.
- Type of Study: Non-clinical tests (integration and functional) were conducted. Verification/validation testing was performed for modifications to previously cleared components.
- Acceptance Criteria (General): "All verification and validation testing has been completed and meets Siemens acceptance criteria." "The testing results support that all the software specifications have met the acceptance criteria."
- Risk Analysis: A risk analysis was completed, and risk control was implemented in accordance with ISO 14971.
- Software Verification and Validation: Documentation for "Moderate Level of Concern" software was included, conforming to FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (May 11, 2005).
- Intended Use: The tests demonstrated the device "performs as intended."
- Comparison to Predicate: "Siemens used the same testing with the same workflows as used to clear the predicate device."
Conclusion based on the provided text:
The submission confirms that the device underwent verification and validation testing as part of the regulatory approval process for software, especially for modifications made to existing functionalities (like the Osteo feature). However, it does not provide the detailed clinical performance study data (including specific acceptance criteria, sample sizes, expert involvement, and ground truth methodologies) often associated with new diagnostic algorithms or AI-driven systems. The clearance is based on demonstrating substantial equivalence to predicate devices, supported by non-clinical performance data and software validation, suggesting the device's functionality is well-understood and its safety and effectiveness are established through these engineering and software-level tests.
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