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510(k) Data Aggregation
(119 days)
This device is intended to provide continuous positive airway pressure (CPAP) for the treatment of adult Obstructive Sleep Apnea (OSA) patients who are spontaneously breathing. It is intended for single patient reuse in the home environment.
The iCH CPAP with PVA 9S-007XXX Series are intended to provide continuous positive airway pressure for the treatment of adult obstructive sleep apnea (OSA). It is a modification of iCH CPAP 9S-007XXX (K120035) with the same algorithm of XT Auto with PVA 9S-005720 (K112079). It shares the same construction and auto adjustment algorithm with iCH CPAP 9S-007XXX but adds the identical Pressure Variation Algorithm with the predicate device XT Auto with PVA 9S-005720 (K112079). The Pressure Variation Algorithm provides a release pressure during expiration phase which is designed for patients who have difficulty exhaling against high CPAP pressure. It works by reducing the CPAP setting pressure in the normal breath status of expiratory phase from the treatment pressure in either CPAP or APAP mode.
A built-in heated humidifier of iCH CPAP with PVA 9S-007XXX Series are designed to increase the humidity of the air from the CPAP thereby relieving the symptoms of a dry nose and throat resulting from constant airflow that some patients may experience. The modified iCH CPAP series (with PVA) are from the iCH CPAP 9S-007XXX (K120035), but the algorithm for pressure variation algorithm(PVA) of the device comes from XT Auto with PVA (K112079).
The PVA Pressure Variation Alqorithm for the subject and predicated device (K112079) is an exhalation pressure relief function which is designed for patients who have difficulty exhaling against high CPAP pressure. Pressure can be reduced to three different levels (according to patient need) during the transition from Inspiration to Expiration phase. This reduced pressure level (depending on the PVA setting) will be maintained during Expiration phase and will return to the therapeutic pressure in the end of Expiration phase. In order to ensure the effectiveness of CPAP therapy, PVA will be automatically suspended if apneas are detected. After apneas disappear, PVA will re-start.
The provided text describes a 510(k) summary for the iCH CPAP with PVA 9S-007XXX series, which is a modified version of an existing device. The summary focuses on demonstrating substantial equivalence to predicate devices rather than detailing a specific study to prove acceptance criteria for a novel algorithm's performance in a clinical setting.
Therefore, many of the requested details about acceptance criteria, clinical study design, sample sizes, expert involvement, and ground truth establishment are not present in this regulatory document. The focus here is on engineering verification and comparison to existing, cleared devices.
Here's an attempt to extract relevant information and note where the requested details are absent:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't provide specific numerical acceptance criteria for clinical performance (e.g., sensitivity, specificity for disease detection). Instead, it relies on design verification tests to ensure the modified device functions similarly and safely to the predicate devices. The "reported device performance" is framed as "equivalent" or "identical" to the predicate.
Device Characteristic | Acceptance Criteria (Implied by Predicate Equivalence) | Reported Device Performance (vs. Predicate) |
---|---|---|
Intended User | Adult | Equivalent |
Outlook & Construction | Be identical to Predicate 1 (K120035) | Identical to Predicate 1 (K120035) |
Air Outlet | 22mm | Equivalent (22mm) |
User | Single-user, multi-use | Equivalent (Single-user, multi-use) |
Operating Environment | Within +5 ~ 35 °C, 15 ~ 95% Non-condensing | Equivalent (+5 ~ 35 °C, 15 ~ 95% Non-condensing) |
Pressure Range | 4 ~ 20 cmH2O | Equivalent (4 ~ 20 cmH2O) |
Pressure Increment | 0.5 cmH2O | Equivalent (0.5 cmH2O) |
Pressure Ramp Time | 0~45 min, 5 minutes per step | Equivalent (0~45 min, 5 minutes per step) |
Pressure Compensate | Yes | Equivalent (Yes) |
Altitude Compensate | Yes | Equivalent (Yes) |
Automatically Titrates Pressure in APAP mode | Yes (iCH Auto) | Identical (Yes, iCH Auto) |
Expiration Pressure Release (PVA) | Yes, Three Constant Levels (1, 2, 3 cmH2O) | Identical to Predicate 2 (K112079) (Yes, Three Constant Levels (1, 2, 3 cmH2O)) |
Design Verification Tests Performed:
- Safety and EMC: According to iCH CPAP 9S-007XXX series (K120035) verification procedures, including FDA reviewer guidance 638.pdf, IEC 60601-1 & IEC 60601-1-2.
- FDA Draft Reviewer Guidance for Ventilators (July 1995)
- FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 11, 2005)
- Side-by-side waveform testing: At various pressure and frequency levels with the predicate device(s).
- Algorithm analysis (for PVA):
- Step function
- PVA waveform with different breathing frequencies and flow volumes
- PVA feature handling conditions of disordered breathing (apneas and hypopneas)
- PVA waveform upper and lower pressure control
- PVA pressure average and tolerance error
- Performance characteristics of PVA
2. Sample Size Used for the Test Set and Data Provenance
This information is not provided in the document. The "test set" here refers to the engineering and algorithm verification tests, not a clinical trial with human subjects. The data provenance would be from internal testing, not patient data in the context of a clinical study.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
This information is not provided. The ground truth for engineering tests is typically established by comparing the device's output to expected behavior based on specifications and predicate device performance, often using calibrated instruments.
4. Adjudication Method for the Test Set
This information is not provided. This refers to clinical adjudication, which is not described for these engineering/algorithm verification tests.
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
A Multi-Reader Multi-Case (MRMC) comparative effectiveness study is not mentioned and is not applicable to this type of device (CPAP machine for treating OSA) or its regulatory submission, which focuses on device functionality and substantial equivalence. This device does not involve "human readers" interpreting medical images or data with AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
Yes, an algorithmic analysis was performed for the Pressure Variation Algorithm (PVA). The document states:
- "Algorithm analysis; by comparing the test items as below:
- a. Step function
- b. PVA waveform with different breathing frequencies and flow volumes
- c. PVA feature handling conditions of disordered breathing (apneas and hypopneas)
- d. PVA waveform upper and lower pressure control
- e. PVA pressure average and tolerance error
- f. Performance characteristics of PVA"
This constitutes a standalone (algorithm-only) assessment of the PVA's expected behavior. However, it's an engineering verification, not a clinical standalone performance study.
7. The Type of Ground Truth Used
For the engineering and algorithm analysis tests, the ground truth would be based on:
- Specifications and engineering requirements: For characteristics like pressure range, increment, ramp time, etc.
- Predicate device performance: The behavior of the previously cleared XT Auto with PVA (K112079) served as the reference for the PVA algorithm's expected output.
- Physiological models/simulations: To test responses to different breathing frequencies, flow volumes, and disordered breathing conditions.
8. The Sample Size for the Training Set
This information is not applicable/provided. This device is a hardware device with an algorithm for pressure variation, not a machine learning model that requires a "training set" in the conventional sense of AI/ML software. The algorithm is stated to be "the same algorithm of XT Auto with PVA 9S-005720 (K112079)," implying it was previously developed and validated.
9. How the Ground Truth for the Training Set was Established
This information is not applicable/provided for the reasons mentioned in point 8.
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