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510(k) Data Aggregation
(149 days)
TrueDx™ hCG Early Result Pregnancy Test (Midstream & Cassette Formatographic immunoassay for qualitative detection of human chorionic (hCG) in urine, as an in aid in early detection of pregnancy, in some case as early as five (5) days before the expected period, i.e., as early as six (6) days before the day of the missed period.
VeriClear™ Early Result Pregnancy Test (Midstream & Cassette Formatographic immunoassay for qualitative detection of human chorionic (hCG) in urine, as an in aid in early detection of pregnancy, in some case as early as five (5) days before the expected period, i.e., as early as six (6) days before the day of the missed period.
TrueDX™ hCG Early Result Pregnancy Test is designed to be tested in midstream and cassette mode. Each of the devices (Cassette and Midstream), contains a pouch with the test and instructions for use. The cassette and midstream nitrocellulose test strips are contained in a plastic housing. The cassette test also contains a dropper.
TrueDX™ hCG Early Result Pregnancy Test is a qualitative lateral flow immunoassay for the detection of hCG. The device comes in two formats: Cassette and Midstream. Each device includes a pouch with the all components to perform the test, instruction for use and a desiccant package to control the moisture during the storage of the test kit. The cassette and midstream nitrocellulose test strips are mounted in a plastic housing. The cassette test, which is designed to be used as prescription use contains a dropper pipette.
The VeriClear™ Early Result Pregnancy Test and TrueDX™ hCG Early Result Pregnancy Test are the same devices, except the device names and intended use population.
The provided document is a 510(k) Summary for the TrueDX™ hCG Early Result Pregnancy Test and VeriClear™ Early Result Pregnancy Test, which are qualitative chromatographic immunoassays for the detection of human chorionic gonadotropin (hCG) in urine. The document details the device's performance characteristics, including analytical and clinical studies.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Acceptance Criteria and Reported Device Performance
The acceptance criteria are generally implied rather than explicitly stated as quantitative targets in a table within this summary document for certain aspects. However, for analytical sensitivity, a clear target is indicated. For other performance metrics, the "acceptance" is demonstrated by the reported results showing highly accurate and consistent performance, often achieving 100% agreement or detection at specified levels.
Here's a table summarizing the acceptance criteria (inferred or explicitly stated) and the reported device performance:
Acceptance Criterion (Inferred/Stated) | Reported Device Performance (Midstream and Cassette formats unless specified) |
---|---|
Analytical Performance | |
Precision/Reproducibility (Across Lots) | |
(0, 3, 5 mIU/ml hCG: 0% positive) | |
(10, 25, 50, 100 mIU/ml hCG: 100% positive) | Midstream: |
0, 3, 5 mIU/ml: 0/250 positive (0%) for all lots. | |
10, 25, 50, 100 mIU/ml: 250/250 positive (100%) for all lots. | |
Cassette: | |
0, 3, 5 mIU/ml: 0/250 positive (0%) for all lots. | |
10, 25, 50, 100 mIU/ml: 250/250 positive (100%) for all lots. | |
(8.5 mIU/ml showed ~50% positivity, as expected for a concentration near the detection limit). | |
Precision/Reproducibility (Across Operators) | |
(0, 3, 5 mIU/ml hCG: 0% positive) | |
(10, 25, 50, 100 mIU/ml hCG: 100% positive) | Midstream: |
0, 3, 5 mIU/ml: 0/150 positive (0%) for all operators. | |
10, 25, 50, 100 mIU/ml: 150/150 positive (100%) for all operators. | |
Cassette: | |
0, 3, 5 mIU/ml: 0/150 positive (0%) for all operators. | |
10, 25, 50, 100 mIU/ml: 150/150 positive (100%) for all operators. | |
(8.5 mIU/ml showed ~50% positivity, as expected). | |
Within-Lot Reproducibility | |
(0, 3, 5 mIU/ml hCG: 0% positive) | |
(10, 25, 50, 100 mIU/ml hCG: 100% positive) | All Formats (Simulate Stream, Midstream Dip, Cassette): |
0, 3, 5 mIU/ml: 20/20 negative (100%) for all. | |
10, 25, 50, 100 mIU/ml: 20/20 positive (100%) for all. | |
(8.5 mIU/ml showed ~55% positivity, as expected). | |
Analytical Sensitivity / Detection Limit | |
(Lowest concentration yielding 100% positive results should be relevant to early pregnancy claims, e.g., 10 mIU/ml) | 10 mIU/ml (lowest concentration that yields 100% positive results for both formats across lots and operators). |
Analytical Specificity (Interference) | |
(No interference from common substances at specified concentrations in negative and 10 mIU/ml hCG samples) | No interfering impact observed for all substances listed (e.g., Acetaminophen, Aspirin, Caffeine, etc.) at their highest tested concentrations, for both negative and 10 mIU/ml hCG. |
Analytical Specificity (Cross-reactivity) | |
(No cross-reactivity with hLH, hFSH, hTSH at high concentrations) | No cross-reactivity observed with 1000 mIU/ml hLH, 1000 mIU/ml hFSH, and 1000 µIU/ml hTSH for both formats. |
Cross-reactivity with Hyper-glycosylated hCG | All replicates tested with H. hCG standards at above 0.0147 µg/L (5.8 mIU/ml) yielded positive results, demonstrating expected reactivity. |
Effect of Urine pH | |
(Results not affected by pH 4.0-9.0) | Positive and negative hCG results were not affected by urine pH levels between 4.0 and 9.0. |
Effect of Urine Specific Gravity | |
(Results not affected by specific gravity 1.000-1.035) | Positive and negative hCG results were not affected by urine specific gravity concentrations between 1.000 and 1.035. |
High Dose Hook Effect | |
(No hook effect up to high hCG concentrations) | No hook effect observed at hCG concentrations up to 450,000 mIU/ml. |
Effect of hCG β-core fragment | |
(No interference from high levels of β-core fragment) | Concentration of hCG beta core fragment up to 408,000 pmole/L yielded correct results. |
Method Comparison with Predicate Device | |
(High concordance with predicate device) | 65/65 positive and 101/101 negative agreement between candidate device and predicate device (100% agreement for both positive and negative samples). |
Clinical Performance (Early Pregnancy Detection) | |
(Detection rates days before missed period consistent with claims) | -5 days before expected period: 71% detection; -1 day before expected period: 100% detection. |
Lay User Performance | |
(High agreement with professional users and correct interpretation) | Lay user vs. Professional (Actual Urine): |
Pregnant: 9/9 agreement (Midstream), 9/9 agreement (Midstream-Dip), 6/6 agreement (Cassette). | |
Non-pregnant: 101/101 agreement (Midstream), 101/101 agreement (Midstream-Dip), 102/102 agreement (Cassette). | |
Lay user vs. Professional (Spiked Urine for Analytical Sensitivity): | |
3 mIU/ml: 100% agreement (0 positives for both). | |
10 mIU/ml: 100% agreement (100% positives for both). | |
(8.5 mIU/ml agreement: 96-97%). | |
Specificity Study (False Positives in Non-Pregnant Women) | |
(No false positives in non-pregnant women across age groups) | 0 false positives out of 320 non-pregnant women (100 pre-menopausal, 111 peri-menopausal, 109 post-menopausal). |
Shelf Life | A 24-month shelf life claimed and supported by stability testing. |
2. Sample sizes used for the test set and data provenance:
- Precision/Reproducibility:
- Across Lots: 250 replicates per hCG level per lot (10 replicates/run x 5 operators x 5 days). Total of 750 replicates per hCG level for 3 lots.
- Across Operators: 150 replicates per hCG level per operator (from the above dataset).
- Within-Lot Reproducibility: 20 replicates for each hCG level.
- Analytical Sensitivity: 15 replicates per hCG concentration per lot. Total of 45 replicates per hCG concentration for 3 lots.
- Analytical Specificity (Interference): At least 2 replicates (implied by "2 different lots") per substance for negative and 10 mIU/ml hCG samples. ("All samples were tested in replicates of 5 for each format" is also stated later, suggesting maybe 5 replicates per lot per sample type.)
- Cross-reactivity: Replicates for each substance (number not explicitly stated, but "tested by two operators with two lots of the test kit for each format" implies multiple tests). For hyper-glycosylated hCG, 5 replicates per hCG concentration for 3 different lots.
- pH/Specific Gravity/Hook Effect/β-core Fragment: Replicates tested (number not always explicitly stated, but implied as sufficient for robust testing). For hook effect, 3 lots tested by 2 operators.
- Method Comparison with Predicate Device: 166 urine samples from women at physician offices.
- Clinical Samples (Early Pregnancy Detection): 616 urine samples from 56 different women.
- Lay User Study:
- Actual Urine: 218 females tested their own urine (110 Midstream, 108 Cassette). 9 pregnant, 101 non-pregnant for Midstream/Midstream-Dip; 6 pregnant, 102 non-pregnant for Cassette.
- Spiked Urine: 53 samples at each hCG level for Midstream, 57 for Midstream-Dip, and 110 for Cassette.
- Specificity Study (False Positives in Non-Pregnant Women): 320 non-pregnant women (100 pre-menopausal, 111 peri-menopausal, 109 post-menopausal).
Data Provenance:
The document does not explicitly state the country of origin for the data. The studies are described as internal performance evaluations. While patient samples were collected from "physician offices" and "women who planned to become pregnant," the document doesn't specify if these were prospective or retrospective collections, though the early pregnancy detection study following women throughout their conception cycles sounds prospective for that specific cohort. The lay user study involved participants with diverse backgrounds recruited specifically for the study, suggesting a prospective design for that component.
3. Number of experts used to establish the ground truth for the test set and their qualifications:
The document describes the device as measuring hCG levels, where hCG is a biological marker. Ground truth for hCG levels in urine samples for the analytical studies (precision, sensitivity, specificity) was established by spiking known concentrations of hCG standard traceable to the WHO 4th International Standard, or by using known negative urine samples. These are objective, quantitative measures rather than observer-dependent expert interpretations.
For the method comparison study, the predicate device was presumably used as the reference standard, and the results of both the candidate and predicate devices were compared. The text states "Urine samples were collected from 166 women at physician offices for pregnancy testing," and the samples were "masked and randomized." All samples were tested by "two different health care professionals." Their specific qualifications are not detailed beyond "health care professionals."
For the clinical sample (early pregnancy detection) study, samples were collected from women followed throughout their conception cycles. The ground truth for pregnancy status and relative timing to the expected menstrual period (EMP) would be clinical, likely based on confirmed pregnancy outcomes and menstrual cycle tracking. The document implies that the detection rate is against the true biological state rather than expert interpretation of the test result itself.
For the lay user study, professional users also tested aliquots of the same urine samples as a reference for comparison, implying their results served as a ground truth for interpretation consistency. Their qualifications are not specified beyond "professional."
For the specificity study to determine false-positive rates, an "ELISA quantitative analyzed hCG level test kit" was used as the reference method ("ground truth") to confirm hCG levels, and subjects with positive results on the new device or hCG levels >5.00 mIU/ml on ELISA were referred for "clinical confirmation of positive." This implies a multi-modal ground truth involving an objective lab assay and clinical follow-up.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
Adjudication methods (like 2+1, 3+1 for consensus readings) are typically used in image-based AI studies where human interpretation is the primary ground truth. This is an hCG urine test kit.
- For analytical studies, the "ground truth" is the known spiked concentration or the characterized negative sample. No adjudication is needed as the result is objectively positive/negative based on the strip's reaction.
- For the precision study, multiple operators tested replicates, and the results were aggregated to calculate reproducibility (e.g., % positive). This is a statistical aggregation, not adjudication.
- For the method comparison study, each sample was tested by "two different health care professionals." It's not stated whether there was an adjudication rule if their interpretations differed; given it's a qualitative test (positive/negative), disagreements would likely be rare or require re-testing/third party confirmation. The 100% agreement reported suggests no significant discrepancies needed formal adjudication.
- For the lay user study, lay user results were compared to professional user results. Discrepancies (e.g., 8 lay users positive vs. 9 professional positive for 7.0mIU/ml, or 30 vs 32 for 8.5mIU/ml) are simply reported as the difference in numbers/percentages, indicating performance deviation, not an adjudication process to force agreement.
Therefore, formal adjudication as typically understood in reader studies was not applicable or explicitly described.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and effect size:
No, an MRMC study was not done. MRMC studies are primarily for evaluating the impact of AI on human reader performance in diagnostic imaging by measuring reader accuracy with and without AI assistance across multiple cases and readers. This document describes a standalone in-vitro diagnostic (IVD) test kit, not an AI-powered diagnostic tool for human interpretation.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Yes, the device is inherently a standalone chemical assay that produces a visual result. The various analytical and clinical studies described (precision, sensitivity, specificity, early pregnancy detection with clinical samples, false-positive rate) demonstrate the "algorithm only" performance (i.e., the device's performance as an assay) without human-in-the-loop assistance influencing the outcome of the test itself. The lay user study primarily evaluates ease of use and interpretation accuracy by lay users rather than an assisted vs. unassisted performance comparison.
7. The type of ground truth used:
- Analytical Studies (Precision, Sensitivity, Specificity): Primarily known spiked concentrations of hCG standard (traceable to WHO 4th International Standard) in negative human urine, and characterized negative urine samples. This is a form of reference standard/laboratory-defined ground truth.
- Method Comparison: Comparison against a legally marketed predicate device (FIRST RESPONSE Early Result Pregnancy Test) on collected urine samples. The predicate device's result serves as the de-facto ground truth for equivalence.
- Early Pregnancy Detection Clinical Samples: Likely clinical confirmation of pregnancy (e.g., blood tests, ultrasound, follow-up) and menstrual cycle tracking for timing relative to the expected period. This is based on outcomes data/clinical truth.
- Lay User Study: Comparison against results obtained by professional users testing aliquots of the same samples (both actual and spiked urine). This is a consensus or expert interpretation ground truth for comparing interpretational consistency.
- Specificity Study (False Positives in Non-Pregnant Women): Quantitative ELISA hCG level test kit results and subsequent clinical confirmation for any elevated hCG or positive results. This combines a laboratory assay ground truth with clinical confirmation/outcomes data.
8. The sample size for the training set:
This document describes a 510(k) submission for a traditional in-vitro diagnostic test kit (lateral flow immunoassay) based on chemical reactions and visual interpretation. It is not an AI/ML-based device, and therefore, there is no "training set" in the context of machine learning. The development of such a device involves iterative R&D, chemical formulation, and design, but not data-driven algorithmic training.
9. How the ground truth for the training set was established:
As there is no AI/ML training set, this question is not applicable to the described device.
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