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510(k) Data Aggregation

    K Number
    K202789
    Date Cleared
    2021-02-23

    (154 days)

    Product Code
    Regulation Number
    892.5050
    Why did this record match?
    Reference Devices :

    K071938, K091179, K110730, K132971, K151233, K183037

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

    The Monaco system is used to make treatment plans for patients with prescriptions for external beam radiation therapy. The system calculates dose for photon, proton, and electron treatment plans and displays, on-screen and in hard-copy, two- or threedimensional radiation dose distributions inside patients for given treatment plan setups.

    The Monaco product line is intended for use in radiation treatment planning. It uses generally accepted methods for:

    • · contouring
    • · image manipulation
    • · simulation
    • · image fusion
    • · plan optimization
    • QA and plan review
    Device Description

    Monaco is a radiation treatment planning system that first received FDA clearance in 2007 (K071938). The modified system received clearance in 2009. when Volumetric Modulated Arc Therapy (VMAT) planning capability was added (K091179), again when Dynamic Conformal Arc planning was added (K110730), and electron planning, support for stereotactic cones, and SUV calculation were added (K132971). Specialty image creation was added in 2015 (K151233), and adaptive planning and dose calculation in the presence of a magnetic field (e.g., MR-Linac) was added in 2018 (K183037). A 510(k) was filed in 2017 for the addition of carbon ion planning. The 510(k) was withdrawn because there was no hardware cleared for the US market capable of delivering carbon ion plans. Monaco's carbon ion planning functionality remains licensed off and inaccessible to US users.

    The Monaco system accepts patient imaging data and "source" dosimetry data from a linear accelerator. The system then permits the user to display and define (contour) the target volume to be treated and critical structures which must not receive above a certain level of radiation on these diagnostic images.

    Based on the prescribed dose, the user, a Dosimetrist or Medical Physicist, can create multiple treatment scenarios involving the number, position(s) and energy of radiation beams and the use of a beam modifier (MLC, block, etc.) between the source of radiation and the patient to shape the beam. The Monaco system then produces a display of radiation dose distribution within the patient, indicating doses to the target volume and surrounding structures. The "best" plan satisfying the clinican prescription is then selected, one that maximizes dose to the target volume while minimizing dose to surrounding healthy volumes.

    Monaco 6.00 supports Proton Pencil Beam Scanning (Proton PBS) planning for IBA Proteus®ONE and Proteus®PLUS delivery systems (Ion Beam Applications S.A.).

    AI/ML Overview

    The provided text is a 510(k) summary for the Elekta Monaco RTP System. It describes the device, its intended use, and a comparison to predicate devices, but it explicitly states that "Clinical trials were not performed as part of the development of this product. Clinical testing on patients is not advantageous in demonstrating substantial equivalence or safety and effectiveness of the device since testing can be performed such that no human subjects are exposed to risk. Validation testing involved simulated clinical workflows using actual patient data, such as patient images. Pre-defined pass/fail criteria were also equivalent to that of the previous version of Monaco."

    Therefore, I cannot provide a detailed answer to your request regarding acceptance criteria and a study proving the device meets them in the way you've outlined, as there was no clinical study (MRMC, standalone, etc.) involving human readers or a traditional test set/ground truth establishment as would be done for an AI-based diagnostic device.

    The study referenced is a non-clinical verification study that focuses on software functionality, safety, and effectiveness compared to an existing predicate device, primarily through regression testing and verification of new functionalities. The acceptance criteria are "pre-defined pass/fail criteria" that were equivalent to those used for the previous version of Monaco.

    However, based on the information provided, I can infer and summarize what was done:

    1. A table of acceptance criteria and the reported device performance:

    The document broadly states that "Pre-defined pass/fail criteria were also equivalent to that of the previous version of Monaco." and "Conformity to the same pass/fail criteria as the predicate version of Monaco indicated that Monaco 6.00 was substantially equivalent in safety and effectiveness."

    While specific numeric acceptance criteria and performance metrics are not detailed in this summary, the overall acceptance criterion was Substantial Equivalence to the predicate devices. The performance reported is that "Monaco 6.00 was deemed safe and effective for its intended use" based on the non-clinical testing.

    Acceptance Criteria (Internal Software Validation/Verification)Reported Device Performance (Summary)
    Equivalence to previous Monaco version's pass/fail criteriaDeemed safe and effective, and substantially equivalent
    Verification of new product functionality (e.g., Proton PBS)"System is working as designed"
    Risk mitigations functioning as intendedEnsured continued safety and effectiveness
    Regression tests to ensure continued safety and effectivenessEnsured continued safety and effectiveness for existing functionality
    Conformity to FDA Quality System Regulation (21 CFR §820)Met regulations
    Conformity to ISO 13485 Quality Management System standardMet standards
    Conformity to IEC 62304 Software Life Cycle standardMet standards
    Conformity to ISO 14971 Risk Management StandardMet standards

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: The document mentions "Over 600 test procedures were executed" and "Validation testing involved simulated clinical workflows using actual patient data, such as patient images." The exact number of patient datasets or specific test cases within those 600 procedures is not specified.
    • Data Provenance: "actual patient data, such as patient images." No specific country of origin is mentioned, but "simulated clinical workflows" suggests internally generated or existing de-identified data. The testing was retrospective in the sense that it used pre-existing patient data for simulation, not prospective patient enrollment.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • This wasn't a ground truth establishment study for a diagnostic AI. The "ground truth" for this system's validation was primarily the expected output of the algorithms (e.g., dose calculations, plan optimizations) as per documented specifications and comparisons to known good results from the predicate device.
    • The document states that "Once completed, plans are reviewed and approved by qualified clinicians and may be subject to quality assurance practices before treatment actually takes place." This implies that the system is used by "Dosimetrist or Medical Physicist" and reviewed by "qualified clinicians" in a clinical setting, but these roles were not part of a formal "ground truth" establishment for the validation study itself.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    • Not applicable. This was a software verification and validation against specified requirements and predicate performance, not a clinical adjudication of diagnostic findings.

    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:

    • No MRMC comparative effectiveness study was performed. The document explicitly states: "Clinical trials were not performed as part of the development of this product." and "Clinical testing on patients is not advantageous in demonstrating substantial equivalence or safety and effectiveness of the device since testing can be performed such that no human subjects are exposed to risk."

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • The testing described is essentially a form of "standalone" algorithm verification in a simulated environment, focused on the software's functional correctness for tasks like dose calculation and plan optimization, rather than a diagnostic AI's performance. The product itself is a "Radiation Treatment Planning System," which is inherently a human-in-the-loop device, where the software outputs are reviewed and approved by clinicians before implementation. The verification ensured the software's outputs were correct according to its specifications and predicate performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The "ground truth" for this validation was primarily derived from:
      • Validated algorithms/physical models: For dose calculation, the "ground truth" is based on established physics principles and validated dose calculation algorithms (Monte Carlo, Collapsed Cone, Pencil Beam).
      • Predicate device performance: Functional equivalence and similar calculation results to the previously cleared Monaco RTP System (K190178) and RayStation 8.1 (K190387).
      • Pre-defined pass/fail criteria: These would be based on engineering specifications, clinical requirements for accuracy in dose distribution, and comparison to known good results for test cases.
      • "Simulated clinical workflows using actual patient data": This implies that for these simulated workflows, the expected correct outcome (e.g., the accurate dose distribution for a given patient anatomy and treatment plan) served as the reference.

    8. The sample size for the training set:

    • This device is not an AI/ML model that undergoes a "training" phase in the typical sense (i.e., learning from annotated data). It's a software system built on established algorithms for radiation treatment planning. Therefore, there is no "training set" as would be applicable to a deep learning model.

    9. How the ground truth for the training set was established:

    • Refer to point 8. Not applicable for this type of device.
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    K Number
    K190178
    Manufacturer
    Date Cleared
    2019-03-29

    (56 days)

    Product Code
    Regulation Number
    892.5050
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K071938, K091179, K110730, K132971, K151233, K183037

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

    The Monaco system is used to make treatment plans for patients with prescriptions for external beam radiation therapy. The system calculates dose for photon and electron treatment plans and displays, on-screen and in hard-copy, two- or three-dimensional radiation dose distributions inside patients for given treatment plan set-ups.

    The Monaco product line is intended for use in radiation treatment planning. It uses generally accepted methods for:

    · contouring

    • · image manipulation
    • · simulation
    • · image fusion
    • plan optimization
    • · QA and plan review
    Device Description

    Monaco is a radiation treatment planning system that first received FDA clearance in 2007 (K071938). The modified system received clearance in 2009, when Volumetric Modulated Arc Therapy (VMAT) planning capability was added (K091179), again when Dynamic Conformal Arc planning was added (K110730), and electron planning, support for stereotactic cones, and SUV calculation were added (K132971). Specialty image creation was added in 2015 (K151233), and adaptive planning and dose calculation in the presence of a magnetic field (e.g., MR-Linac) was added in 2018 (K183037). A 510(k) was filed in 2017 for the addition of carbon ion planning. The 510(k) was withdrawn because there was no hardware cleared for the US market capable of delivering carbon ion plans. Monaco's carbon ion planning functionality remains licensed off and inaccessible to US users.

    The Monaco system accepts patient imaging data and "source" dosimetry data from a linear accelerator. The system then permits the user to display and define (contour) the target volume to be treated and critical structures which must not receive above a certain level of radiation on these diagnostic images.

    Based on the prescribed dose, the user, a Dosimetrist or Medical Physicist, can create multiple treatment scenarios involving the number, position(s) and energy of radiation beams and the use of a beam modifier (MLC, block, etc.) between the source of radiation and the patient to shape the beam. The Monaco system then produces a display of radiation dose distribution within the patient, indicating doses to the target volume and surrounding structures. The "best" plan satisfying the clinican prescription is then selected, one that maximizes dose to the target volume while minimizing dose to surrounding healthy volumes.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study information for the Monaco RTP System based on the provided text:

    Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Functional/Technological)Reported Device Performance (Monaco with new features)
    ContouringYes
    Dose CalculationYes
    Plan OptimizationYes
    Image Manipulation & FusionYes
    CT SimulationYes
    QA/Plan ReviewYes
    Dose Calculation AlgorithmsMonte Carlo (electron & photon), Collapsed Cone (photon), Pencil Beam (optimization only), GPUMCD for MR-linac
    Calculates dose for MR-Linac (including magnetic field, coils & cryostat)Yes
    Adaptive therapy featuresYes
    Calculation and display of standardized uptake valueYes
    Local Biological Measure OptimizationYes
    Support for various treatment aidsYes
    Support for Dynamic Delivery MethodsYes
    Operating SystemWindows
    DICOM RT SupportYes
    Modalities Supported: Full RTP workflow (Photon, Electron)Photon, Electron
    Modalities Supported: Partial workflow (Photon, Electron, Proton)Photon, Electron, Proton
    Support for brachytherapyNo
    Interoperable with OIS systemYes, including support for prescribed relative offset (PRO)
    Beam modelingBeam modeling is performed by Elekta personnel. New standardized beam models are provided for some Elekta linac energy options, and absolute dose calibration will be performed by users.
    Conformity to pre-defined pass/fail criteria (equivalent to K183037)Confirmed. The product was deemed substantially equivalent and fit for clinical use.
    Functionality as designed, including new features, risk mitigations, and existing featuresVerified by over 600 test procedures.

    Study Information:

    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: Not explicitly stated as a number of cases or patients. The validation testing involved "simulated clinical workflows using actual patient data, such as patient images."
      • Data Provenance: "Actual patient data, such as patient images." The country of origin is not specified, but the context of an FDA submission implies a focus on data relevant to the U.S. market, though not exclusively. The study was retrospective in the sense that it used pre-existing "actual patient data."
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This information is not provided in the document. The adjudication of ground truth for the test set is not explicitly detailed.
    3. Adjudication method for the test set:

      • The document states that plans are "reviewed and approved by qualified clinicians and may be subject to quality assurance practices before treatment actually takes place." However, for the specific test set used in validation, the adjudication method (e.g., 2+1, 3+1 consensus) is not explicitly described. The testing involved "pre-defined pass/fail criteria" that were "equivalent to that of the predicate, K183037."
    4. 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 was not performed. The device is a treatment planning system, not an AI-assisted diagnostic tool for human readers in the traditional sense discussed in MRMC studies.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • Yes, the primary validation was effectively a standalone performance evaluation of the software. The document states: "Verification tests were written and executed to ensure that the system is working as designed. Over 600 test procedures were executed, including tests to verify requirements for new product functionality, tests to ensure that risk mitigations function as intended, and regression tests to ensure continued safety and effectiveness of existing functionality." This describes an algorithm-only evaluation against predefined criteria.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The "ground truth" for the test set verification was based on pre-defined pass/fail criteria and ensuring the system's calculations and functionality matched expectations established by the predicate device (K183037) and internal Elekta requirements. It also relied on "simulated clinical workflows using actual patient data" to ensure the system produced expected dose distributions and plan outputs. It is not framed as comparing to pathology or long-term outcomes data, but rather the accurate computation and display of dose distributions as per established physics and clinical planning principles.
    7. The sample size for the training set:

      • The document does not specify a distinct "training set" for the Monaco RTP System. As a radiation treatment planning system, it relies on physics models and algorithms rather than machine learning models that typically require a training set in the AI sense. The development likely involved extensive testing and calibration against known physics principles and clinical data, which is distinct from a machine learning training set.
    8. How the ground truth for the training set was established:

      • Since a distinct "training set" in the machine learning context is not mentioned, the concept of establishing ground truth for it is not applicable based on the provided text. The accuracy of the system is established through rigorous verification against physics models, calculations, and clinical expectations, rather than learning from a labeled training dataset.
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    K Number
    K151233
    Device Name
    Monaco
    Date Cleared
    2015-07-07

    (60 days)

    Product Code
    Regulation Number
    892.5050
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K071938, K091179, K110730, K132971

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

    The Monaco system is used to make treatment plans with prescriptions for external beam radiation therapy. The system calculates dose for photon and electron treatment plans and displays, on-screen and in hard-copy, two- or three-dimensional radiation dose distributions inside patients for given treatment plan set-ups.

    The Monaco product line is intended for use in radiation treatment planning. It uses generally accepted methods for:

    • contouring
    • image manipulation
    • simulation
    • image fusion
    • plan optimization
    • QA and plan review
    Device Description

    Monaco is a radiation treatment planning system that first received FDA clearance in 2007 (K071938). The modified system received clearance in 2009, when Volumetric Modulated Arc Therapy (VMAT) planning capability was added (K091179), when Dynamic Conformal Arc planning was added (K110730), and most recently when the system's intended use was expanded to include electron treatment planning, among other changes (K132971). The Monaco system accepts patient diagnostic imaging data and "source" dosimetry data from a linear accelerator. The system then permits the user to display and define (contour) the target volume to be treated and critical structures which must not receive above a certain level of radiation on these diagnostic images.

    Based on the prescribed dose, the user, a Dosimetrist or Medical Physicist, can create multiple treatment scenarios involving the number, position(s) and energy of radiation beams and the use of beam modifiers between the source of radiation and the patient to shape the beam. The Monaco system then produces a display of radiation dose distribution within the patient, indicating doses to the target volume and surrounding structures. The "best" plan satisfying the prescription is then selected, one that maximizes dose to the target volume while minimizing dose to surrounding healthy volumes. The Monaco system supports 3D conformal planning, IMRT, and Dynamic Conformal. It supports inverse and forward planning workflows.

    AI/ML Overview

    The provided text describes the Monaco RTP System, a medical device for radiation treatment planning. It includes information on its intended use, technological characteristics, and a comparison with predicate devices. However, the document does not contain specific acceptance criteria, a detailed study proving the device meets acceptance criteria, or information on ground truth establishment, sample sizes for training/test sets, expert qualifications, or adjudication methods in the manner typically expected for AI/ML device submissions.

    The document states:

    • Clinical trials were not performed.
    • Validation testing involved simulated clinical workflows.
    • Over 600 test procedures were executed (verification tests) to ensure the system works as designed, including new functionality, risk mitigations, and regression tests.

    Therefore, most of the requested information cannot be extracted from this document as it pertains to a different type of device (a treatment planning system, not an AI/ML diagnostic aid) and an earlier regulatory submission context where such detailed performance studies for AI/ML were not standard.

    Here's a breakdown of what can be extracted and what cannot:

    1. A table of acceptance criteria and the reported device performance:

    This document does not present quantitative acceptance criteria or corresponding reported device performance metrics like sensitivity, specificity, or AUC, which are common for AI/ML devices. Instead, it states that "Monaco passed testing and was deemed safe and effective for its intended use." The "performance" described is in terms of functionality and passing verification tests.

    Acceptance Criteria (Implied)Reported Device Performance
    System works as designedPassed over 600 test procedures, including new functionality, risk mitigations, and regression tests. Deemed safe and effective for its intended use.
    Functionality (e.g., contouring, dose calculation, plan optimization, image manipulation & fusion, CT simulation, QA/Plan Review)All listed functionalities are supported and passed verification tests.
    Substantial equivalence to predicate deviceDemonstrated via comparison table (Monaco is substantially equivalent to K132971 and AdvantageSim MD K132944 in intended use and safety/effectiveness).

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: Not specified. The document mentions "over 600 test procedures" but doesn't detail the number of cases or data points used within these procedures.
    • Data Provenance: Not specified. The testing involved "simulated clinical workflows," but the origin (e.g., country of origin of data, retrospective or prospective) of the data used in these simulations is not mentioned.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This information is not provided. The testing described is verification-based ("system is working as designed"), not ground truth establishment by experts for specific diagnostic or prognostic outcomes.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    Not specified.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and if so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    No MRMC study was performed or mentioned. The device is a treatment planning system, not an AI-assisted diagnostic device, and clinical trials were explicitly stated as not being performed.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    The device's performance is described as standalone in the sense that its functional verification tests ensure it performs its calculations and operations correctly. However, it's explicitly stated that "Monaco does not directly control the linear accelerator that delivers the radiation. Once completed, plans are reviewed and approved by qualified clinicians and may be subject to quality assurance practices before treatment actually takes place." This implies that the system is always used with human oversight, but its core calculation and planning functionalities are "standalone" in their execution. The document does not describe specific "standalone performance" metrics in the context of an AI/ML algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    The concept of "ground truth" as typically applied to diagnostic AI/ML devices based on expert consensus or pathology is not present in this document. The "truth" for this device's performance would be the accuracy of its physical dose calculations and the correct execution of its planning algorithms against established physics models and pre-defined test cases, rather than clinical outcomes or diagnostic interpretations.

    8. The sample size for the training set:

    The document does not refer to a "training set" as this is not an AI/ML device in the modern sense that learns from data. It's a deterministic software system.

    9. How the ground truth for the training set was established:

    Not applicable, as there is no "training set."


    Summary of what is available from the document:

    The Monaco RTP System is a radiation treatment planning system. Its regulatory submission (K151233) describes its intended use, technological characteristics, and compares it to predicate devices (Monaco K132971, AdvantageSim MD K132944) to demonstrate substantial equivalence.

    Device Performance and Testing:

    • Type of Study: Verification testing and simulated clinical workflows.
    • Number of Tests: Over 600 test procedures were executed.
    • Purpose of Tests: To verify requirements for new product functionality, ensure risk mitigations function as intended, and regression tests to ensure continued safety and effectiveness of existing functionality.
    • Outcome: "Monaco passed testing and was deemed safe and effective for its intended use."
    • Clinical Trials: Explicitly stated as not performed because "Clinical testing on patients is not advantageous in demonstrating substantial equivalence or safety and effectiveness of the device since testing can be performed such that no human subjects are exposed to risk."
    • Human-in-the-Loop: The system's plans are always "reviewed and approved by qualified clinicians and may be subject to quality assurance practices before treatment actually takes place."
    • "Level of Concern": Classified as "major level of concern" because "should a flaw in the treatment plan escape the notice of the qualified professionals using the Monaco system, serious injury or death could result."
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