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510(k) Data Aggregation
(277 days)
MyndMove and MyndMove 2.0 are electrical stimulation devices indicated for the following uses:
Functional electrical stimulation (FES)
Improvement of arm and hand function and active range of motion in patients with hemplegia due to stroke or upper limb paralysis due to C3-T1 spinal cord injury.
NeuroMuscular Electrical Stimulation (NMES) for general rehabilitation for:
- · maintenance and/or increase of arm and hand range of motion,
- · prevention and/or retardation of disuse atrophy,
- · increase in local blood circulation,
- · reduction in muscle spasm, and
- · re-education of muscles.
MyndMove and MyndMove 2.0 therapies can only be administered by Occupational or Physical Therapy professionals that have completed MyndMove training by MyndTec on the use of the MyndMove 2.0 Systems.
The MyndMove and MyndMove 2.0 Systems are neuromodulation devices that deliver short electrical pulses to stimulate muscle contractions and enhance motor recovery following Stroke or Spinal Cord Injury. The MyndMove and MyndMove 2.0 systems comprise the Stimulator device, stimulation electrodes and cables, hand and foot switches, and integrated software.
The Functional Electrical Stimulators in the MyndMove 2.0 are eight-channel devices with a touch screen user interface (UI). The Stimulator software allows the User to choose from a number of pre-programmed stimulation protocols, to customize the stimulation intensities for each patient, and to document the treatments provided.
Each MyndMove/MyndMove 2.0 Stimulator is connected, via an IEEE 802.11 a/b/g/n wireless radio adapter, to a cloud-based backend data management system. The primary function of the backend is to manage the various elements of the MyndMove 2.0 ecosystem including but not limited to patient unique IDs and prescriptions, therapist profiles and stimulation protocols.
MyndMove and MyndMove 2.0 use surface electrical stimulation to produce muscle contractions in different combinations to achieve a wide range of reaching and grasping functions. To achieve these movements, the single use electrodes are placed in various combinations on the surface of muscles in the arm and hand.
MyndMove and MyndMove 2.0 are based on advanced functional electrical stimulation (FES) principles designed to promote neuroplasticity by influencing the efferent and afferent pathways. Proper sequencing of the muscle contractions as per the MyndMove or MyndMove 2.0 protocols achieve a wide range of functions. During the delivery of MyndMove 2.0 therapy, the patient executes functional tasks with assistance from the MyndMove/MyndMove 2,0 device. The patient attempts to perform the movement and is then assisted to complete the movement when the therapist activates the MyndMove 2.0 stimulation protocol, which generates bursts of short electrical pulses, using surface electrodes, to produce muscle contraction. In this manner, the patient gets both efferent and afferent input as they are actively attempting a movement. Non-damaged pathways can be activated and non-damaged areas of the central nervous system can be trained to substitute for injured areas.
The provided text is a 510(k) summary for the MyndMove and MyndMove 2.0 electrical stimulation devices. It aims to demonstrate substantial equivalence to previously cleared predicate devices (MyndMove K170564 and MyndMove 2.0 K212149).
The key takeaway is that no new acceptance criteria, performance studies, or clinical data were generated or required for this 510(k) submission (K233006). The submission explicitly states: "No additional non-clinical performance testing was conducted because there was no change to the hardware or software since clearances of MyndMove (K170564) and MyndMove 2.0 (K212149)."
Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" for this specific submission (K233006) refer to the previously established criteria and studies for the predicate devices. The document essentially argues that since the new submission's devices are identical in technological characteristics and therapy protocols to the cleared predicates, they inherently meet the acceptance criteria validated by the predicate studies.
However, to answer your request fully, I will extrapolate the "acceptance criteria" and "reported device performance" based on the "Substantial Equivalence Discussion" table, which compares the subject devices (MyndMove and MyndMove 2.0) to their predicates across various technical specifications. The acceptance criteria, in this context, are the specifications of the predicate devices that the subject devices are claiming to be identical to.
1. Table of Acceptance Criteria and the Reported Device Performance
Since the submission explicitly states there are no changes to the technological characteristics of MyndMove or MyndMove 2.0, the "reported device performance" for the subject devices (MyndMove and MyndMove 2.0 in K233006) is asserted to be identical to the predicate devices. The "acceptance criteria" are the specifications of the predicate devices.
| Feature / Acceptance Criteria (from Predicate Device) | Reported Device Performance (MyndMove & MyndMove 2.0 in K233006) | SE Comparison |
|---|---|---|
| Indications for Use: FES for improvement of arm/hand function and active ROM in hemiplegia (stroke) or upper limb paralysis (C3-T1 SCI). NMES for general rehabilitation (maintenance/increase ROM, prevention disuse atrophy, increase local blood circulation, reduction muscle spasm, re-education muscles). Administered by trained PT/OT professionals. | Identical to Predicate | Similar (minor wording change for NMES definition) |
| Anatomical Sites for Stimulation (Upper Limb): Extensor Digitorum, Extensor Carpi Radialis & Ulnaris, Thenar Eminence (Opponens Pollicis Brevis, Flexor Pollicis Brevis & Abductor Pollicis Brevis), Flexor Digitorum Superficialis and Profundus, Biceps, Triceps, Posterior Deltoid, Middle Deltoid, Anterior Deltoid, Pectoralis Major, 1st, 2nd, and 3rd Lumbricals, 2nd Dorsal Interosseous, Serratus Anterior, Lower Trapezius, Upper Trapezius (Scapula). | Identical to Predicate | Identical |
| Where Used: MyndMove: clinical setting only. MyndMove 2.0: clinical setting and home use by qualified user. | Identical to Predicate | Identical |
| Regulated current or regulated voltage? Current Regulated | Current Regulated | Identical |
| Software/firmware/microprocessor control? Yes | Yes | Identical |
| Automatic overload trip? Yes | Yes | Identical |
| Automatic no-load trip? Yes | Yes | Identical |
| Automatic shut off? Yes | Yes | Identical |
| User override control? Yes | Yes | Identical |
| Indicator display: Yes (On/off status, Low battery, Voltage/current level) | Yes | Identical |
| Timer range (minutes): Max duration of stimulation program = 120 minutes (configurable in the backend). | Max duration of stimulation program = 120 minutes (configurable in the backend). | Identical |
| Compliance with voluntary standards: MyndMove: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-10. MyndMove 2.0: ANSI AAMI ES 60601-1, IEC 60601-1-2, IEC 60601-2-10. | Identical to Predicate | Identical |
| Compliance with 21 CFR 898? Yes | Yes | Identical |
| Power Sources: MyndMove: Mains OR Rechargeable Li-Ion Battery (specified specs). MyndMove 2.0: AHM100PS24C2-8 manufactured by XP-Power (specified specs), Tripp Lite P012-006. | Identical to Predicate | Identical |
| Method of line current isolation: Galvanic Isolation (transformer) 4000 VAC | Galvanic Isolation (transformer) 4000 VAC | Identical |
| Normal condition (uA) (Leakage): Earth Leakage: < 500 uA, Lead to Ground: < 100 uA | Earth Leakage: < 500 uA, Lead to Ground: < 100 uA | Identical |
| Single fault condition (uA) (Leakage): Earth Leakage: < 1000 uA, Lead to Ground: < 500 uA, Patient on Mains: < 5000 uA | Earth Leakage: < 1000 uA, Lead to Ground: < 500 uA, Patient on Mains: < 5000 uA | Identical |
| Average DC current through electrodes when device is on but no pulses are being applied (uA): Patient auxiliary current: Normal condition: < 100 uA, Single fault condition: < 500 uA | Patient auxiliary current: Normal condition: < 100 uA, Single fault condition: < 500 uA | Identical |
| Number of output modes (stimulation protocols): MyndMove: Two Modes (Biphasic Symmetric, Biphasic Asymmetric). MyndMove 2.0: Biphasic Asymmetric. | Identical to Predicate | Identical |
| Number of output channels: 8 | 8 | Identical |
| Synchronous or alternating? Asynchronous (channels are staggered) | Asynchronous (channels are staggered) | Identical |
| Method of channel isolation: Galvanic isolation (transformer): 1500VAC/3kV DC | Galvanic isolation (transformer): 1500VAC/3kV DC | Identical |
| Weight (Ibs., oz.): 14lbs 6oz. | 14lbs 6oz. | Identical |
| Dimensions (in.) [W x H x D] (including accessories): MyndMove: Stimulator: 9.0 in x 4.3 in x 9.8 in. MyndMove 2.0: Stimulator: L 33 cm x W 25 cm x H 13.5 cm. | Identical to Predicate | Identical |
| Housing materials and construction: Enclosure = Lexan PCB HPX4R, Plastic Bezel = ABS Plastic, Rubber Membrane = Silicone. | Identical to Predicate | Identical |
| Additional Features: Timing of stimulation controlled by user via hand or foot switch. | Identical to Predicate | Identical |
| Design and Human Factors: FES, Single Use Gel Electrodes, 8 stimulation channels (up to 16 electrodes), Controlled by embedded touchscreen GUI and hand/foot switches, Preprogrammed stimulation protocols, No fitting required, instructions for electrode placement included, Used by Clinician Only. | Identical to Predicate | Identical |
| Biphasic Symmetrical Output Mode (MyndMove only - MyndMove 2.0 N/A): | ||
| Waveform: Balanced Biphasic Symmetrical | Balanced Biphasic Symmetrical | Identical |
| Shape: Rectangular | Rectangular | Identical |
| Max Output Voltage (+/- 10%) @ 500, 2k, 10kohms: 160V | 160V | Identical |
| Max Output Current (+/- 10%) @ 500, 2k, 10kohms: 20mA (500/2k), 16mA (10k) | 20mA (500/2k), 16mA (10k) | Identical |
| Pulse width: Positive: 150-400 us, Negative: 150-400 us | Positive: 150-400 us, Negative: 150-400 us | Identical |
| Frequency: 1Hz or 40Hz | 1Hz or 40Hz | Identical |
| Symmetrical phases? Yes | Yes | Identical |
| Phase Duration: Positive: 150-400 us, Negative: 150-400 us | Positive: 150-400 us, Negative: 150-400 us | Identical |
| Net Charge (uC per pulse): 2.00 uC | 2.00 uC | Identical |
| Maximum Phase Charge (uC): 9.02 uC | 9.02 uC | Identical |
| Maximum Current Density (RMS) (mA/cm2): 1.36 mA/cm2 (for 1cm x 3cm electrode) | 1.36 mA/cm2 (for 1cm x 3cm electrode) | Identical |
| Maximum Power Density (W/cm2): 0.044W/cm2 | 0.044W/cm2 | Identical |
| Burst Mode (Pulses per burst, Bursts per second, Burst duration, Duty Cycle): Not Applicable, No Burst Mode | Not Applicable, No Burst Mode | Identical |
| ON Time (seconds): Not Fixed - User Controlled | Not Fixed - User Controlled | Identical |
| OFF Time (seconds): Not Fixed - User Controlled | Not Fixed - User Controlled | Identical |
| Biphasic Asymmetrical Output Mode (MyndMove & MyndMove 2.0): | ||
| Waveform: Balanced Biphasic Asymmetrical | Balanced Biphasic Asymmetrical | Identical |
| Shape: Rectangular | Rectangular | Identical |
| Max Output Voltage (+/- 10%): Positive: 160V; Negative: 40V | Positive: 160V; Negative: 40V | Identical |
| Max Output Current (+/- 10%): Positive: 20mA (500/2k), 16mA (10k); Negative: 5mA (500/2k), 4mA (10k) | Positive: 20mA (500/2k), 16mA (10k); Negative: 5mA (500/2k), 4mA (10k) | Identical |
| Pulse width: Positive: 150-400 us, Negative: 600-1600 us | Positive: 150-400 us, Negative: 600-1600 us | Identical |
| Frequency: 1Hz or 40Hz | 1Hz or 40Hz | Identical |
| Symmetrical phases? No | No | Identical |
| Phase Duration: Positive: 150-400 us, Negative: 600-1600 us | Positive: 150-400 us, Negative: 600-1600 us | Identical |
| Net Charge (uC per pulse): 1.85uC | 1.85uC | Identical |
| Maximum Phase Charge (uC): MyndMove: Positive: 9.02 uC, Negative: 8.86 uC. MyndMove 2.0: 9.02 uC | Identical to Predicate | Identical |
| Maximum Current Density (RMS) (mA/cm2): MyndMove: 1.07 mA/cm2 (for 1 cm x 3 cm electrodes). MyndMove 2.0: Values for various electrode sizes given. | Identical to Predicate | Identical |
| Maximum Power Density (W/cm2): 0.044W/cm2 | 0.044W/cm2 | Identical |
| Burst Mode (Pulses per burst, Bursts per second, Burst duration, Duty Cycle): Not Applicable, No Burst Mode | Not Applicable, No Burst Mode | Identical |
| ON Time (seconds): Not Fixed - User Controlled | Not Fixed - User Controlled | Identical |
| OFF Time (seconds): Not Fixed - User Controlled | Not Fixed - User Controlled | Identical |
Regarding the Study that Proves the Device Meets the Acceptance Criteria:
The current 510(k) (K233006) for MyndMove and MyndMove 2.0 relies entirely on the previous clearances of K170564 (MyndMove) and K212149 (MyndMove 2.0). The submission explicitly states: "No additional non-clinical performance testing was conducted because there was no change to the hardware or software since clearances of MyndMove (K170564) and MyndMove 2.0 (K212149).". This indicates that the "study" proving the device meets acceptance criteria was performed for the predicate devices. The current submission's argument is based on the substantial equivalence of the subject devices to these previously cleared predicates, meaning they share the same technological characteristics, indications for use, and therapy protocols.
Therefore, the following information relates to the predicate devices' original submissions, as K233006 did not involve new testing. This document does not provide details on the original studies for the predicate devices, but typically such studies would have addressed:
- Sample size used for the test set and the data provenance: Not provided in K233006 document. The original predicate submissions (K170564 and K212149) would have outlined any clinical studies, their sample sizes, and whether the data was retrospective or prospective, and its geographical origin.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not provided in K233006 document. If clinical performance was assessed (likely in the predicate submissions), the ground truth for patient outcomes or assessments would typically be established by qualified medical professionals (e.g., physical therapists, occupational therapists, neurologists), but the specific number and qualifications are not detailed in this current summary.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not provided in K233006 document. This would depend on the nature of any clinical studies for the predicate devices.
- 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: Not applicable or provided. These devices are functional electrical stimulators for rehabilitation, not imaging analysis tools that typically use MRMC studies with "human readers" and "AI assistance." The "assistance" is the stimulation aiding patient movement, not an AI interpreting medical images.
- If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable in the AI sense. The device requires human professionals (Occupational or Physical Therapy professionals) to administer the therapy, making it a human-in-the-loop system. There's no "algorithm-only" performance for the therapeutic effect. However, the device's software and hardware components would have undergone standalone verification and validation to ensure they meet their design specifications and safety standards as detailed under "Summary of Non-Clinical Testing" (e.g., IEC 62304 for software life cycle processes).
- The type of ground truth used (expert consensus, pathology, outcomes data, etc): Not explicitly stated for the predicate studies in K233006. For an FES/NMES device, ground truth for clinical effectiveness would typically involve outcomes data such as changes in objective measures of arm/hand function (e.g., Fugl-Meyer Assessment, Action Research Arm Test), active range of motion, muscle strength, and patient-reported outcomes, as assessed by trained therapists or clinicians.
- The sample size for the training set: Not provided in K233006 document. If any machine learning components were involved in the development of the predicate devices (which is typical for "coded therapeutic algorithmic protocols"), a training set would have been used. This summary does not give such details.
- How the ground truth for the training set was established: Not provided in K233006 document. Similar to point 8, this information would be specific to the development of the predicate devices.
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