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510(k) Data Aggregation

    K Number
    K222728
    Date Cleared
    2023-05-17

    (251 days)

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

    K181145

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

    The Radiation Planning Assistant (RPA) is used to plan radiotherapy treatments with cancers of the head and neck, cervix, breast, and metastases to the brain. The RPA is used to plan external beam irradiation with photon beams using CT images. The RPA is used to create contours and treatment plans that the user imports into their own Treatment Planning System (TPS) for review, editing, and re-calculation of the dose.

    Some functions of the RPA use Eclipse 15.6. The RPA is not intended to be used as a primary treatment planning system. All automatically generated contours and plans must be imported into the user's own treatment planning system for review, edit, and final dose calculation.

    Device Description

    The Radiation Planning Assistant (RPA) is a web-based contouring and radiotherapy treatment planning software tool that incorporates the basic radiation planning functions from automated contouring, automated planning with dose optimization, and quality control checks. The system is intended for use for patients with cancer of the head and neck, cervix, breast, and metastases to the brain. The RPA system is integrated with the Eclipse Treatment Planning System v15.6 software cleared under K181145. The RPA radiation treatment planning software tool was trained against hundreds / thousands of CT Scans of normal and diseased tissues from patients receiving radiation for head and neck, cervical, breast, and whole brain at MD Anderson Cancer Center.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Radiation Planning Assistant (RPA) device:


    1. Table of Acceptance Criteria and Reported Device Performance

    Criteria NumberCriteriaReported Device Performance (Overall, across all sites/anatomical locations where available)
    1.Assess the safety of using the RPA plan for normal structures for treatment planning by comparing the number of patient plans that pass accepted dosimetric metrics when assessed on the RPA contour with the number that pass when assessed on the clinical contour. The difference should be 5% or less. When there are multiple metrics for a single structure at least one should pass this criterion.Cervix: 0.7
    Head & Neck: 25th percentile for recall > 0.7
    5.Assess the quality of body contouring generated by the RPA by comparing primary and secondary body contours generated by the RPA with manual body contours. Surface DSC (2mm) should be greater than 0.8 for 95% of the CT scans.Cervix: Surface DSC > 0.8 for 95% of CT scans
    Chest Wall: Surface DSC > 0.8 for 95% of CT scans
    Head & Neck: Surface DSC > 0.8 for >95% of CT scans
    Whole Brain: > 0.8 difference between RPA Plan and Clinical Plan for all assessments.
    6.Assess the ability of the RPA to accurately identify the marked isocenter. This is achieved by comparing the automatically generated isocenters with manually generated ones. 95% of automatically generated marked isocenters (primary and verification approaches) should agree with manually generated marked isocenters within 3mm in all orthogonal directions (AP, lateral, cranial-caudal).Cervix:
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    K Number
    K210645
    Device Name
    RayStation 10.1
    Date Cleared
    2021-06-29

    (118 days)

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

    K203172, K181145

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

    RayStation is a software system for radiation therapy and medical oncology. Based on user input, RayStation proposes treatment plans. After a proposed treatment plan is reviewed and approved by authorized intended users, RayStation may also be used to administer treatments.

    The system functionality can be configured based on user needs.

    Device Description

    RayStation is a treatment planning system for planning, analysis and administration of radiation therapy and medical oncology treatment plans. It has a modern user interface and is equipped with fast and accurate dose and optimization engines.

    RayStation consists of multiple applications:

    • The main RayStation application is used for treatment planning.
    • . The RayPhysics application is used for commissioning of treatment machines to make them available for treatment planning and used for commissioning of imaging systems.
    • . The RayTreat application is used for sending plans to treatment delivery devices for treatment and receiving records of performed treatments.
    • o The RayCommand application is used for treatment session management including treatment preparation and sending instructions to the treatment delivery devices.
    AI/ML Overview

    The provided text details the 510(k) summary for RayStation 10.1, a software system for radiation therapy and medical oncology. The document indicates that the determination of substantial equivalence to the primary predicate device (RayStation 9.1) is not based on an assessment of non-clinical performance data. Instead, it relies on the entire system verification and validation specifications and reports.

    However, the document does describe the performance data for several new features and explicitly states that these features have been "successfully validated for accuracy in clinically relevant settings according to specification" or "successfully validated according to specification." While these statements imply acceptance criteria were met, the specific numerical acceptance criteria and the reported device performance values are not explicitly provided in a comparative table format within the given text.

    Therefore, the following response will extract the implied acceptance criteria and reported performance from the descriptions provided, and note where specific numerical values are absent.


    Acceptance Criteria and Device Performance Study for RayStation 10.1

    The provided document, K210645 for RayStation 10.1, indicates that the determination of substantial equivalence to the primary predicate device (RayStation 9.1) is not based on non-clinical performance data directly comparing the existing features of 10.1 to 9.1. Instead, it relies on the comprehensive system verification and validation reports.

    However, for the new features introduced in RayStation 10.1, the document states that these features have undergone validation and met their respective specifications. While specific, quantifiable acceptance criteria and reported performance values are not presented in a direct comparative table within the provided text, the descriptions imply the following:

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

    FeatureImplied Acceptance Criteria (from text)Reported Device Performance (from text)
    Brachytherapy TG43 Dose CalculationAccurately models output from single and combined brachytherapy sources in clinical plans. All doses reported as dose-to-water (DWw).Successfully validated for accuracy in clinically relevant settings according to specification.
    Medical Oncology Dose Calculation FunctionsAppropriate for supporting medical oncology planning workflows when used by qualified users according to IFU.Validated to be appropriate for supporting medical oncology planning workflows.
    Proton Ocular Treatment Dose CalculationAccurately models proton dose calculation for ocular treatments using the single scattering (SS) delivery technique (modeled as double scattering).Successfully validated for accuracy in clinically relevant settings according to specification.
    Robust Planning of Organ MotionCorrectly generates deformed image sets to simulate organ motion and uses them for robust planning against intra-fractional or inter-fractional organ motion.Successfully validated according to specification.

    Note: The provided text does not contain specific numerical acceptance criteria (e.g., "accuracy within X%") or quantitative reported performance data for any of these features. The reported performance essentially states that the criteria were "met" or "validated."

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

    The document indicates that RayStation 10.1's test specification is a further developed version of RayStation 9.1's, supported by requirements specification. The verification activities included "User validation in cooperation with cancer clinics." However, no specific sample sizes for test sets (e.g., number of patient cases) or data provenance (e.g., country of origin, retrospective/prospective nature) are provided in the given text for any of the validations.

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

    The text mentions "User validation in cooperation with cancer clinics" but does not specify the number of experts, their qualifications, or how ground truth was established for the "test set" (if a distinct clinical test set was used for ground truth establishment).

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

    No information on adjudication methods is provided in the supplied text.

    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 text does not mention any multi-reader multi-case (MRMC) comparative effectiveness study, nor does it discuss human readers improving with or without AI assistance. The device is a treatment planning system, and while it states it "proposes treatment plans" based on user input, it does not describe AI-assisted diagnostic or interpretation tasks. It explicitly states, "Related to machine learning, there is no change compared to the primary predicate device." suggesting limited or no direct machine learning components in the new features where such a study would typically be relevant.

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

    The validations described for brachytherapy, medical oncology, proton ocular treatment, and robust planning of organ motion appear to be standalone algorithm performance assessments against defined specifications. These validations verify the accuracy and appropriateness of the software's calculations and functionalities independently, assuming "intended qualified user" interaction for medical oncology, but not as part of a human-in-the-loop performance study.

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

    For the dose calculation features (brachytherapy, proton ocular treatment), the "ground truth" implicitly refers to theoretical models and established physical principles (e.g., accurate modeling of TG43 formalism, proton dose calculations) as compared against the output of the software. For medical oncology functions, the "ground truth" for validation appears to be whether the functions are "appropriate" for planning workflows, likely assessed against clinical guidelines or expert workflows. For robust planning of organ motion, the ground truth relates to the correct generation and application of deformed image sets according to specifications. The document does not explicitly state that ground truth was established through pathology or outcomes data.

    8. The sample size for the training set

    The document refers to the system as "built on the same software platform" and "developed under the same quality system, by the same development teams." It mentions that "related to machine learning, there is no change compared to the primary predicate device." Given this, and the nature of treatment planning software, the concept of a "training set" in the context of machine learning (e.g., for image classification or prediction models) is not directly applicable or discussed for the validations mentioned. The system's development would involve software engineering and clinical validation rather than machine learning training sets for the described functionalities.

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

    As there is no mention of a training set or machine learning components for the new features, information on how its ground truth was established is not provided.

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    K Number
    K192377
    Date Cleared
    2020-02-10

    (164 days)

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

    K173838, K181145, K181032

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

    Ethos Treatment Management is indicated for use in managing and monitoring radiation therapy treatment plans and sessions.

    Ethos Treatment Planning is indicated for use in generating and modifying radiation therapy treatment plans.

    Halcyon and Ethos Radiotherapy System are indicated for the delivery of stereotactic radiosurgery and precision radiotherapy for lesions, tumors and conditions anywhere in the body where radiation is indicated for adults and pediatric patients.

    Device Description

    Ethos Treatment Management is software designed for radiation therapy medical professionals to support them in managing radiation treatments for patients.

    Ethos Treatment Planning is software that is designed generate treatment plans, modify treatment plans, and guide users within adaptive treatment sessions.

    Halcyon and Ethos Radiotherapy System are single energy linacs designed to deliver Image Guided Radiation Therapy and radiosurgery, using Intensity Modulated and Volumetric Modulated Arc Therapy techniques. They consist of an accelerator and patient support within a radiation shielded treatment room and a control console outside the treatment room.

    AI/ML Overview

    I am sorry, but the provided text does not contain the specific information required to answer your request regarding acceptance criteria and a study proving device performance. The document describes a premarket notification for several medical devices and confirms their substantial equivalence to predicate devices, but it does not detail specific performance metrics, clinical studies, or acceptance criteria with reported device performance against those criteria.

    Therefore, I cannot provide:

    1. A table of acceptance criteria and the reported device performance.
    2. Sample size used for the test set and data provenance.
    3. Number of experts used to establish ground truth and their qualifications.
    4. Adjudication method for the test set.
    5. Whether an MRMC comparative effectiveness study was done or its effect size.
    6. Whether a standalone performance study was done.
    7. The type of ground truth used.
    8. The sample size for the training set.
    9. How the ground truth for the training set was established.

    The document mentions that "Hardware and software verification and validation testing was conducted" and "Test results showed conformance to applicable requirements specifications," but it does not provide the details of these tests or their results against specific criteria. It also states, "No animal studies or clinical tests have been included in this pre-market submission," which indicates that the information you requested about clinical performance studies is not present in this document.

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