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510(k) Data Aggregation
(158 days)
The BrainsWay Deep TMS™ System is indicated for the treatment of depressive episodes and for decreasing anxiety symptoms for those who may exhibit comorbid anxiety symptoms in adult patients suffering from Major Depressive Disorder (MDD) and who failed to achieve satisfactory improvement from previous antidepressant medication treatment in the current episode.
The BrainsWay Deep TMS™ System enables direct non-invasive activation of deep brain structures. Transcranial magnetic stimulation (TMS) is a non-invasive technique used to apply brief magnetic pulses to the brain. The pulses are administered by passing high currents through an electromagnetic coil placed adjacent to a patient's scalp. The pulses induce an electric field in the underlying brain tissue. When the induced field is above a certain threshold and is directed in an appropriate orientation relative to the brain's neuronal pathways, localized axonal depolarizations are produced, thus activating neurons in the targeted brain structure. The BrainsWay Deep TMS™ System is composed of the following main components: Cart (TMS Neurostimulator, Cooling System, Positioning Device), and Helmet (Aiming Apparatus, Electromagnetic Coil (H7 Coil), Cap).
The provided text from the FDA 510(k) summary does not contain acceptance criteria or a study that directly proves the device meets those specific criteria in the way typically seen for AI/ML devices with quantitative performance metrics.
Instead, the document details a non-inferiority study to demonstrate that a modified version of a device (BrainsWay Deep TMS™ System with H7 Coil) is as safe and effective as a previously cleared predicate device (BrainsWay Deep TMS™ System with H1 Coil). The "acceptance criteria" in this context are implicitly that the new device performs at least as well as the predicate device within a defined non-inferiority margin for key clinical outcomes.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria (Non-inferiority Limit) | Reported Device Performance (H7 vs H1 Coil) |
---|---|
Upper limit of one-sided 95% CI for the difference in change from baseline in HDRS-21 at 6 weeks is lower than 3 (non-inferiority limit). | Upper limit of one-sided 95% CI was 1.9. |
No statistically significant difference in response rates and remission rates at week 6. | Response rates and remission rates at week 6 were not statistically significantly different. |
No statistically significant difference in the incidence of adverse events. | No statistically significant difference in the incidence of any adverse events reported. |
2. Sample size used for the test set and the data provenance
- Sample size: 169 subjects total.
- Specific breakdown by H7 and H1 coil groups is not explicitly stated, but the study was a "Randomized Controlled Trial," implying subjects were divided between these two groups.
- Data provenance: Prospective, Multicenter. Country of origin not specified, but the study was titled "Multicenter H7 vs H1 Study."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
The "ground truth" in this study relates to clinical outcomes over time (e.g., changes in HDRS-21 scores). These scores are typically assessed by trained clinicians, often psychiatrists or psychologists, but the exact number of experts or their specific qualifications for this study are not detailed in the provided text. Scores like HDRS-21 are standardized clinical assessments, not typically "established" by multiple experts for each patient like in imaging adjudication.
4. Adjudication method for the test set
Not explicitly stated. Clinical rating scales like HDRS-21 are usually administered by trained raters, potentially with inter-rater reliability checks, but a formal adjudication method like "2+1" or "3+1" is not mentioned as it would be for diagnostic imaging studies.
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, this was not an MRMC comparative effectiveness study involving human readers with or without AI assistance. It was a clinical trial comparing two different device configurations (H7 coil vs. H1 coil) for direct patient treatment. The device itself is a treatment system, not a diagnostic AI tool. Therefore, an effect size of human reader improvement with AI assistance is not applicable.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. The device is a deep transcranial magnetic stimulation (TMS) system for treating Major Depressive Disorder, not an algorithm or AI system used for diagnosis or image analysis in a standalone capacity.
7. The type of ground truth used
The ground truth used was clinical outcome data from patient assessments, specifically changes in the Hamilton Depression Rating Scale (HDRS-21) and Hamilton Anxiety Rating Scale (HARS) scores, as well as response and remission rates. These are standard measures of treatment efficacy in psychiatry.
8. The sample size for the training set
Not applicable. This device is a medical device for treatment, not an AI/ML algorithm that requires a "training set" in the conventional sense. The "study" described (CTP-0002-00) is a clinical trial to demonstrate safety and effectiveness for regulatory approval.
9. How the ground truth for the training set was established
Not applicable for the same reason as point 8.
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(127 days)
The Brainsway Deep Transcranial Magnetic Stimulation System is indicated to be used as an aid in short-term smoking cessation for adults.
The Brainsway Deep TMS System enables direct non-invasive activation of deep brain structures. Transcranial magnetic stimulation (TMS) is a non-invasive technique used to apply brief magnetic pulses to the brain. The pulses are administered by passing high currents through an electromagnetic coil placed adjacent to a patient's scalp. The pulses induce an electric field in the underlying brain tissue. When the induced field is above a certain threshold, and is directed in an appropriate orientation relative the brain's neuronal pathways, localized axonal depolarizations are produced, thus activating neurons in the targeted brain structure.
The Brainsway Deep TMS System is composed of the following main components:
- Cart
a) TMS Neurostimulator
b) Cooling System
c) Positioning Device - Helmet
a) Aiming Apparatus (i.e., ruler/grid)
b) Electromagnetic Coil (H4-Coil)
c) Cap
Based on the provided text, the device in question is the Brainsway Deep TMS System, indicated as an aid in short-term smoking cessation for adults. The document outlines a 510(k) submission, classifying it as a Class II medical device.
Crucially, the provided document explicitly states under the "Clinical Performance Data" section: "Not Applicable." This indicates that no direct clinical efficacy or performance study of the device itself (i.e., algorithm only or human-in-the-loop performance with the device) was conducted or provided for this specific 510(k) submission for the Brainsway Deep TMS System for smoking cessation.
Instead, the submission focuses on demonstrating substantial equivalence to previously cleared predicate devices by Brainsway Ltd., specifically:
- Main Predicate (K200957): Brainsway Deep TMS System for smoking cessation.
- Reference Predicate (K183303): Brainsway Deep TMS System for OCD (used to demonstrate equivalence of device modifications like the new stimulator).
The acceptance criteria and performance data provided are primarily non-clinical (bench) performance data showing that the modified Brainsway Deep TMS System performs similarly to already cleared versions. The "study that proves the device meets the acceptance criteria" in this context is the bench testing and compliance with recognized standards to demonstrate that the modifications made do not raise new safety or effectiveness concerns compared to the predicate devices.
Therefore, many of the requested details about acceptance criteria, test set sample size, expert ground truth, adjudication methods, MRMC studies, standalone performance, and ground truth for training/test sets are not applicable or not provided in this specific 510(k) summary, as the clearance relies on substantial equivalence based on technical and performance similarities to existing cleared devices, rather than new clinical efficacy demonstrations.
Given this, I will answer the questions based on the information available in the document, highlighting what is and is not present.
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a substantial equivalence submission based on non-clinical performance and a pre-existing indication, the "acceptance criteria" are not framed as specific clinical performance metrics (e.g., sensitivity, specificity for a diagnostic device) but rather as successful demonstration of technical equivalence and safety.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Non-Clinical (Bench) Performance | |
Output Waveform | Demonstrated "substantially equivalent" to the previously cleared Brainsway DTMS System (K200957) through performance testing. |
Electrical Field Spatial Distribution | Demonstrated "substantially equivalent" to the previously cleared Brainsway DTMS System (K200957) through performance testing. |
Magnetic Field Strength Gradient | Demonstrated "substantially equivalent" to the previously cleared Brainsway DTMS System (K200957) through performance testing. |
Electrical Safety | Compliance with IEC 60601-1 standard. Results of tests demonstrated substantial equivalence. |
Mechanical Safety | Compliance with IEC 60601-1 standard. Results of tests demonstrated substantial equivalence. |
Electromagnetic Compatibility | Compliance with IEC 60601-1-2 standard. Results of tests demonstrated substantial equivalence. |
Software Validation | Compliance with FDA guidelines for software validation and IEC 62304 standard requirements. The new stimulator software has been validated to ensure proper performance. |
Biocompatibility | Materials are biocompatible. |
Functional Equivalence | |
Intended Use/Indications for Use | Same as the main predicate device (Brainsway Deep TMS System cleared in K200957) for aid in short-term smoking cessation for adults. |
Mechanism of Action | Similar mechanism of action (electromechanical instrument producing pulsed magnetic fields to induce electrical currents in targeted brain regions for non-invasive stimulation of cortical neurons). |
System Components | Basic components are similar to cleared predicate devices. Minor modifications (new Brainsway stimulator, minor cart/cooling system/coil wire/helmet changes) introduced, but already present in reference predicate (K183303). |
Safety Features | Introduces similar safety features and complies with the same relevant consensus standards as predicate devices. Potential hazards from modifications were mitigated through performance testing. |
Performance Parameters | Treatment parameters (Magnetic Field Intensity, Frequency, Train duration, Inter-train interval, Number of trains, Magnetic Pulses per Session, Tx Session Duration, Session frequency) are identical to the main predicate (K200957). |
Environmental Parameters | Coil's Operating Temperature, Storage Temperature, Atmospheric Pressure Range, and Relative Humidity Range are within the same or comparable bounds as the predicate devices. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not applicable / Not specified. The data provided focuses on non-clinical bench testing of the modified device's components and system performance against engineering and safety standards, rather than clinical performance on a patient test set.
- Data Provenance: The document does not specify the country of origin for the non-clinical bench test data. It is inherently prospective in the sense that new tests were performed on the modified device, but these are engineering tests, not clinical data from patients.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not applicable. As indicated in point 2, there was no clinical test set requiring expert ground truth for patient outcomes or conditions. The "ground truth" for the non-clinical tests would be the established engineering and safety standards (e.g., IEC standards, FDA guidelines for software validation).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No clinical test set requiring adjudication was performed or reported in this 510(k) summary.
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. This is a medical device for treatment (Transcranial Magnetic Stimulation), not an AI diagnostic/imaging device. Therefore, a MRMC study for AI assistance to human readers is not relevant and was not performed.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- The device (Brainsway Deep TMS System) is a physical medical device. It does not operate as a standalone algorithm in the way a diagnostic AI would. Its performance is evaluated through its physical output (magnetic pulses) and electrical/mechanical characteristics as detailed in the non-clinical tests, and its substantial equivalence to a predicate device. Clinical performance of the therapy using the device relies on the operator (human-in-the-loop) and the patient, but the performance evaluation here is for the device's technical specifications.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For non-clinical performance: The "ground truth" is adherence to established engineering, electrical, mechanical, and software safety standards (e.g., IEC 60601-1, IEC 60601-1-2, IEC 62304) and comparison to the output/characteristics of the legally marketed predicate devices.
- For the overall indication (smoking cessation): The acceptability of the indication itself and its efficacy as a therapy stems from the prior clearance of the predicate device (K200957), which would have established this efficacy through clinical trials (though not detailed in this particular 510(k) summary).
8. The sample size for the training set
- Not applicable. This device is not an AI/ML algorithm that requires a "training set" in the conventional sense for learning patterns from data. The "training" in this context would be the design and development processes for the hardware and software, and testing against specifications.
9. How the ground truth for the training set was established
- Not applicable. As above, there is no "training set" for an AI/ML algorithm in this context.
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