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510(k) Data Aggregation
(269 days)
MSKai is an image identification, post-processing, measurement, and reporting software tool that provides qualitative viewing and quantitative spine measurements from previously-acquired T2 weighted DICOM lumbar spine Magnetic Resonance Imaging (MRI) images for users' review, evaluation and analysis. It provides the following functionality to assist users in identifying, observing, measuring and reporting measurements:
- Anatomy segmentation;
- Anatomy labeling;
- Anatomy measurement; and
- Export of measurement results to a qualitative and quantitative report for user's evaluation, amendment and authorization
MSKai does not serve as a diagnostic device by providing or recommending any type of medical diagnosis or treatment. MSKai simply provides users the ability to access objective and repeatable identification, segmentation, measurement and reported measurements of the Lumbar spine. The user is responsible for the indications of preferences and settings, confirming the software-generated measurements, and reviewing, confirming and approving draft reports based on their medical training.
The device is intended to be used only by physicians, radiologist, hospitals and other medical institutions. Only T2 weighted DICOM images of MRI acquired from lumbar spine exams of patients aged 18 and above are acceptable input. MSKai does not support DICOM images of patients that are pregnant, have post-operational complications, tumors, infections, or complex hardware.
MSKai is a medical device (software) for inspecting and evaluating T2-weighted magnetic resonance imaging (MRI) of the lumbar spine. The software is an imaging interpretation tool that assists radiologists and neuro/ortho spine surgeons ("users") to identify and measure lumbar spine features in medical images and document their interpretations in a report. The segmentation and measurements are classified using "alerts" based on rule-based algorithms. The user also identifies and classifies any other observations that the software may not annotate.
Here's a breakdown of the acceptance criteria and the study proving the MSKai device meets those criteria, based on the provided FDA 510(k) clearance letter:
MSKai Device Performance Study Summary
The MSKai device is an image identification, post-processing, measurement, and reporting software tool for T2-weighted lumbar spine MRI images. A standalone software performance assessment study was conducted to demonstrate its accuracy in segmentation and measurement, meeting pre-defined acceptance criteria.
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Table of Acceptance Criteria and Reported Device Performance:
A. Segmentation Performance (Mean Dice Coefficient - MDC)
Anatomy Segmentation View Acceptance Criteria (MDC Limit) Reported Device Performance (Mean Dice Coefficient) 95% Confidence Interval (CI) Met Criteria? Vertebral Body (L1) Sagittal 0.8 0.968 0.92-0.98 Yes Vertebral Body (L2) Sagittal 0.8 0.977 0.93-0.98 Yes Vertebral Body (L3) Sagittal 0.8 0.981 0.94-0.99 Yes Vertebral Body (L4) Sagittal 0.8 0.963 0.92-0.98 Yes Vertebral Body (L5) Sagittal 0.8 0.985 0.91-0.98 Yes Vertebral Body (S1) Sagittal 0.8 0.945 0.93-0.99 Yes L5/S1 Disc Sagittal 0.8 0.993 0.91-0.99 Yes L4/L5 Disc Sagittal 0.8 0.991 0.93-0.99 Yes L3/L4 Disc Sagittal 0.8 0.992 0.93-0.99 Yes L2/L3 Disc Sagittal 0.8 0.989 0.91-0.99 Yes L1/L2 Disc Sagittal 0.8 0.986 0.94-0.99 Yes Cord Canal Sagittal 0.8 0.983 0.93-0.99 Yes Axial Disc Axial 0.8 0.984 0.89-0.97 Yes Vertebral Body Axial 0.8 0.991 0.93-0.99 Yes Dural Sac Axial 0.8 0.978 0.90-0.98 Yes Nerve Root Axial 0.8 0.952 0.90-0.95 Yes Posterior Arch Axial 0.8 0.911 0.90-0.96 Yes All reported Mean Dice Coefficients (MDC) met or exceeded the acceptance criterion of 0.8.
B. Measurement Performance (Mean Absolute Error - MAE)
Structural Measurements View Acceptance Criteria (MAE Limit) Reported Device Performance (Mean Absolute Error) 95% Confidence Interval (CI) Met Criteria? Protruding Disc Material (L5/S1) Sagittal 2mm 1.19mm 1.11 -1.68mm Yes Protruding Disc Material (L4/L5) Sagittal 2mm 1.22mm 1.12 -1.71mm Yes Protruding Disc Material (L3/L4) Sagittal 2mm 1.23mm 1.14 -1.65mm Yes Protruding Disc Material (L2/L3) Sagittal 2mm 1.19mm 1.07 -1.61mm Yes Protruding Disc Material (L1/L2) Sagittal 2mm 1.21mm 1.11 -1.63mm Yes Intervertebral Angle (L5/S1) Sagittal 6° 2.6° 1.58 - 2.45° Yes Intervertebral Angle (L4/L5) Sagittal 6° 2.7° 1.61 - 2.59° Yes Intervertebral Angle (L3/L4) Sagittal 6° 2.7° 1.57 - 2.54° Yes Intervertebral Angle (L2/L3) Sagittal 6° 2.9° 1.64 - 2.62° Yes Intervertebral Angle (L1/L2) Sagittal 6° 2.4° 1.66 - 2.48° Yes Vertebral Body Height (Anterior) (L1) Sagittal 2mm 0.66mm 0.62 -0.91mm Yes Vertebral Body Height (Anterior) (L2) Sagittal 2mm 0.68mm 0.61 -0.88mm Yes Vertebral Body Height (Anterior) (L3) Sagittal 2mm 0.69mm 0.61 -0.93mm Yes Vertebral Body Height (Anterior) (L4) Sagittal 2mm 0.64mm 0.58 -0.91mm Yes Vertebral Body Height (Anterior) (L5) Sagittal 2mm 0.67mm 0.61 -0.91mm Yes Vertebral Body Height (Midline) (L1) Sagittal 2mm 0.94mm 0.62 -0.87mm Yes Vertebral Body Height (Midline) (L2) Sagittal 2mm 0.93mm 0.54 -1.03mm Yes Vertebral Body Height (Midline) (L3) Sagittal 2mm 0.96mm 0.61 -1.01mm Yes Vertebral Body Height (Midline) (L4) Sagittal 2mm 0.97mm 0.57 -1.13mm Yes Vertebral Body Height (Midline) (L5) Sagittal 2mm 0.94mm 0.57 -0.99mm Yes Vertebral Body Height (Posterior) (L1) Sagittal 2mm 0.92mm 0.67 -0.99mm Yes Vertebral Body Height (Posterior) (L2) Sagittal 2mm 0.93mm 0.61 -1.01mm Yes Vertebral Body Height (Posterior) (L3) Sagittal 2mm 0.91mm 0.68 -0.99mm Yes Vertebral Body Height (Posterior) (L4) Sagittal 2mm 0.92mm 0.71 -1.06mm Yes Vertebral Body Height (Posterior) (L5) Sagittal 2mm 0.93mm 0.68 -1.09mm Yes Disc Height (Anterior) (L5/S1) Sagittal 2mm 0.91mm 0.67 -0.99mm Yes Disc Height (Anterior) (L4/L5) Sagittal 2mm 0.90mm 0.57 -1.06mm Yes Disc Height (Anterior) (L3/L4) Sagittal 2mm 0.87mm 0.62 -1.03mm Yes Disc Height (Anterior) (L2/L3) Sagittal 2mm 0.89mm 0.78 -1.06mm Yes Disc Height (Anterior) (L1/L2) Sagittal 2mm 0.93mm 0.71 -1.23mm Yes Disc Height (Midline) (L5/S1) Sagittal 2mm 0.93mm 0.73 -1.12mm Yes Disc Height (Midline) (L4/L5) Sagittal 2mm 0.90mm 0.68 -1.01mm Yes Disc Height (Midline) (L3/L4) Sagittal 2mm 0.89mm 0.71 -1.13mm Yes Disc Height (Midline) (L2/L3) Sagittal 2mm 0.91mm 0.64 -1.03mm Yes Disc Height (Midline) (L1/L2) Sagittal 2mm 0.92mm 0.69 -1.11mm Yes Disc Height (Posterior) (L5/S1) Sagittal 2mm 0.87mm 0.58 -1.03mm Yes Disc Height (Posterior) (L4/L5) Sagittal 2mm 0.93mm 0.67 -0.99mm Yes Disc Height (Posterior) (L3/L4) Sagittal 2mm 0.87mm 0.66 -1.07mm Yes Disc Height (Posterior) (L2/L3) Sagittal 2mm 0.93mm 0.72 -1.21mm Yes Disc Height (Posterior) (L1/L2) Sagittal 2mm 0.89mm 0.58 -0.91mm Yes Anterio-Lithesis (L5/S1) Sagittal 2mm 1.04mm 0.81 -1.43mm Yes Anterio-Lithesis (L4/L5) Sagittal 2mm 1.02mm 0.77 -1.52mm Yes Anterio-Lithesis (L3/L4) Sagittal 2mm 1.05mm 0.88 -1.61mm Yes Anterio-Lithesis(L2/L3) Sagittal 2mm 1.07mm 0.84 -1.43mm Yes Anterio-Lithesis (L1/L2) Sagittal 2mm 1.02mm 0.79 -1.33mm Yes Retro-Lithesis (L5/S1) Sagittal 2mm 1.07mm 0.82 -1.51mm Yes Retro-Lithesis (L4/L5) Sagittal 2mm 1.049mm 0.78 -1.42mm Yes Retro-Lithesis (L3/L4) Sagittal 2mm 1.01mm 0.81 -1.29mm Yes Retro-Lithesis (L2/L3) Sagittal 2mm 1.05mm 0.77 -1.34mm Yes Retro-Lithesis (L1/L2) Sagittal 2mm 1.08mm 0.83 -1.27mm Yes Lordotic Angle Sagittal 6° 2.99° 2.01 - 3.62° Yes Protruding Disc Material Axial 2mm 0.97 mm 0.72 -1.42mm Yes Dural Sac Diameter Axial 2mm 1.3 mm 0.87 -1.39mm Yes All reported Mean Absolute Errors (MAE) were below the acceptance criterion of 2mm or 6°.
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Sample Size and Data Provenance:
- Test set sample size: 238 MR image studies (from 238 patients).
- Data Provenance: Images were collected from five sites across the U.S.
- Timeframe: Not explicitly stated whether retrospective or prospective, but generally clinical performance studies for 510(k) clearances use retrospective data. The description "collected from five sites across the U.S." doesn't specify if it was specifically collected for this study, implying it could be retrospective.
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Number of Experts and Qualifications for Ground Truth:
- Total number of experts for ground truth establishment (initial curation for training/testing): 5 experts.
- Qualifications of these experts: 3 neurosurgeons, 1 interventional radiologist, and 1 PhD in Biomechanics.
- Number of experts for measurement analysis in the testing dataset (independent group): 4 separate and independent experts.
- Qualifications of these specific measurement experts: 2 neurosurgeons, 2 radiologists.
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Adjudication Method for the Test Set:
- The document implies a consensus method for ground truth, stating "Ground truth data, curated by five experts in a two-phase process, underpins model training." and for the independent testing dataset, "being measured by an independent group of 4 experts."
- For the testing dataset measurements, it says "Measurement analysis was performed by 4 separate and independent experts." It also mentions "Inter-ratter reliabilities were conducted in the experts who perform the training/testing measurements."
- However, it does not explicitly state a formal adjudication method like "2+1" or "3+1" (where agreement by a majority or third reader is required to resolve discrepancies). The language "curated by five experts" and "measured by an independent group of 4 experts" suggests a consensus or multiple-read approach, but the specific rule for resolving disagreements is not detailed.
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Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC study was done. The document explicitly states: "No human clinical study was conducted to support the pre-market clearance." This means there is no data provided on how much human readers improve with AI vs. without AI assistance. The study described is a standalone performance study.
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Standalone Performance:
- Yes, a standalone (algorithm only without human-in-the-loop performance) study was done. The study's title is "Standalone Software Performance Study" and it states, "the MSKai software outputs without any editing by a radiologist" were compared to ground truth.
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Type of Ground Truth Used:
- Expert Consensus: The ground truth was established by human experts (3 neurosurgeons, 1 interventional radiologist, and 1 PhD in Biomechanics) who curated and measured anatomical segmentations and structures.
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Sample Size for the Training Set:
- Training Data: The document mentions "Three blind independent data sets were used to train, test and measure within the model." It specifically states the "Ground Truth dataset: 255 patient images." While this dataset was used for "ground truth development" for model training, the exact number of images specifically used only for the training phase versus those used for internal testing/validation during development is not distinctly broken out beyond the general "Ground Truth dataset: 255 patient images" being used to "underpin model training."
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How Ground Truth for the Training Set Was Established:
- The ground truth for the training set (referred to as the "Ground Truth dataset") was "curated by five experts in a two-phase process." These experts were 3 neurosurgeons, 1 interventional radiologist, and 1 PhD in Biomechanics. This involved establishing the accurate segmentations and measurements that the algorithm was trained to reproduce.
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