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510(k) Data Aggregation

    K Number
    K203089
    Manufacturer
    Date Cleared
    2021-08-17

    (308 days)

    Product Code
    Regulation Number
    862.1355
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K200876

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

    The Dexcom G6 Glucose Program Continuous Glucose Monitoring System (Dexcom Glucose Program System) is a real time, continuous glucose monitoring device indicated for the management of diabetes in persons 2 years and older.

    The Dexcom Glucose Program System is intended to replace fingerstick blood glucose testing for diabetes treatment decisions for persons with diabetes who are not at significant risk of severe hypoglycemia. Interpretation of the Dexcom Glucose Program System results should be based on the glucose trends and several sequential readings over time. The Dexcom Glucose Program System also aids in the detection of episodes of hyperglycemia, facilitating long-term therapy adjustments.

    The Dexcom Glucose Program System is also intended to autonomously communicate with digitally connected devices. The Dexcom Glucose Program System can be used alone or in conjunction with these digitally connected devices or services for the purpose of managing diabetes.

    Device Description

    The Dexcom G6 Glucose Program Continuous Glucose Monitoring (CGM) System measures and displays glucose values and trends for patients with diabetes who are not at significant risk of severe hypoglycemia. The system is factory calibrated and provides continuous glucose readings at five-minute intervals for up to ten days of use. The system consists of a sensor/applicator, a Bluetooth Low Energy (BLE) transmitter, and a BLE enabled mobile CGM display.

    The sensor is a small and flexible wire, which is inserted by the applicator into subcutaneous tissue where it converts glucose into electrical current. The transmitter is connected to the sensor and is worn on the body. The transmitter samples the electrical current produced by the sensor and converts these measurements into estimated glucose values (EGV) using an onboard algorithm. The transmitter sends glucose data to the mobile CGM displays the current glucose reading (updated every 5 minutes) and glucose trends. The mobile CGM display does not include any glucose related alarm or alerts but will alert the user when important system conditions occur.

    The subject of this submission is a change to the primary display mobile device software. Compared to the predicate device which uses a standalone mobile CGM application, the proposed Glucose Program System uses a new mobile CGM software module (app module) that is embedded within a third party program provider's mobile app (host app).

    This change is to help encourage CGM retention for those not at significant risk of severe hypoglycemia by providing Dexcom Glucose Program CGM functions and program provider's functions on a single unified mobile application. The app module is designed as a finished sovereign software that interacts directly with smart device hardware/operating system and maintains the same core CGM functionality as the predicate device, independent of the host app. The proposed Glucose Program System uses the same sensor/applicator and transmitter as the predicate device, with only changes to the mobile CGM software.

    The change to the primary display mobile device software described in this submission does not impact the standalone G6 mobile application used in the G6 CGM System (last cleared K200876) and only affects the Glucose Program System which is designed for payor-sponsored, valuebased health programs.

    AI/ML Overview

    The document describes the Dexcom G6 Glucose Program Continuous Glucose Monitoring (CGM) System and its comparison to a predicate device (K200876). The core of the information provided shows that the new device, referred to as the "subject device," is substantially equivalent to the predicate, with the primary change being a modification to the mobile display software.

    Here's an analysis of the provided text in relation to the requested information:

    1. Table of acceptance criteria and the reported device performance

    The document does not explicitly present a table of acceptance criteria with corresponding reported device performance values. Instead, it asserts "substantial equivalence" to a predicate device, implying that the subject device meets the same performance standards as the predicate. The description highlights that the subject device "has the same core CGM functionality and meets the same system requirements as the predicate G6 Glucose Program System."

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

    The document does not specify a sample size for a test set that was used to prove the device meets acceptance criteria. It mentions that "All testing referenced in the predicate device (K200876) in accordance with special controls for integrated continuous glucose monitors remain applicable." This suggests that new clinical performance testing with human subjects was not conducted for this specific submission because the underlying hardware and core algorithms are the same as the predicate.

    Regarding data provenance (country of origin, retrospective/prospective), this information is also not provided as new clinical trials were not detailed for this submission.

    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 in the document. As stated above, new clinical performance data from human subjects is not detailed for this submission, as the claim is based on substantial equivalence to a predicate device for which such testing would have been performed.

    4. Adjudication method for the test set

    This information is not provided in the document.

    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

    This type of study is not applicable to this device. The Dexcom G6 Glucose Program CGM System is a continuous glucose monitoring device, not an AI-assisted diagnostic imaging or interpretation tool that would involve "human readers" in the context of an MRMC study.

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

    The device itself is a continuous glucose monitoring system with an onboard algorithm that converts sensor measurements into estimated glucose values. The document states, "The transmitter samples the electrical current produced by the sensor and converts these measurements into estimated glucose values (EGV) using an onboard algorithm." This confirms a standalone algorithm that processes raw sensor data. The claim of substantial equivalence implies that the performance of this standalone algorithm has been previously validated as part of the predicate device's clearance.

    7. The type of ground truth used

    For a glucose monitoring device, the typical "ground truth" for evaluating accuracy would be laboratory reference standard blood glucose measurements (e.g., from a YSI analyzer). While the document doesn't explicitly state the ground truth used for this specific submission, it relies on the predicate device's clearance, which would have established accuracy against such a standard. The section "Glucose Value Estimation Algorithm" mentions an "Optimized Joint Probability Algorithm with improved data availability," which would be evaluated against such ground truth.

    8. The sample size for the training set

    The document does not provide information regarding the sample size for the training set. This is likely because the core algorithm remains the same as the predicate device, and new training data for algorithm development is not part of this specific submission.

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

    The document does not provide this information. It only states that the "Optimized Joint Probability Algorithm" is used, implying that any training and its associated ground truth establishment would have occurred during the development of this algorithm (likely for the predicate device).

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