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510(k) Data Aggregation
(266 days)
NeuroStar Advanced Therapy is indicated as an adjunct for the treatment of Major Depressive Disorder (MDD) in adolescent patients (age 15-21).
The NeuroStar Advanced Therapy System is a transcranial magnetic stimulation device. Specifically, it is a computerized, electromechanical medical device that produces and delivers non-invasive magnetic fields to induce electrical currents targeting specific regions of the cerebral cortex. 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 pathway, localized axonal depolarizations are produced, thus activating neurons in the targeted brain region.
The NeuroStar System consists of a combination of hardware, disposable, and consumable supplies, which are required for the operation of the system. The basic configuration includes the following components:
- Mobile Console
- System Software
- Treatment Chair
- Head Support System
- MT Cap
- . D-Tect MT Accessory
- TrakStar Data Management
The NeuroStar Advanced Therapy System is indicated as an adjunct for the treatment of Major Depressive Disorder (MDD) in adolescent patients (age 15-21).
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Success Criteria) | Reported Device Performance |
---|---|
A minimum of 50% of the primary per protocol analysis population meet the Individual Subject Success Criteria (defined as a meaningful reduction in depression symptoms based on PHQ-9 scores over a pre-post TMS treatment interval of 6 weeks and achieving remission of MDD symptoms). | 77.8% (95% CI: 72.8%, 83.0%) of the primary per protocol population met the criteria. |
The lower limit of the 95% confidence interval for individual success rate should exceed the pre-established Overall Study Success Criteria of a minimum 50%. | The lower limit (72.8%) exceeded 50% by 22.79%. |
Proportion of responders (defined as a meaningful reduction in depression symptoms based on PHQ-9 scores) is statistically significant. | This proportion was found to be statistically significant at p |
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(178 days)
The NeuroStar Advanced Therapy 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 NeuroStar Advanced Therapy System is a transcranial magnetic stimulation device. Specifically, it is a computerized, electromechanical medical device that produces and delivers non-invasive magnetic fields to induce electrical currents targeting specific regions of the cerebral cortex. 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 pathway, localized axonal depolarizations are produced, thus activating neurons in the targeted brain region.
The NeuroStar System consists of a combination of hardware, disposable, and consumable supplies, which are required for the operation of the system. The basic configuration includes the following components:
- Mobile Console
- System Software
- Treatment Chair
- Head Support System
- TrakStar PC
- TrakStar Software
The NeuroStar Advanced Therapy System is indicated for treating depressive episodes and decreasing anxiety symptoms in adult patients with Major Depressive Disorder (MDD) who have not achieved satisfactory improvement from previous antidepressant medication.
Here's an analysis of the acceptance criteria and supporting studies:
- Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Outcome Measures) | Reported NeuroStar Advanced Therapy System Performance |
---|---|
For Depression (Derived from Predicate Device Clearance, not explicitly detailed here for criteria beyond initial clearance) | O'Reardon et al., 2008 & George et al., 2010 (original clearance studies for MDD): |
Response Rate (≥ 50% decrease in end score relative to baseline) for HAMD-17 and HAMD-24 | Statistically significant improvement (p |
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(32 days)
NeuroStar Advanced Therapy System, K201158
The NeuroStar Advanced Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
The NeuroStar Advanced Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Maqnetic Stimulation (TMS). NeuroStar Advanced Therapy is a non-invasive tool for the stimulation of cortical neurons for the treatment of adult patients with Major Depressive Disorder (MDD) who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode. NeuroStar Advanced Therapy is used for patient treatment by prescription only under the supervision of a licensed physician and can be used in both inpatient and outpatient settings including physician's offices, clinics, and hospitals. NeuroStar Advanced Therapy uses a well-understood property of physics regarding the law of electromagnetic induction, which states that a time-varying or moving magnetic field will induce an electric current in an adjacent conductive substance with the electric current traveling in a direction perpendicular to the motion of the magnetic field. NeuroStar Advanced Therapy uses a generated magnetic field as a vector for delivering an electrical current to a tarqet conductor of interest, which in therapeutic application, is the brain. By using this method of delivering electrical current to the brain the electrical current produced in the brain can be delivered in an anatomically focused manner at discrete cortical areas of interest and can avoid areas of the brain that are not relevant for its therapeutic actions.
The NeuroStar Advanced Therapy System is an integrated system consisting of a combination of the following components:
- Mobile Console for housing the electronics and includes a software . controlled graphical user interface, display monitor, display arm, and gantry that supports the treatment coil.
- Ferromagnetic Coil for delivering treatment. .
- . Head Support System for positioning the treatment coil and includes a laser-guided alignment system
- . Optional MT Cap for
- Multi-use consumable SenStar Treatment Link for contact sensing of the ● treatment coil with the patient's head and maqnetic field quality control.
- TrakStar Patient Data Management System for recording patient data and includes a stand-alone computer and data management software
Here's a breakdown of the acceptance criteria and study information for the NeuroStar Advanced Therapy System, based on the provided FDA 510(k) summary:
The primary purpose of this 510(k) submission is for the addition of the MT Cap accessory. The document explicitly states that the NeuroStar Advanced Therapy System (the subject device) has the same indications for use and technological characteristics as the predicate device, implying that the core system's performance metrics have already been established in previous submissions. This K213543 submission focuses on the safety and effectiveness of the new accessory.
Therefore, the "acceptance criteria" and "device performance" in the context of this specific submission revolve around demonstrating that the MT Cap accessory does not negatively impact the existing performance or introduce new risks, and that it functions as intended to aid in the Motor Threshold Hunt process.
Acceptance Criteria and Reported Device Performance
Given that this 510(k) is an update for an accessory (MT Cap) to an already cleared device, the acceptance criteria are focused on demonstrating that the accessory does not compromise the device's safety or efficacy. The document does not provide specific quantitative performance metrics tied to sensitivity, specificity, accuracy, or similar measures typically found in standalone diagnostic AI/ML device acceptances. Instead, the "performance" demonstrated is compliance with relevant standards and successful usability.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Biocompatibility (for MT Cap) | MT Cap material compliant with ISO 10993-1:2018; uses standard materials commonly used in consumer products and medical device applications. |
Usability (for MT Cap integration) | Usability testing completed in accordance with IEC 60601-1-6:2010, Edition 3.1 and FDA Guidance Document "Applying Human Factors and Usability Engineering to Medical Devices." The MT Cap enables physicians to easily move the coil incrementally without adjusting the A/P Bar. |
Safety - Electrical/EMC (overall system) | IEC 60601-1 compliant; IEC 60601-1-2 compliant (inherited from predicate device, not re-evaluated for MT Cap specifically as it's a passive accessory). |
No New Questions of Safety or Effectiveness | The use of the optional MT Cap accessory "does not raise any new questions of safety or effectiveness." This is the overarching acceptance. |
Functional Aiding of MT Hunt | MT Cap provides symmetrical grid for incremental coil movement and includes intersecting lines for starting point; aids in facilitating the hunt for the MT location. |
No change to core treatment parameters | All core treatment parameters (%MT Range, PPS Range, Induced Electric Field, Pulse Type, Pulse Width, Treatment Protocols, Treatment Level Range) remain identical to the predicate device. |
Study Information Specific to the MT Cap Accessory
-
Sample Size used for the test set and the data provenance:
- The document states, "There is no clinical testing required to support this submission."
- For Usability testing, the sample size is not explicitly stated in the provided text. Usability studies typically involve a small number of representative users (e.g., 8-15) as per human factors guidance, but the exact number is not here.
- The provenance for usability testing would typically be prospective, involving healthcare professionals interacting with the device/accessory. The document does not specify country of origin for usability test participants.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- As no clinical testing was required, there was no "ground truth" to establish in the traditional sense of disease diagnosis or outcome for the MT Cap.
- For usability testing, "experts" would be the healthcare professionals participating in the test. Their qualifications would typically involve experience with TMS procedures. The document does not specify the number or detailed qualifications of these individuals.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable as there was no clinical study with a diagnostic endpoint requiring adjudication. Usability studies use qualitative and quantitative measures of user performance, error rates, and satisfaction rather than adjudication of findings.
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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 MRMC or comparative effectiveness study was done. This device is a hardware accessory (MT Cap) for a TMS system, not an AI/ML diagnostic or assistive algorithm. The MT Cap is a physical guide to assist in a manual process (Motor Threshold Hunt), not an AI.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. The MT Cap is a passive physical accessory, not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Not applicable for the MT Cap accessory. For the overall NeuroStar system (established in prior submissions), ground truth for Major Depressive Disorder (MDD) efficacy would have been based on clinical assessments (e.g., Hamilton Depression Rating Scale, Montgomery-Åsberg Depression Rating Scale) and clinical outcomes, but this is not part of this submission.
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The sample size for the training set:
- Not applicable as this is not an AI/ML device requiring a training set.
-
How the ground truth for the training set was established:
- Not applicable as this is not an AI/ML device requiring a training set.
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(132 days)
Horizon® 3.0 TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
The Horizon® 3.0 TMS Therapy System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic stimulation using brief duration rapidly alternating, or pulsed, magnetic fields to induce electrical currents directed at spatially discrete regions of the cerebral cortex. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation. ("TMS")
The Horizon® 3.0 TMS Therapy System is a non-invasive tool for the stimulation of cortical neurons for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from antidepressant medication in the current episode. The Horizon® 3.0 TMS Therapy System is used for patient treatment by prescription only under the supervision of a licensed physician. It can be used in both inpatient settings, including physicians' offices, clinics, and hospitals.
Horizon® 3.0 TMS Therapy System is an integrated system consisting of a combination of hardware, software, and accessories.
The acceptance criteria and the study that proves the device meets the acceptance criteria are detailed below. It is important to note that this document primarily focuses on non-clinical testing for substantial equivalence to predicate devices, rather than a clinical effectiveness study against a gold standard.
1. Table of Acceptance Criteria and Reported Device Performance
The provided document describes non-clinical testing conducted to validate the performance of the Horizon® 3.0 TMS Therapy System and to ensure it meets design specifications and relevant FDA guidance. The "acceptance criteria" here are generally compliance with recognized standards and demonstration of substantial equivalence to predicate devices. The "reported device performance" is the outcome of these compliance tests.
Acceptance Criteria (General) | Reported Device Performance |
---|---|
Electrical Safety (Compliance with ANSI/AAMI ES60601-1:2005/(R)2012 and A1:2012) | A sample Horizon® 3.0 TMS Therapy System (specifically Horizon® 3.0 with StimGuide+) was tested by independent test laboratory BSI Appliances and found to be compliant with the requirements of ANSI/AAMI ES 60601-1, demonstrating safety and effectiveness following incorporation of new/different characteristics compared to the predicate device. |
Mechanical Safety (Implicit in ANSI/AAMI ES60601-1:2005/(R)2012 and A1:2012) | (Covered by Electrical Safety compliance above) |
Electromagnetic Compatibility (EMC) (Compliance with IEC 60601-1-2: 2014) | A sample of the Horizon® 3.0 TMS Therapy System (specifically Horizon® 3.0 with StimGuide+) was tested by independent test laboratory Eurofins Hursley and found to be compliant with the requirements of IEC 60601-1-2, demonstrating safety and effectiveness following incorporation of new/different characteristics compared to the predicate device. |
Alarm Systems (Compliance with IEC 60601-1-8) | A sample Horizon® 3.0 TMS Therapy System was tested by independent test laboratory BSI Appliances and found to be compliant with the requirements of IEC 60601-1-8, demonstrating substantial equivalence to the legally marketed predicate device. |
Biocompatibility (Compliance with ISO 10993-1:2009, ISO 10993-5:2009, ISO 10993-10:2010) | Patient-contacting components (Enclosure of Horizon® MT Coil, Enclosure of Horizon® E-z Cool Coil 3.0, Enclosure of Horizon® E-z Cool Coil (Nav) 3.0) were tested by an independent test laboratory and found, for materials with limited skin contact duration (surface contacting, less than 24-hour duration), to be compliant with the requirements of ISO 10993-1, ISO 10993-5, and ISO 10993-10, demonstrating substantial equivalence to the legally marketed predicate devices. |
Human Factors Testing (Compliance with AAMI/ANSI HE75 and IEC 62366-1) | Usability testing was performed on the Horizon® 3.0 TMS Therapy System. The Human Factors Engineering report verifies the system is safe and effective for the intended users, uses, and use environments, demonstrating substantial equivalence to the legally marketed predicate devices. |
Software Lifecycle Process (Verification & Validation, ISO 14971, AAMI TIR57:2016/(R)2019 for Cybersecurity) | The software lifecycle process, including verification and validation testing, assures that the software performs as intended and in accordance with specifications. Potential risks were identified and evaluated in compliance with ISO 14971 (Ed 2.0) and determined acceptable or addressed with risk control measures. AAMI TIR57:2016/(R)2019 was applied to evaluate and control cybersecurity risks, which were determined acceptable. |
Substantial Equivalence to Predicate Devices | The Horizon® 3.0 TMS Therapy System was found substantially equivalent to the Horizon® TMS Therapy System (K182853) and Horizon® TMS Therapy System with Navigation (K183376) in terms of intended use, indications for use, basic design, mechanism of action, coil head geometry, magnetic field characteristics, and treatment protocols (standard rTMS and iTBS). Minor differences (upgraded mainframe, PSU design change, new interface unit, improved touch panels/GUI, upgraded cart/arm, StimGuide+ updates, Magstim Connect integration) were evaluated through the non-clinical testing listed above, demonstrating that the Horizon® 3.0 is as safe and effective as the predicate devices. |
2. Sample Size Used for the Test Set and the Data Provenance
The document does not specify a "test set" in the context of patient data or clinical trials. The testing described is primarily non-clinical bench testing and verification/validation activities on the device itself.
- For tests like Electrical Safety, EMC, and Alarm Systems, a "sample Horizon® 3.0 TMS Therapy System (specifically Horizon® 3.0 with StimGuide+)" was used.
- For Biocompatibility, "samples of these materials" (patient-contacting components) were tested.
- For Human Factors, "Usability testing was performed to Horizon® 3.0 TMS Therapy System."
Data Provenance: This is not applicable to the non-clinical testing described, as it does not involve patient data. The tests were performed by independent test laboratories (BSI Appliances, Eurofins Hursley) and internally by Magstim.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This is not applicable as the study involves non-clinical engineering and systems testing, not the establishment of a medical 'ground truth' based on expert consensus for diagnostic or prognostic purposes. Compliance with standards and direct measurement against specifications serve as the "ground truth."
4. Adjudication Method for the Test Set
This is not applicable, as the study does not involve expert adjudication of medical cases. The tests are objective measurements and compliance checks performed by qualified testing laboratories and the manufacturer.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The document explicitly states that the submission relies on non-clinical testing to demonstrate substantial equivalence to predicate devices, rather than a clinical trial of effectiveness. There is no mention of human readers or AI assistance in this context.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
The device is a physical medical system (Transcranial Magnetic Stimulation Therapy System), not primarily an AI algorithm. Therefore, the concept of "standalone (algorithm only without human-in-the-loop performance)" does not directly apply in the typical sense of AI diagnostics. However, the software components of the device were a subject of extensive verification and validation testing, including assessing cybersecurity risks, as part of the overall system. This can be seen as an evaluation of the system's inherent performance, albeit for a complex electro-mechanical system rather than a purely diagnostic algorithm.
7. The Type of Ground Truth Used
For this submission, the "ground truth" for the non-clinical testing is:
- Recognized International and National Standards: e.g., ANSI/AAMI ES60601-1, IEC 60601-1-2, IEC 60601-1-8, ISO 10993 series, AAMI/ANSI HE75, IEC 62366-1.
- Design Specifications and Intended Performance: The device was tested to ensure it performs as intended and meets its internal design specifications.
- FDA Guidance: "Class II Special Controls Guidance Document: Repetitive Transcranial Magnetic Stimulation (rTMS)."
- Predicate Device Characteristics: Comparison of the new device's technical specifications and performance to legally marketed predicate devices to establish substantial equivalence.
8. The Sample Size for the Training Set
This is not applicable. The document describes a 510(k) submission based on non-clinical testing for substantial equivalence. It does not involve machine learning models that require training sets of data.
9. How the Ground Truth for the Training Set Was Established
This is not applicable, as no machine learning training set is described in the document.
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