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510(k) Data Aggregation
(262 days)
The Zio monitor is a prescription-only, single-use, ECG monitor that continuously records data for up to 14 days. It is indicated for use on patients, 18 years and older, who may be asymptomatic or who may suffer from transient symptoms such as palpitations, shortness of breath, dizziness, lightheadedness, pre-syncope, syncope, fatigue, or anxiety.
The Zio monitor is a non-sterile, single-use, continuously recording, long-term ambulatory ECG monitor that is adhered to a patient's left pectoral region in a modified Lead II orientation. The goal of the Zio monitor is to help physicians initiate long-term, patient-compliant ECG monitoring utilizing proprietary technology. The Zio monitor is applied and activated by the patient at home or at a clinic. Once activated, the device provides continuous, uninterrupted ECG recording into memory with minimal patient interaction. There is a button on the surface of the Zio monitor, which serves to activate the device and may be pressed by the patient during wear to indicate when he or she is experiencing a symptom. Additionally, there is a surface LED light that blinks green to confirm proper activation or that the device is working, and orange to indicate loss of connection with the skin or the presence of error conditions.
The Zio monitor utilizes firmware that captures single-channel ECG data into memory, there is no wireless transmission of data during the wear period of the device. After the prescribed monitoring period is complete, the Zio monitor is returned to iRhythm where the ECG data is then analyzed and annotated by the ZEUS System (K222389). ECG data is then presented to the Qualified Cardiac Technicians (QCT) at the Independent Diagnostic Testing Facility (IDTF) for review and subsequent creation and posting of the end-of-wear report with preliminary findings. Zio monitor device is not intended for real-time patient monitoring.
The provided text is an FDA 510(k) clearance letter and summary for the Zio® monitor. It details the device, its indications for use, comparison to a predicate device, and nonclinical testing performed to establish substantial equivalence. However, it explicitly states:
"No clinical testing was performed in support of this premarket notification."
Therefore, I cannot provide a table of acceptance criteria and reported device performance based on a clinical study, nor specific details about sample size, data provenance, ground truth establishment, expert qualifications, or MRMC studies, as these aspects relate to clinical testing which was not conducted for this submission.
Here's what I can extract and state based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance:
Based on the provided document, the acceptance criteria and device performance are established through nonclinical testing, demonstrating conformance to recognized standards and performance specifications, rather than through a clinical study with specific performance metrics like sensitivity or specificity for detecting arrhythmias.
Criteria Category | Description (as inferred from document) | Reported Device Performance (as inferred from document) |
---|---|---|
System Performance | The device performs as intended per specifications. Verification of functionality. | Met (implied by "System performance testing" and conclusion of substantial equivalence). |
Biocompatibility | Device materials are safe for patient contact. | Met (based on "Biocompatibility testing" and conformance to ISO 10993 standards). |
Firmware Verification | Software components function correctly and reliably. | Met (based on "Firmware verification testing" and conformance to IEC 62304). |
Electrical Safety & EMC | Device meets electrical safety and electromagnetic compatibility standards. | Met (based on "Electrical safety and EMC testing" and conformance to IEC 60601 series). |
Human Factors | Device design allows for safe and effective use by operators. | Met (based on "Human Factors testing" and conformance to IEC 62366-1). |
IR Sensitivity | Analyzable time is comparable to reference devices despite a new failure mode. | Analyzable time equivalent to Zio AT (based on "Additional analysis was conducted regarding a new failure mode found for IR sensitivity"). |
2. Sample size used for the test set and the data provenance:
- Sample Size for Test Set: Not applicable as no clinical testing was performed. The nonclinical testing would have used various test samples, components, or simulated data as appropriate for each specific engineering and performance test (e.g., system testing, electrical testing).
- Data Provenance: Not applicable for clinical data. For nonclinical testing, the data is generated in-house or by accredited testing laboratories as part of the device's design verification and validation.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as no clinical testing with human-established ground truth was reported. Ground truth in nonclinical testing refers to established engineering specifications or reference standards.
4. Adjudication method for the test set:
- Not applicable as no clinical testing requiring expert adjudication was performed.
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 MRMC comparative effectiveness study was done as no clinical testing was performed. The device, Zio monitor, is described as recording ECG data which is then "analyzed and annotated by the ZEUS System (K222389)" and "presented to the Qualified Cardiac Technicians (QCT) at the Independent Diagnostic Testing Facility (IDTF) for review." This implies an existing workflow with a human-in-the-loop, but this submission specifically states no clinical testing was performed to evaluate its effectiveness in combination with human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- The document implies that the "ZEUS System (K222389)" performs initial analysis and annotation of the ECG data, but this specific 510(k) is for the Zio® monitor hardware device. Performance data for the ZEUS System itself would be found in its own 510(k) clearance (K222389). This submission does not provide standalone algorithm performance metrics.
7. The type of ground truth used:
- For the nonclinical testing, the ground truth would be based on:
- Engineering Specifications: Device design requirements and intended performance.
- Recognized Consensus Standards: Compliance with international standards (e.g., IEC 60601 series, ISO 10993 series).
- Internal Product Specifications: How the device is designed to function and its measurable outputs.
8. The sample size for the training set:
- Not applicable. This submission is for a hardware device and relies on nonclinical testing for substantial equivalence, not a machine learning model's training set. While the ZEUS System (K222389) likely uses a training set, details for that system are outside the scope of this document.
9. How the ground truth for the training set was established:
- Not applicable as no training set for an algorithm is discussed in this submission for the Zio® monitor hardware.
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