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510(k) Data Aggregation
(44 days)
The SphygmoCor® Cardiovascular Management System (CvMS) provides a derived ascending aortic blood pressure waveform and a range of central arterial indices. The CvMS is used with a tonometer over a radial artery calibrated with a standard cuff blood pressure measurement. It is to be used on those patients where information related to ascending aortic blood pressure is desired but in the opinion of the physician, the risks of cardiac catheterization procedure or other invasive monitoring may outweigh the benefits.
The CvMS Heart Rate Variability (HRV) option is intended for use in obtaining HRV measurements in response to controlled exercises.
The CvMS Pulse Wave Velocity (PWV) option is intended for use in obtaining PWV measurements. The PWV option is used on adult patients only.
The SphygmoCor CvMS device (un-modified device) is a computerized tool for providing a derived ascending aortic blood pressure waveform and a range of central anterial indices. The CvMS is used with a tonometer over the radial artery to capture a pressure waveform which is used to derive central pressure and is calibrated with a standard blood pressure cuff measurement. The CvMS is intended for use on those patients where information related to ascending aortic blood pressure is desired but in the opinion of the physician, the risks of cardiac catheterization procedure or other invasive monitoring may outweigh the benefits. In addition, the CvMS incorporates an option to enable users to measure Heart Rate Variability (HRV) in response to controlled exercises.
The SphygmoCor CvMS with the PWV option (modified device) is a software addition to the SphygmoCor CvMS device (K070795). This software feature provides an additional central arterial indice - Pulse Wave Velocity (PWV).
The provided document describes the SphygmoCor Cardiovascular Management System (CvMS), with a specific focus on the Pulse Wave Velocity (PWV) option.
Here's an analysis of the acceptance criteria and study information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly list quantitative acceptance criteria for the PWV measurement or a detailed performance report against such criteria. Instead, it states that "All tests confirmed the product met the acceptance criteria" and that a clinical comparison study "demonstrated similar performance between the two devices" (the modified SphygmoCor CvMS with PWV and its predicate).
While explicit acceptance criteria are not provided, the implied acceptance criteria are:
- The software verifies and validates correctly.
- The device performs similarly to the predicate device in a clinical comparison.
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Software verification passed | "Software verification" performed and product "met the acceptance criteria" |
Software validation (System Verification) passed | "Software validation (System Verification)" performed and product "met the acceptance criteria" |
Clinical comparison demonstrates similar performance to predicate | "clinical comparison study was conducted which compared SphygmoCor CvMS side-by-side with the predicate. The tests results demonstrated similar performance between the two devices." |
No alteration of safety and effectiveness | "AtCor Medical has determined that the PWV software addition has not altered the safety and effectiveness of the device" |
2. Sample Size Used for the Test Set and Data Provenance
The document states, "a clinical comparison study was conducted." However, it does not specify the sample size used for this test set nor the data provenance (e.g., country of origin, retrospective or prospective nature of the study).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
The document does not provide information on the number of experts used or their qualifications for establishing ground truth for the test set. Given that the predicate device is also a non-invasive blood pressure and cardiac monitor, the "ground truth" for the comparison would likely be the measurements provided by the predicate device itself.
4. Adjudication Method for the Test Set
The document does not specify any adjudication method (e.g., 2+1, 3+1, none) for the test set.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
The document does not describe a multi-reader multi-case (MRMC) comparative effectiveness study. The clinical comparison mentioned is between two devices, not an assessment of human reader performance with and without AI assistance. Therefore, there is no effect size given for human readers improving with AI vs. without AI assistance.
6. Standalone (Algorithm Only) Performance
The document does not explicitly present a standalone (algorithm only) performance study with metrics like sensitivity, specificity, or accuracy. The focus is on the performance of the device (which includes the software/algorithm) as a whole, compared to a predicate device. The software verification and validation activities are mentioned, implying that the algorithm's functionality was tested, but not in terms of traditional standalone diagnostic performance metrics.
7. Type of Ground Truth Used
The type of ground truth for the clinical comparison study was based on the performance of a legally marketed predicate device. Specifically, the unmodified SphygmoCor CvMS (K070795) and the Vascular Profiling System VP-2000 (K013434) were used as predicates for equivalence. The study aimed to show "similar performance" to these established devices rather than against an independent, gold-standard ground truth like pathology or long-term outcomes data.
8. Sample Size for the Training Set
The document only refers to a clinical comparison study and internal design/verification activities. It does not mention a separate training set or its sample size for the development of the PWV algorithm. It describes the PWV option as a "modular software addition" that calculates PWV using existing tonometry and ECG capabilities from the predicate device. This suggests that the algorithm leverages established physiological principles rather than being a machine learning model requiring a distinct training set in the typical sense.
9. How Ground Truth for the Training Set Was Established
Since a distinct "training set" for a machine learning algorithm is not mentioned, the document does not describe how ground truth for such a set was established. The PWV calculation method is explicitly defined as "measuring the distance between the two arteries and then dividing by At" (where At is the time difference between two pressure waveforms using ECG as a timing reference), indicating a deterministic algorithmic approach rather than a learned model from a labeled dataset.
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