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510(k) Data Aggregation
(274 days)
The NoCoding1 Plus Blood Glucose Monitoring System is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertip. The NoCoding1 Plus Blood Glucose Monitoring System is intended for self-testing outside the body (for in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The system is intended to be used by a single person and should not be shared. It is not intended for use on neonates and is not for the diagnosis or screening of diabetes.
The NoCoding1 Blood Glucose Test Strips are for use with the NoCoding1 Plus Blood Glucose Meters to quantitatively measure glucose in fresh capillary whole blood samples drawn from the fingertip.
The NoCoding1 Glucose Control Solutions are for use with the NoCoding1 Plus Blood Glucose Meters and NoCoding1 Blood Glucose Test Strips to check that the meter and the test strips are working together properly and that the test is performing correctly.
The NoCoding1 Plus Blood Glucose Monitoring System (BGMS) consists of a blood glucose meter, single use test strips, and control solutions with two different glucose concentrations (“Control A" and "Control B" ranges). The NoCoding1 Plus BGMS is based on an electrochemical biosensor technology (electrochemical). The System measures the glucose level in whole blood samples using a small electrical current generated in the test strips.
The following items are included in the NoCoding1 Plus Blood Glucose Monitoring system:
- 1 NoCoding1 Plus Blood Glucose Meter
- 10 NoCoding1 Blood Glucose Test Strips
- 1 Lancing device
- 10 Lancets
- 1 Owner's Booklet
- 1 Quick Reference Guide
- 2 Batteries (3.0V lithium batteries)
The following items are compatible with the NoCoding1 Plus BGMS and are available separately.
NoCoding1 Glucose Control Solution (cleared in K080923)
Here's a breakdown of the acceptance criteria and study details for the NoCoding1 Plus Blood Glucose Monitoring System, based on the provided document:
Acceptance Criteria and Reported Device Performance
The document states that the NoCoding1 Plus BGMS was tested in accordance with ISO 15197, which would define the acceptance criteria for its analytical performance. While specific numerical acceptance criteria from ISO 15197 are not explicitly listed in detail for each test alongside the device's reported performance, the summary consistently states that the device met the acceptance criteria for each test. For tests where specific numerical acceptance criteria are mentioned (e.g., linearity, hematocrit effect), they are presented alongside the observed performance.
Note: The provided text refers to "Primary and Reference criteria" being met for user performance, which likely corresponds to the ISO 15197 accuracy requirements (e.g., within ±15 mg/dL or ±15%).
| Acceptance Criteria (from ISO 15197, or implied from context) | Reported Device Performance (NoCoding1 Plus BGMS) |
|---|---|
| Repeatability Test: | The pooled SD for concentration intervals 1 and 2 were 1.9 and 2.1 mg/dL, respectively (below 5.0 mg/dL). The pooled CV% for concentration intervals 3, 4, and 5 were 2.8%, 2.6%, and 3.2%, respectively (below 5.0%). All three lots met the acceptance criteria. |
| Intermediate Precision: | The pooled SD for concentration interval 1 was 1.4 mg/dL. The pooled CV for concentration intervals 2 and 3 were 3.0% and 2.4%, respectively. Met the acceptance criteria. |
| Linearity Test: | Acceptance Criteria: Within ±10 mg/dL for glucose concentrations <100 mg/dL and within 10% for glucose concentrations ≥100 mg/dL. Precision maintained under 5 mg/dL for <100 mg/dL (SD) and 5% for ≥100 mg/dL (CV). Linear correlation coefficient (r²) well above 0.98. Reported Performance: All data points were within ±10 mg/dL for <100 mg/dL and within 10% for ≥100 mg/dL. Precision was maintained under 5 mg/dL (SD) for <100 mg/dL and 5% (CV) for ≥100 mg/dL. Linear correlation coefficients (r²) for all strip lots were well above 0.98. |
| Hematocrit Effect Test: | Acceptance Criteria: Less than 10 mg/dL bias for glucose <80 mg/dL and less than 10% for glucose >100 mg/dL. Reported Performance: Biases of individual BGMS measurements from YSI were less than 10 mg/dL and 10% below 80 mg/dL and above 100 mg/dL, respectively. No significant interference within 15% to 65% hematocrit levels. |
| Interference Test: | Acceptance Criteria: No significant effect on glucose measurement from interferents. Reported Performance: The 24 interferents studied showed no effect on glucose measurement at both low and high glucose concentration intervals. |
| Altitude Test: | Acceptance Criteria: Individual results not showing significant difference (±10%) with respect to reference equipment or different altitudes. Reported Performance: Individual results did not show significant difference (±10%) with respect to the reference equipment, nor with different altitudes at all glucose concentrations. No systematic response to altitudes up to 10,000 feet (3,048m). |
| Operating Condition Test: | Acceptance Criteria: Individual meter measurements giving less than 10 mg/dL or 10% bias from YSI reference results. Reported Performance: Individual meter measurements gave less than 10 mg/dL or 10% bias from YSI reference results. Operates normally at presented conditions (6°C to 44°C and 10% to 90% RH). |
| Sample Volume Test: | Acceptance Criteria: Meter bias from YSI within acceptance criteria. Reported Performance: The smallest volume required for accurate measurement was 0.5 uL, and the meter bias from YSI was all within the acceptance criteria. |
| User Performance (Accuracy): | Acceptance Criteria (implied from meeting "Primary and Reference criteria," likely based on ISO 15197): - For glucose concentration < 75 mg/dL: likely a high percentage within ±5 mg/dL, ±10 mg/dL, etc. - For glucose concentration ≥ 75 mg/dL: likely a high percentage within ±5%, ±10%, etc. Reported Performance: - Glucose < 75 mg/dL (n=41): 61.0% within ±5 mg/dL, 97.6% within ±10 mg/dL, 100% within ±15 mg/dL. - Glucose ≥ 75 mg/dL (n=330): 70.0% within ±5%, 96.1% within ±10%, 100% within ±15%, 100% within ±20%. |
| User Performance (Usability): | Acceptance Criteria: Users find the device easy to follow and use. Reported Performance: 100% of data met Primary and Reference criteria. More than 100% of subjects gave scores above 3 (neither easy nor difficult) on the questionnaire, confirming the User's Guide is easy to follow and the device is easy to use. |
Study Information:
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Sample sizes used for the test set and the data provenance:
- Analytical Performance Tests (Repeatability, Intermediate Precision, Linearity, Hematocrit, Interference, Altitude, Operating Condition, Sample Volume): The specific number of individual samples (e.g., blood solutions) tested varies per experiment. For example, linearity involved 9 concentration intervals, tested once with 5 meters per lot across 3 lots. Hematocrit effect involved 3 glucose intervals x 7 hematocrit levels, tested for 3 lots of strips.
- User Performance Study:
- Test Participants: 371 diabetic and pre-diabetic individuals.
- Provenance: The study was conducted at "three clinical sites," implying a prospective study. The country of origin is not explicitly stated for the participant data, but the manufacturer is based in Seoul, Korea, so it's likely Korean or a similar demographic.
- Naive Subjects: Approximately 10% to 15% were "naive subjects" (never exposed to using BGMS on their own).
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- For the analytical performance tests (linearity, hematocrit, interference, altitude, operating condition, sample volume), the ground truth was established by a Yellow Springs Instrument (YSI), which is a laboratory comparator method known for its accuracy in glucose measurement. This is a highly accurate chemical analysis method, not an expert human interpretation.
- For the user performance study, the blood glucose measurements from the NoCoding1 Plus BGMS were compared against an unstated "reference" (likely also a YSI or similar high-accuracy lab method, as implied by other tests and typical BGMS validation). The ground truth was based on these objective reference measurements, not expert human assessment of BGMS readings.
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Adjudication method for the test set:
- Not applicable in the traditional sense of image interpretation or clinical diagnosis. The tests involved objective analytical measurements (device reading vs. YSI reference) and user questionnaire responses. There was no mention of human expert adjudication of results for accuracy.
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If a multi-reader multi-case (MRMC) comparative effectiveness study was done:
- No, a multi-reader multi-case (MRMC) comparative effectiveness study in the context of diagnostic imaging (which often involves human reader performance with and without AI assistance) was not done. This device is a Blood Glucose Monitoring System, which does not involve human interpretation of complex data for diagnosis in the same way imaging AI does. The user performance study involved users operating the device and comparing its readings to a reference, not human readers interpreting device-generated "cases."
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Yes, the majority of the analytical performance tests (Repeatability, Intermediate Precision, Linearity, Hematocrit Effect, Interference, Altitude, Operating Condition, Sample Volume Tests) represent standalone performance of the device (meter + strip) without human-in-the-loop decision-making. The measurements are automated, and the results are compared against a laboratory reference standard (YSI).
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The type of ground truth used:
- Laboratory Reference Standard: The primary ground truth for all analytical accuracy assessments (Linearity, Hematocrit, Interference, Altitude, Operating Condition, Sample Volume, and the underlying accuracy of Repeatability and Intermediate Precision) was a Yellow Springs Instrument (YSI), described as a "laboratory comparator method."
- For the user performance study, the device's measurements were compared against an unstated "reference" which, given the context, is also likely a YSI or similar high-accuracy laboratory method.
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The sample size for the training set:
- The document describes performance testing for regulatory submission (510(k)) and does not mention a training set in the context of machine learning or AI. This is a traditional medical device (blood glucose meter) validation, not an AI/ML-based device that typically requires a large training dataset.
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How the ground truth for the training set was established:
- Not applicable, as no training set for an AI/ML algorithm was mentioned or appears to be part of this device's validation.
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(110 days)
The BaseSens I Blood Glucose Monitoring System is used for the quantitative measurement of glucose levels in capillary whole blood as an aid in monitoring the effectiveness of diabetes management at home or in clinical settings. The BaseSens I Blood Glucose Monitoring System should be used only for testing outside the body (in vitro diagnostic use only). The BaseSens I Blood Glucose Monitoring System is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates. Testing sites include the fingertip along with alternate sites testing (AST) on the forearm, palm, thigh and calf. AST in this system can be used only during steady-state blood glucose conditions.
BaseSens I Test Strip is used with the BaseSens I Blood Glucose Meter for quantitatively measuring glucose in capillary whole blood. The BaseSens I Test Strip is intended for self-testing outside the body (in vitro diagnostic use only). The BaseSens I Test Strips are not intended for the diagnosis of or screening for diabetes mellitus, and are not intended for use on neonates. Testing sites include the fingertip along with alternate sites testing (AST) on the forearm, palm, thigh and calf. AST in this system can be used only during steady-state blood glucose conditions.
BaseSens I Control A&B Solutions are a red liquid to check that both the meters and test strips are working together properly. It contains a known range of glucose as written on the bottle.
The BaseSens I Blood Glucose Monitoring System is identical to the i-Sens CareSens N Blood Glucose Monitoring System. The Hygieia BaseSens I Blood Glucose Monitoring System is a rebranded CareSens N System. Rebranding here is intended to be understood as all components of the CareSens N System have been relabeled with the Hygieia name BaseSens I or BaseSens I Blood Glucose Monitoring System.
The System includes the BaseSens 1 blood glucose meter, test strips and controls.
The provided document describes the "BaseSens I Blood Glucose Monitoring System". However, it's a rebranding of an existing device, the i-Sens CareSens N Blood Glucose Monitoring System (FDA clearance K083468). The document explicitly states: "The BaseSens I Blood Glucose Monitoring System is identical to the i-Sens CareSens N Blood Glucose Monitoring System. The Hygieia BaseSens I Blood Glucose Monitoring System is a rebranded CareSens N System."
Therefore, this filing does not present a new study to prove "device meets the acceptance criteria". Instead, it argues for substantial equivalence based on the predicate device's existing clearance. The crucial statement in the document is: "The BaseSens I Blood Glucose Monitoring System does not raise any new safety and efficacy concerns when compared to the cleared CareSens N Blood Glucose Monitoring System." This implies that the acceptance criteria and performance were already met by the predicate device.
Since this is a re-branding application, it does not include a new study with specific acceptance criteria and performance data for the BaseSens I device. It relies on the previously submitted data and clearance of the i-Sens CareSens N.
Therefore, for the request, I will extract relevant information about the predicate device's characteristics and the basis for substantial equivalence, as no new study data is presented for the BaseSens I device itself.
Acceptance Criteria and Device Performance (Based on Substantial Equivalence to Predicate Device)
Given that the BaseSens I Blood Glucose Monitoring System is a rebranding and identical to the i-Sens CareSens N Blood Glucose Monitoring System, the acceptance criteria and reported performance would be those established for the i-Sens CareSens N Blood Glucose Monitoring System during its original FDA clearance (K083468). This document does not provide a table of acceptance criteria or specific performance data for the BaseSens I. It relies on the fact that its specifications are identical to the predicate.
Key specifications for both devices, implying the performance targets, are:
| Item | BaseSens I BGMS | CareSens N BGMS |
|---|---|---|
| Enzyme | Glucose Oxidase | Glucose Oxidase |
| Measurement Principle | Amperometric method | Amperometric method |
| Test Principle | Glucose oxidase chemical reaction. The instrument measures the extent of current cause by presence of glucose in sample. | Glucose oxidase chemical reaction. The instrument measures the extent of current cause by presence of glucose in sample. |
| Intended use | Quantitatively measure glucose in capillary whole blood in vitro (outside the body) | Quantitatively measure glucose in capillary whole blood in vitro (outside the body) |
| Sample | Fresh capillary whole blood | Fresh capillary whole blood |
| Electrode | Carbon | Carbon |
| Calibration | Plasma-equivalent | Plasma-equivalent |
| Test Time (seconds) | 5 | 5 |
| Sample volume (µL) | 0.5 | 0.5 |
| Memory | 250 | 250 |
| Test Range(mg/dL) | 20~600 | 20~600 |
| Hematocrit range (%) | 20~60 (below 400mg/dL) | 20~60 (below 400mg/dL) |
| Glucose units | Either mg/dL or mmol/L | Either mg/dL or mmol/L |
| Checking the system | Control solution | Control solution |
| Alternate Site Capability | Yes | Yes |
| Operating Humidity | 10~90% | 10~90% |
Note: This table details device characteristics that presumably met acceptance criteria in the predicate's original submission. This document does not contain specific numerical performance metrics (e.g., accuracy percentages, bias) or a direct comparison to predefined acceptance criteria for the BaseSens I.
Study Information (Based on Substantial Equivalence)
Since this is a rebranding, there is no new study performed or described in this document to prove the BaseSens I meets acceptance criteria. The claim of substantial equivalence is based on the predicate device (i-Sens CareSens N). Therefore, the following information is not applicable to this specific 510(k) submission but would have been part of the predicate device's original submission (K083468).
- Sample size used for the test set and the data provenance: Not provided in this document, as no new study was conducted for the BaseSens I. This would have been part of the predicate's original submission.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable.
- Adjudication method for the test set: Not applicable.
- 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: Not applicable. This device is a blood glucose monitoring system, not an AI-based diagnostic imaging tool, and does not involve human readers interpreting cases.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: The device is a standalone blood glucose meter. Its performance would be assessed as such, but no new standalone performance study is presented here.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For blood glucose monitoring systems, ground truth is typically established by laboratory reference methods (e.g., YSI analyzer) for glucose concentration. This information is not explicitly stated in this document but would have been used for the predicate device's performance claims.
- The sample size for the training set: Not applicable, as this is a physical medical device (blood glucose meter and strips), not a machine learning algorithm requiring a "training set" in the conventional sense. Its calibration and operational parameters are set during manufacturing and validation, which would correspond to a rigorous design and verification process, not a "training set" for AI.
- How the ground truth for the training set was established: Not applicable for the same reasons as above.
In summary: The provided document is a 510(k) submission for a rebranded medical device. It asserts substantial equivalence to a legally marketed predicate device (i-Sens CareSens N) because the devices are identical. As such, it does not present new acceptance criteria or new study data. All performance claims and conformity to acceptance criteria for the BaseSens I are implicitly covered by the predicate device's prior FDA clearance.
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