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510(k) Data Aggregation
(328 days)
Regulation section:
21 CFR 862.3245
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- Classification:
Class II (Special Controls)
- Classification:
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Product Code: QKT Device Type: Clozapine test system Class: II (special controls) Regulation: 21 CFR 862.3245
The MyCare Psychiatry Clozapine Assay Kit is intended for the in vitro quantitative measurement of clozapine in adult human serum using automated clinical chemistry analyzers. Measurements obtained can be used to aid in the management of individuals prescribed clozapine for treatment-resistant schizophrenia. This assay should be used in conjunction with other clinical and laboratory findings and results from this test alone should not be used to make treatment decisions.
The MyCare Psychiatry Clozapine Assay Kit is a homogenous two reagent nanoparticle agglutination assay used for detection of clozapine in human serum. It is based on competition between drug and drug-conjugates for binding to drug-specific antibodies covalently bound to nanoparticles. The extent of particle aggregation can be followed spectrophotometrically on clinical chemistry analyzers. This aggregation is measured at a wavelength of around (b)(4) by automated clinical chemistry analyzers.
The assay contains:
- Reagent 1 (R1) reaction buffer that contains drug-conjugate in a buffered protein . solution
- . Reagent 2 (R2) - nanoparticle reagent that contains clozapine-specific monoclonal antibody bound to nanoparticles in a buffered solution
Here's a breakdown of the acceptance criteria and the study proving the MyCare Psychiatry Clozapine Assay Kit meets them, based on the provided text:
Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria/Study Goal | Reported Device Performance / Outcome |
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Precision/Reproducibility | To evaluate precision according to CLSI EP05-A3. (Demonstrate consistent results under repetitive conditions). | Achieved acceptable CVs (Coefficient of Variation) for within-run and total precision across various clozapine concentrations in serum pools, spiked serum, and controls. Total CVs ranged from 4.0% to 7.8%. |
Linearity/Reportable Range | To evaluate linearity across the measuring range of the assay following CLSI EP06-A. (Demonstrate accurate measurement across a range of concentrations). Claimed range: 68-1500 ng/mL. | Supports claimed measuring range of 68 to 1500 ng/mL. For the worst performing lot, linear regression showed: Slope = 0.920 (0.910 to 0.930), Intercept = 4.1 (1.4 to 6.8), R = 0.9985. |
Traceability | Traceability to a certified reference standard. (Ensure measurements are linked to accepted standards). | MyCare Psychiatry Calibrator Kit is traceable to a certified USP clozapine reference standard. Master calibrators verified by LC-MS/MS. |
Detection Limit | To determine Limit of Blank (LOB), Limit of Detection (LOD), and Limit of Quantitation (LOQ) according to CLSI EP17-A2. (Establish the lowest concentration the device can reliably detect and quantify). | LOB determined to be (b)(4) (specific value redacted, but determined and reported). LOD determined to be 39 ng/mL. LOQ determined to be 68 ng/mL. |
Analytical Specificity | Potentially Cross-Reacting Substances: Evaluate cross-reactivity with clozapine metabolites (Clozapine-N-oxide, 8-Hydroxy-8-deschloro-clozapine, Norclozapine) in the presence of clozapine. (Ensure the device measures clozapine specifically, without significant interference from related compounds). | No cross-reactivity exceeding ±10% was observed. Clozapine-N-oxide: 3%, 8-Hydroxy-8-deschloro-clozapine: 9%, Norclozapine: 1%. |
Endogenous & Exogenous Interfering Substances: Evaluate interference from various endogenous substances (Bilirubin, Hemolysate, Human IgG, Human Serum Albumin, Rheumatoid Factor, Triglycerides) and a wide range of exogenous drugs. (Ensure other common substances in blood or co-administered drugs do not significantly affect results). | None of the tested endogenous or exogenous substances were found to lead to clinically significant interference (> ±10%) for the device at the tested concentrations. (Extensive list of compounds tested and reported as having no significant interference). | |
Method Comparison Study | To compare results from the MyCare Psychiatry Clozapine Assay Kit with a validated clozapine LC-MS/MS method using clinical samples. (Demonstrate agreement with a gold standard method). | Deming regression analysis showed: y = 1.037 (0.939 to 1.135) x - 27.8 (-78.3 to +22.7); R = 0.9269. |
Accuracy (difference within LC-MS/MS) was 30% within 10% for 68-350 ng/mL range, 34% within 10% for 350-1000 ng/mL range, and 50% within 10% for 1000-1500 ng/mL range. |
Important Note: The document consistently contains redacted information, marked as (b)(4), particularly for specific numerical values (e.g., sample sizes, number of replicates, actual LOB values). This means some of the specific "Reported Device Performance" details are generalized based on the description of the study rather than exact numbers.
Study Design Details
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Sample sizes used for the test set and the data provenance:
- Precision Study:
- N=480 for each of the 9 samples/controls tested across all reagent lots and analyzers (9 * 480 = 4320 total measurements for precision).
- Provenance: Clinical samples from patients taking clozapine therapy for serum pools; spiked serum samples; control materials. Data is likely retrospective or a mix, prepared as described from clinical samples and spiked.
- Linearity Study:
- 11 different clozapine levels, each tested in 5 replicates, using 3 lots of reagents and 2 analyzers. (11 levels * 5 replicates * 3 lots * 2 analyzers = 330 measurements).
- Provenance: Samples prepared by pooling human serum specimens and spiking with clozapine.
- Detection Limit Studies:
- LOB: Each of the "n=" (redacted) serum samples tested in duplicate on 3 different days on 2 different analyzers for "n=" (redacted) runs, using "lots" (redacted) of reagents.
- LOD: Each of the "n=" (redacted) human serum samples tested in duplicate on 3 different days on "n=" (redacted) different analyzers for "n=" (redacted) runs, using "lots" (redacted) of reagents.
- LOQ: Each of the 4 individual normal human serum samples tested "n=" (redacted) times on "b)(4)" (redacted) different days on "analyzer" (singular, redacted), using "lots" (redacted) of reagents.
- Provenance: Normal human serum samples, some spiked with clozapine.
- Analytical Specificity (Cross-reactivity & Interference):
- Cross-reactivity: (b)(4) (redacted) replicates per compound.
- Interference: Each sample tested at a minimum of 5 runs.
- Provenance: Human serum pools for interference studies.
- Method Comparison Study:
- (b)(4) (redacted) samples were used for Deming regression.
- Counted samples in ranges provided: 50 + 71 + 2 = 123 unique samples or measurements explicitly tabulated, though the total for Deming regression is redacted.
- Provenance: Clinical samples collected at six different U.S. clinical sites from patients receiving clozapine therapy. This indicates prospective collection from diverse U.S. clinical settings.
- Precision Study:
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):
- This is a quantitative assay (measuring clozapine concentration), not an imaging or diagnostic interpretation task that typically requires expert readers for ground truth.
- The ground truth for the method comparison study was established by a "validated clozapine LC-MS/MS method." LC-MS/MS (Liquid Chromatography-Mass Spectrometry/Mass Spectrometry) is a highly accurate and sensitive analytical technique often considered a "gold standard" for precise quantification of small molecules in biological samples. It does not involve human expert interpretation in the same way as, for example, a radiologist reading an MRI.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. As a quantitative assay compared to an analytical gold standard (LC-MS/MS), there's no "adjudication" in the sense of reconciling differing human interpretations. The LC-MS/MS results serve as the objective reference.
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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. This is a device for measuring a chemical concentration, not an AI-assisted diagnostic tool that would typically involve human readers.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Yes, implicitly. The entire performance evaluation (precision, linearity, detection limits, specificity, and method comparison) assesses the standalone analytical performance of the assay kit (the "algorithm" equivalent in this context, though it's a biochemical assay, not software) on an automated clinical chemistry analyzer, without human interpretation as part of its measurement function. Human input is for sample preparation, loading, and instrument operation, but not for the actual clozapine measurement itself.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The primary ground truth used for the method comparison study was a validated clozapine LC-MS/MS method. This is an analytical gold standard.
- For other analytical performance characteristics (precision, linearity, detection limits), the ground truth was established by preparation of samples with known concentrations (e.g., spiking clozapine into serum).
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The sample size for the training set:
- This is an in vitro diagnostic (IVD) assay kit, not a machine learning algorithm that requires a "training set" in the conventional sense. The "development" of such a kit involves chemical formulation, optimization of reagents, and validation of the measurement principles, not data-driven model training.
- Therefore, there is no discrete "training set" of patient data as might be found for an AI/ML device.
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How the ground truth for the training set was established:
- Not applicable, as there's no "training set" for this type of device. The "ground truth" during the development of the assay would have been established by precisely preparing solutions of known clozapine concentrations and optimizing the assay's chemical reactions and detection parameters to accurately reflect those concentrations.
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