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510(k) Data Aggregation

    K Number
    DEN200040
    Device Name
    OMNIgene GUT Dx
    Manufacturer
    Date Cleared
    2021-11-03

    (506 days)

    Product Code
    Regulation Number
    866.2952
    Type
    Direct
    Reference & Predicate Devices
    N/A
    Predicate For
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Regulation section:
    21 CFR 866.2952

    |
    | Regulation: | 21 CFR 866.2952

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    OMNIgene. GUT Dx is intended for the non-invasive collection of human fecal samples and the stabilization of DNA from the bacterial community for subsequent assessment of the microbiome profile by an assay validated for use with OMNIgene GUT Dx.

    Device Description

    The OMNIgene . GUT Dx device consists of a collection tube with a tube top and pusher cap with a screw seal, along with a spatula or spoon for transferring fecal specimen into the collection tube. The tube contains 2 mL of the stabilizing liquid and a stainless-steel mixing ball. These components are intended to stabilize bacterial DNA in human fecal specimens. notably to preserve the relative abundances of bacterial organisms, for potential downstream analysis of the fecal microbiome. The collection device is designed for storage of fecal specimens at room temperature (20-26°C/68-79°F) for up to 30 days.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the studies conducted to prove the OMNIgene.GUT Dx device meets these criteria, based on the provided text:

    Acceptance Criteria and Reported Device Performance

    The device's performance was evaluated through several analytical studies focusing on DNA yield, microbial community neutrality (preservation of relative abundances), and stability at room temperature, as well as reproducibility.

    Table of Acceptance Criteria and Reported Device Performance

    Performance CharacteristicAcceptance CriteriaReported Device PerformanceStudy Section
    DNA Yield≥ 120 ng (0.12 µg) per extraction aliquot in ≥ 95% of samples (Neutrality Study)100% of specimens met the DNA yield acceptance criteria of 120 ng (0.12 µg) for both adult and pediatric cohorts. (Neutrality Study Results)L.1.b, Neutrality results; L.1.c, Reproducibility results
    ≥ 120 ng (0.12 µg) per extraction aliquot in ≥ 95% of samples (Room Temperature Storage Stability Study)100% of specimens met the DNA yield acceptance criteria of 120 ng (0.12 µg) for both adult and pediatric cohorts. (Room Temperature Storage Stability Results)
    ≥ 120 ng (0.12 µg) per extraction aliquot in ≥ 95% of samples (Reproducibility Study)100% of specimens for both lot-to-lot and aliquot-to-aliquot reproducibility met the DNA yield acceptance criteria of 120 ng (0.12 µg).
    Microbial Community Neutrality (Relative Abundance Preservation)Per donor, each Microbiome Panel species in the stored sample has read counts within the TeSaRCol (Test Sample Read Count Limit) range as calculated using the unstabilized Control Baseline. Neutrality demonstrated in ≥ 90% of donors that were successfully screened to contain that species.All species examined as part of the Microbiome Panel demonstrated neutrality in ≥ 90% of donors between unstabilized and OMD-200 fecal samples. Whole Microbiome Analysis: Group wise comparison of Aitchison distance showed change in microbial profile was significantly lower between OMD-200 collected fecal samples at baseline and unstabilized control fecal samples than observed donor-to-donor differences (P < 0.0001). No taxa had a differential abundance exceeding measured within-group variance (effect size < 1, adjusted P-value > 0.1). PCA and hierarchical clustering showed intra-donor clustering.L.1.b, Neutrality Acceptance Criteria; Neutrality Results; L.1.e, Neutrality (Whole Microbiome) Results
    Room Temperature Storage StabilityPer donor, each Microbiome Panel species in the stored sample has read counts within the TeSaRCol range as calculated using the OMD Baseline. Stability demonstrated in ≥ 90% of donors that were screened to contain that species.All species examined as part of the Microbiome Panel demonstrated stability in ≥ 90% of donors when stored at room temperature for up to 30 days either with or without the addition of OM-LQR. Whole Microbiome Analysis: Group wise comparison of Aitchison distance showed no difference between stability time points (P > 0.05) and change was significantly lower than observed donor-to-donor differences (P < 0.0001). No taxa had a differential abundance exceeding measured within-group variance (effect size < 1, adjusted P-value > 0.1).L.1.b, Room Temperature Storage Stability Acceptance Criteria; Stability Results; L.1.e, Stability (Whole Microbiome) Results
    ReproducibilityCV of classified read counts post-rarefaction < 30% for each Microbiome Panel Species between all samples per donor (lot-to-lot assessment) or between all aliquots per donor (aliquot-to-aliquot assessment). Consistency demonstrated in ≥ 90% of donors per Microbiome Panel species.Consistency of microbial composition demonstrated by a CV ≤ 30% for each Microbiome Panel Species of all donors investigated as part of both lot-to-lot and aliquot-to-aliquot assessments. Lot-to-lot: Max CV 21.95%, Overall pass rate 100%. Aliquot-to-aliquot: Max CV 32.48% (with 99.4% overall pass rate). Whole Microbiome Analysis: Aitchison distance showed lot-to-lot and aliquot-to-aliquot differences were significantly lower than stability time points; magnitude and variability much less than between donor changes (P < 0.0001). PCA showed intra-donor clustering.L.1.c, Reproducibility Acceptance Criteria; Reproducibility Results; L.1.e, Reproducibility (Whole Microbiome) Results

    Study Details

    1. Sample Sizes and Data Provenance

    • Test Set Sample Sizes:
      • Neutrality Study: 30 total donors (Adult Cohort: minimum 30 donors, Pediatric Cohort: minimum 30 donors initially, but final dataset included 30 total after screening; tables indicate "45" collected, "30" in final dataset for adults and 30 total for pediatrics with specific sub-cohort counts).
      • Room Temperature Storage Stability Study: 30 total donors (same 30 OMD-200 baseline samples from Neutrality Study, plus additional samples for different time points/conditions).
      • Reproducibility Study (Lot-to-lot & Aliquot-to-aliquot): 14 donors in the final dataset (adult cohort, screened).
    • Data Provenance:
      • Human fecal specimens collected from adult and pediatric donors.
      • Specimens were collected under an Institutional Review Board (IRB) approved protocol and informed consent was obtained.
      • Retrospective/Prospective: Primarily prospective or collected for the purpose of these studies (e.g., "Fecal collection occurred at either the donor's home or a collection site").
      • Country of Origin: Not explicitly stated, but implies a US-based study given the FDA regulatory context and IRB mention.

    2. Number of Experts and Qualifications for Ground Truth

    • Number of Experts: Not applicable. These studies are analytical performance assessments of a collection device, not diagnostic interpretation by human experts. The "ground truth" is derived from the WGS assay results of unstabilized (fresh) fecal samples and the established quantification limits for bacterial species.
    • Qualifications: N/A

    3. Adjudication Method for the Test Set

    • Adjudication Method: Not applicable. This is an analytical performance study, not one requiring adjudication by human readers/experts for a diagnostic outcome. The primary measurements are DNA yield and relative read counts of specific bacterial species.

    4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • MRMC Study: No. This type of study is not relevant for evaluating the performance of a sample collection and stabilization device. MRMC studies are typically used for evaluating the effectiveness of diagnostic imaging tools or AI algorithms that assist human interpretation.

    5. Standalone Performance (Algorithm Only)

    • Standalone Performance: Not applicable in the traditional sense of an "algorithm." The device itself is a collection and stabilization tool. Its "performance" is assessed by its ability to preserve the biological sample's integrity for downstream analysis. The "algorithms" used are bioinformatics analyses (WGS, CLR transformation, Aitchison distance, ALDEx2, Shannon's index, PCA) to quantify changes in the microbial community, not algorithms that provide a diagnostic output on their own.

    6. Type of Ground Truth Used

    • Ground Truth:
      • Analytical Ground Truth: Unstabilized (fresh) fecal samples collected from the same donors, processed immediately, serving as the "baseline" or "in vivo state" for comparison of microbial community composition.
      • Quantitative Ground Truth: Established Limit of Blank (LoB), Limit of Detection (LoD), Lower Limit of Quantitation (LLoQ), Upper Limit of Quantitation (ULoQ), and corresponding Baseline Read Count Limits (BRCLs) and Test Sample Read Count Limits (TeSaRCol) for a defined Microbiome Panel of bacterial species. These limits provide quantitative thresholds for acceptable performance.

    7. Sample Size for the Training Set

    • Training Set Sample Size:
      • The document implies that the WGS Assay Validation section (L.1.a) describes the process of establishing the LoQ values and BRCLs for the Microbiome Panel species. This can be considered analogous to a "training" or "assay establishment" phase.
      • The specific sample size for that validation is not explicitly stated in terms of number of donors or samples for each bacterial species to define these limits. However, it mentions using "contrived sample sequencing and analysis" and calculations based on the LoQ values.

    8. How the Ground Truth for the Training Set was Established

    • Ground Truth for Training/Assay Validation:
      • The "ground truth" for defining the WGS assay limits (LoB, LoD, LLoQ, ULoQ) and subsequently the BRCLs and TeSaRCols was established through analytical validation methods. This involved:
        • Defining a Microbiome Panel (MP) of bacterial species based on criteria like prevalence, abundance, phylogenetic representation, and GC content, plus specific pathogenic/pediatric species.
        • Using "Background DNA Mixture (BDM)" as a diluent for determining LoD, LoQ, and Range.
        • Establishing these limits through quantitative experimental procedures (e.g., "contrived sample sequencing and analysis") to determine the lowest and highest amounts of analyte that can be determined with acceptable precision and trueness.
        • The BRCLs were calculated based on these LLoQ and ULoQ values for each species, ensuring that baseline samples fell within the quantifiable range of the WGS assay.

    In summary, the device's performance was rigorously evaluated through analytical studies using well-defined quantitative acceptance criteria related to DNA preservation, microbial community neutrality, and stability, with comparisons made against immediate processing of unstabilized samples from the same donors to establish "ground truth" for its performance claims.

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