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510(k) Data Aggregation
(450 days)
France
Re: K240795
Trade/Device Name: Withings ECG App
Regulation Number: 21 CFR 870.2345
Regulation Name:** Electrocardiograph software for over-the-counter use
Regulation Number: 21 CFR 870.2345
Withings | Apple, Inc | NA |
| 510(k) | Not assigned | K201525 | NA |
| Regulation Number | 21 CFR 870.2345
| 21 CFR 870.2345 | Identical |
| Class | Class II | Class II | Identical |
| 510(k) Review Panel |
The Withings ECG App is a software-only device intended for use with the ScanWatch to create, record, store, transfer and display a single channel electrocardiogram (ECG) similar to a Lead I ECG. The Withings ECG App determines the presence of atrial fibrillation (AFib), sinus rhythm and high heart rate (no signs of AFib with heart rate 100-150 bpm) on a classifiable waveform. The Withings ECG App is not recommended for users with other known arrhythmias.
The Withings ECG App is intended for over-the-counter (OTC) use. The ECG data displayed by the Withings ECG App is intended for informational use only. The user is not intended to interpret or take clinical action based on the device output without consultation of a qualified healthcare professional. The ECG waveform is meant to supplement rhythm classification for the purposes of discriminating AFib from normal sinus rhythm and not intended to replace traditional methods of diagnosis or treatment.
The Withings ECG App is intended to supplement rhythm classification for the purposes of discriminating AFib from normal rhythms. The device is not intended to replace traditional methods or diagnosis.
The ECG acquired by ScanWatch is not intended for manual and/or automated measurement of QT-interval.
The Withings ECG app is not intended for use by people under 22 years old.
The Withings ECG App is a software only mobile medical application that has two components:
- Withings ECG Watch App
- Withings ECG Phone App
The Withings ECG Watch App is integrated on the Withings ScanWatch, model number hwa10. The Withings ECG Watch App analyzes the data collected by electrodes on the Withings ScanWatch to generate an ECG waveform similar to a Lead I, calculate the average heart rate and provide rhythm classification to the user for a given 30 second session.
Withings ECG Watch App consists of a software library called ECG-SW2 library. The ECG-SW2, is a software library that includes an algorithm that processes the raw ECG signals and a tracing filter that filters the ECG signal to provide the user an output on the user interface (watch and smartphone).
The Withings ECG Phone App contains the installation steps, tutorial and the instructions for use that the user must review prior to taking an ECG reading. The Withings ECG Phone App is included in the Withings App, which displays the ECG results and also allows the user to store, manage and share health data.
Here's a breakdown of the acceptance criteria and the study proving the device meets those criteria, based on the provided FDA 510(k) clearance letter for the Withings ECG App:
Overall Summary of the Study:
The Withings ECG App's performance was evaluated through a pivotal, prospective, multi-center clinical trial. This trial assessed the device's ability to accurately classify ECG recordings into Atrial Fibrillation (AFib), sinus rhythm, and high heart rate (no AFib) compared to a cardiologist's rhythm classification from a simultaneously collected 12-lead ECG (the ground truth). Non-clinical testing, including database testing of the algorithm and human factors studies, also supported the device's safety and effectiveness.
1. Table of Acceptance Criteria and Reported Device Performance
The clearance letter does not explicitly state pre-defined "acceptance criteria" as distinct numerical thresholds to be met. Instead, it describes the results achieved by the device, which implicitly serve as the demonstration of acceptable performance to the FDA. The performance metrics presented are sensitivity and specificity for AFib and sinus rhythm classification.
Performance Metric | Acceptance Criteria (Implied by achieved performance) | Reported Device Performance |
---|---|---|
AFib Classification (HR 50-150 bpm) | High sensitivity for detecting AFib in classifiable recordings. | 99.7% Sensitivity |
Sinus Rhythm Classification (HR 50-150 bpm) | High specificity for identifying sinus rhythm in classifiable recordings. | 99.8% Specificity |
Waveform Morphology - PQRST Visibility | High agreement with 12-lead reference ECG. | P-waves: 95.3% |
QRS Complexes: 100% | ||
T-waves: 100% | ||
Waveform Morphology - Polarities | High agreement with 12-lead reference ECG. | P-waves: 100% |
T-waves: 99.6% |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Clinical Test Set: Approximately 626 subjects.
- 219 in the Atrial Fibrillation cohort
- 369 in the normal sinus rhythm cohort
- 33 had other arrhythmias
- 5 were uninterpretable
- Data Provenance:
- Clinical Trial: Pivotal, prospective, multi-center clinical trial. The specific countries are not mentioned for the clinical trial itself, but the training data (Deep Train) is described as being from the European Union, and Heartbeats from the United States. Given the FDA clearance, it's highly probable the pivotal clinical trial included data from the U.S. or other regions acceptable to the FDA.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
- Number of Experts: At least one cardiologist was used for ground truth establishment. The use of "a cardiologist" in the singular suggests a primary determination, though it's common practice for such a determination to be peer-reviewed or confirmed by a panel in high-stakes clinical trials. The document explicitly states: "Rhythm classification of a 12-lead ECG by a cardiologist was compared to the rhythm classification of a simultaneously collected ECG from the Withings ECG App."
- Qualifications of Experts: Cardiologist. Further details on experience (e.g., years of experience, board certification) are not specified in the provided text.
4. Adjudication Method for the Test Set
The adjudication method is implied as comparison to a cardiologist's 12-lead ECG interpretation. While it states "Rhythm classification of a 12-lead ECG by a cardiologist was compared...", it doesn't describe a multi-reader adjudication process (e.g., 2+1 or 3+1). It points to a direct comparison with a single cardiologist's interpretation of the 12-lead ECG as the reference standard.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study involving human readers improving with AI vs. without AI assistance was not described in this document. The study focused on the device's standalone performance in classifying ECG rhythms against a clinical gold standard (cardiologist's 12-lead interpretation).
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Yes, a standalone performance study was done. The core of the clinical trial directly assessed the "Withings ECG App's ability to accurately classify an ECG recording" which is its algorithmic performance in classifying AFib, sinus rhythm, and high heart rate. The sensitivity and specificity numbers (99.7% and 99.8% respectively) are metrics of the algorithm's performance in this standalone capacity relative to the ground truth.
7. The Type of Ground Truth Used
The primary ground truth used was expert consensus / clinical diagnosis from a 12-lead ECG. Specifically, "Rhythm classification of a 12-lead ECG by a cardiologist" served as the reference standard.
8. The Sample Size for the Training Set
The document mentions two "user datasets" used for training and testing (via 4-Fold Cross Validation for hyperparameter tuning):
- "Deep train": n = 11,701
- "Heartbeats": n = 5,089
It's important to note that these datasets were used for initial training and hyperparameter tuning (4-Fold cross validations and act as train and test sets
). The "clinical study datasets" (HWA08 test, HWA08 CE, WEFA HWA09 part 1) were used as a "first layer of validation sets" to check generalization, and "WEFA HWA09 part 2" was a "second layer of validation after the software freeze". The pivotal clinical trial data (626 subjects) described under "Clinical Testing" was the independent, locked algorithm validation set for regulatory submission.
9. How the Ground Truth for the Training Set Was Established
The document provides the following for the "ML algorithm training and testing" datasets ("Deep train" and "Heartbeats"):
- It states these datasets were "user datasets".
- It does not explicitly detail how the ground truth for these training datasets was established. While the clinical trial's ground truth was a cardiologist's 12-lead ECG interpretation, the method for labeling the much larger training datasets is not provided in this excerpt. This is a common omission in 510(k) summaries which focus on the final validation. It's plausible they were labeled by a similar expert review process, potentially leveraging a larger pool of retrospectively acquired data.
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(176 days)
K243236**
Trade/Device Name: WHOOP ECG (electrocardiogram) Feature (1.0)
Regulation Number: 21 CFR 870.2345
software for over-the-counter use |
| Regulatory Class | Class II |
| Regulation Number | 21 CFR 870.2345
--|---|---|
| Product Code | QDA | QDA | Identical to the predicate |
| Regulation | 21 CFR 870.2345
| 21 CFR 870.2345 | Identical to the predicate |
| Device Class | Class II | Class II | Identical
Ambulatory ECG Systems)
Human Factors Validation
To address special control (4) under 21 CFR 870.2345
The WHOOP ECG Feature is a software-only mobile medical application intended for use with the WHOOP Strap to create, record, store, transfer, and display a single-channel electrocardiogram (ECG) qualitatively similar to a Lead I ECG. The WHOOP ECG Feature determines the presence of atrial fibrillation (AFib), normal sinus rhythm, low heart rate (≤ 50 beats per minute [bpm]), and high heart rate (≥ 100 bpm) on a classifiable waveform. The WHOOP ECG Feature is not recommended for users with other known arrhythmias.
The WHOOP ECG Feature is intended for over-the-counter (OTC) use. The ECG data displayed by the ECG Feature are intended for informational use only. The user is not intended to interpret or take clinical action based on the device output without the consultation of a qualified healthcare professional. The ECG waveform is meant to supplement rhythm classification for the purposes of discriminating AFib from normal sinus rhythm and is not intended to replace traditional methods of diagnosis or treatment.
The WHOOP ECG Feature is intended for use by adults 22 years of age and older.
The WHOOP ECG Feature is a software-only medical mobile application integrated into the consumer (non-device) WHOOP System. It consists of three medical device modules: ECG Strap Module, ECG Phone Module, and ECG Cloud Module.
The feature is designed to create, record, store, transfer, and display a single-channel electrocardiogram (ECG), qualitatively similar to a Lead I ECG. It analyzes ECG recordings collected via the ECG electrodes on the WHOOP Strap.
The ECG Strap Module firmware is integrated within the WHOOP Strap's firmware. The ECG Strap Module firmware contains the FDA-cleared B-Secur HeartKey Software Library (K200884) which is used to provide classification for a 30-second ECG spot check recording into corresponding WHOOP ECG Feature outputs: Normal Sinus Rhythm; AFib; Low Heart Rate; High Heart Rate; Inconclusive; and Unsuccessful Reading. Users must opt in and complete onboarding through the ECG Phone Module within the WHOOP Mobile Application before accessing the ECG Feature.
The ECG Cloud Module processes requests for ECG report generation. Users can download ECG reports in PDF format to their mobile device or share them via applications such as email or messaging.
The WHOOP ECG Feature is not intended to replace traditional diagnostic or treatment methods.
The provided FDA 510(k) clearance letter for the WHOOP ECG Feature offers details regarding its acceptance criteria and the study conducted to prove it meets those criteria. Here's a structured breakdown of the information:
Acceptance Criteria and Reported Device Performance
1. Table of Acceptance Criteria and Reported Device Performance
Classification Type | Acceptance Criteria (Implicit) | Reported Device Performance | Comments |
---|---|---|---|
AFib Classification (Sensitivity) | High sensitivity for detecting AFib (no explicit threshold provided, but common for medical devices is often >90%) | 96.2% sensitivity in classifying AFib (HR 50-150 bpm) in classifiable recordings. | This meets or exceeds typical expectations for AFib detection sensitivity. |
Normal Sinus Rhythm Classification (Specificity) | High specificity for classifying Normal Sinus Rhythm (no explicit threshold provided, but common for medical devices is often >90%) | 99.4% specificity in classifying sinus rhythm (HR 50-150 bpm) in classifiable recordings. | This meets or exceeds typical expectations for Sinus Rhythm detection specificity. |
Classifiable Waveforms | High percentage of classifiable waveforms. | The ECG Feature produced waveforms with acceptable signal quality 99.4% of the time. | This indicates a very high success rate for obtaining usable ECG data. |
Inconclusive Rate | Acceptable rate of inconclusive readings (no explicit threshold provided). | 11% of recordings were determined inconclusive. | Real-world performance for inconclusive and poor recording may differ. When including all inconclusive recordings: |
- Probability of AFib result for true AFib: 87.47%
- Probability of SR result for true SR: 96.59% |
| Morphology Assessment | Acceptable similarity of waveform morphology to reference ECG. | Comprehensive visual assessment demonstrated acceptable signal quality. Quantitative assessment compared key features (PR interval, QRS duration, R-wave amplitude, RR interval) with 12-lead reference. | Supported by clinical validation; differences do not raise new safety/effectiveness questions. |
| User Comprehension/Human Factors | Users can correctly use the device, interpret output, and understand when to seek medical care. Users can adequately self-select if the device is intended for them. | Results were positive, demonstrating correct device use, output interpretation, and understanding of when to seek medical care. Testing with 51 participants confirmed adequate user self-selection. | Special Control (4) under 21 CFR 870.2345 addressed. Supports OTC use. |
| Signal Acquisition Reliability | Reliable acquisition of ECG signals suitable for analysis and display. | Testing on commercial WHOOP system confirmed ability to reliably acquire ECG signals. | Supported by IEC 60601-2-47:2012 compliance. |
| Database Testing | Compliance with special controls under 21 CFR 870.2345(3) using adjudicated dataset. | Conducted as per ANSI/AAMI EC57:2012(R2020). (Specific performance metrics not detailed, but compliance stated). | |
| Software Verification | Compliance with FDA guidance for software functions. | Completed as recommended by "Guidance for Industry and FDA Staff Content of Premarket Submissions for Device Software Functions (issued June 14, 2023)." Includes cybersecurity, labeling, and management plan. | Device is a "basic level device" in terms of software. |
| Electromagnetic Compatibility (EMC) & Electrical Safety | Compliance with relevant standards. | Meets specifications based on IEC 62368-1: 2018, EN 301-489 series, FCC 47 CFR Part 15 Subpart B:2024. | Confirms electrical safety and absence of electromagnetic interference issues. |
Study Information
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Approximately 540 subjects.
- 255 enrolled in the AFib cohort.
- 285 enrolled in the normal sinus rhythm cohort.
- Data Provenance: The document does not explicitly state the country of origin. It describes the study as a "clinical trial," which typically implies prospective data collection. There is no mention of it being retrospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Number of Experts: One "cardiologist" was used for rhythm classification.
- Qualifications of Experts: The ground truth was established by "a cardiologist." Specific experience (e.g., 10 years of experience) is not detailed in the provided text.
4. Adjudication Method for the Test Set
- The document states that rhythm classification of a 12-lead ECG by "a cardiologist" was compared to the device's classification. This implies a single expert established the ground truth. There is no mention of a multi-reader adjudication method (e.g., 2+1 or 3+1).
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- No, a multi-reader multi-case (MRMC) comparative effectiveness study was not explicitly stated as being done within the context of human readers improving with AI vs. without AI assistance. The study described focuses on the device's standalone performance compared to a cardiologist's interpretation of a 12-lead ECG.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Yes, the primary clinical validation described was a standalone (algorithm only) performance assessment. The study "compared to the rhythm classification of a simultaneously collected ECG from the WHOOP feature" against the 12-lead ECG interpreted by a cardiologist. The reported sensitivity, specificity, and inconclusive rates are metrics of the algorithm's performance.
7. The Type of Ground Truth Used
- Expert Consensus (single expert): The primary ground truth for rhythm classification (AFib/Sinus Rhythm) was established by a "cardiologist" interpreting a 12-lead ECG. This is a form of expert interpretation as ground truth.
- Reference Device Comparison: For waveform morphology, a "12-lead reference system" and "12-lead reference ECG" were used for comparison, implying a gold standard for electrical activity measurement.
8. The Sample Size for the Training Set
- The document does not provide information regarding the sample size of the training set used for the WHOOP ECG Feature algorithm.
9. How the Ground Truth for the Training Set Was Established
- The document does not provide information on how the ground truth for the training set was established. It only mentions that the WHOOP ECG Feature integrates the FDA-cleared B-Secur HeartKey Software Library (K200884), which would have had its own training and validation data. The specific methods for establishing ground truth for the WHOOP ECG Feature's training data are not detailed.
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(164 days)
870.2340, Class II/ DPS | 21 CFR 870.2340, Class II/ DPS | 21 CFR 870.2340, Class II/ DPS | 21 CFR 870.2345
Masimo W1™ and the integrated Masimo W1 Module are intended to record, store and transfer single-channel electrocardiogram (ECG) rhythms. The Masimo W1 also displays ECG rhythms, and the Masimo W1 Module detects the presence of atrial fibrillation. The Masimo W1 and the integrated Masimo W1 Module are intended for use by healthcare professionals, patients with known or suspected heart conditions, and health-conscious individuals.
Masimo W1 Module ECG software is an over-the-counter (OTC) software that operates on the Masimo W1 Module that can be used with compatible watches (e.g., Masimo W1). The software is intended to create, record, store, transfer, and display a single channel electrocardiogram (ECG) for informational use only in adults 22 years and older. It supports the classification of either atrial fibrillation (AFib) or sinus rhythm with the intention of aiding heart rhythm identification; it is not intended to replace traditional methods of diagnosis or treatment. The software is not intended for users with other known arrhythmias and users should not interpret or take clinical action based on the device output without consultation of a qualified healthcare professional.
The Masimo W1™ and the integrated Masimo W1 Module are also intended for the spot-checking of functional oxygen saturation of arterial hemoglobin (SpO2) and pulse rate (PR). The Masimo W1 and the integrated Masimo W1 Module are indicated for adults in hospitals, clinics, long-term care facilities, and homes.
The Masimo W1 is a watch that incorporates the Masimo W1 Module, which is the device that is responsible for the physiological signal detection and algorithm used to support the different parameters. The Masimo W1 Module incorporates spot check ECG functionality and Masimo SET Pulse Oximetry technology so that it can provide both ECG and Masimo SET pulse oximetry parameters. As part of this submission, Masimo is requesting clearance for an automated atrial fibrillation "AFib" Classification Feature that is used to analyze the single channel ECG waveform.
The parameter outputs from the Masimo W1 Module are communicated and displayed on the watch screen so that the data can be viewed and recorded. Masimo W1 also supports wireless communication of monitored data to a compatible smart device application. The sharing of the parameter data to the applications allows the users to see and track their data using their smart phones. Smart phone applications can also help to share information to caregivers and healthcare professionals.
Here's a breakdown of the acceptance criteria and the study that proves the device meets them, based on the provided FDA 510(k) Clearance Letter for the Masimo W1 with the Atrial Fibrillation (AFib) Classification Feature:
1. Table of Acceptance Criteria and Reported Device Performance
For the Atrial Fibrillation Classification Feature:
Performance Metric | Acceptance Criteria (Not explicitly stated as "acceptance criteria" but implied by comparison to predicates and clinical study results) | Reported Device Performance (Masimo W1 with AFib Classification Feature) |
---|---|---|
Atrial Fibrillation (AFib) Classification | ||
Sensitivity | Comparable to or better than predicate devices (Withing Scan Monitor: 96.3%; Samsung ECG Monitor: 98.1%) | 99.3% [96.3%, 100%] |
Specificity (Sinus Rhythm) | Comparable to or better than predicate devices (Withing Scan Monitor: 100%; Samsung ECG Monitor: 100%) | 100% [97.8%, 100%] |
Positive Predictive Value (PPV) | (Not explicitly compared in table, but reported as a key performance metric) | 100% [97.5%, 100%] |
Unclassified Rate | (Not explicitly compared in table) | 5.0% |
Noise Rate | (Not explicitly compared in table) | 1.7% |
ECG Waveform Quality Analysis | ||
Qualitative Agreement (with 12-lead ECG Lead I) | High agreement by qualified clinicians | 98% [96% - 98%] |
Quantitative Similarity (Key ECG features like QRS amplitude, QRS width) | Similar to Lead I of a gold-standard 12-lead ECG reference | Similar to Lead I of a gold-standard 12-lead ECG reference |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: The document states "Prospective clinical testing was conducted to validate the AFib Classification Feature on adult subjects from 4 different sites." While a specific number of subjects is not provided, it indicates a multi-site study.
- Data Provenance: Prospective clinical testing. The country of origin is not explicitly stated in the provided text.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Number of Experts: Unspecified (referred to as "qualified clinicians" for the qualitative assessment of ECG waveforms).
- Qualifications of Experts: "Qualified clinicians" were used for the qualitative assessment of the ECG waveforms. Further specific qualifications (e.g., cardiologist, years of experience) are not detailed in the provided text.
4. Adjudication Method for the Test Set
The document does not explicitly state the adjudication method used for establishing the ground truth for the test set (e.g., 2+1, 3+1). It only mentions that "qualified clinicians" made an agreement assessment.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- Was it done? No, a multi-reader multi-case (MRMC) comparative effectiveness study comparing human readers with AI assistance versus without AI assistance was not described in the provided text. The study focused on the standalone performance of the AI AFib classification feature and the quality of its ECG waveform compared to a gold standard.
- Effect Size: Not applicable, as an MRMC study was not described.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- Was it done? Yes, a standalone performance study was clearly conducted for the AFib Classification Feature. The "Masimo W1 ECG AFib Classification feature Performance" section directly reports sensitivity, specificity, and PPV for the algorithm's output. The "Masimo W1 Module ECG software" is described as supporting the classification, indicating an algorithmic assessment.
7. Type of Ground Truth Used
- For AFib Classification: The gold standard for AFib classification is not explicitly stated, but clinical validation for ECG rhythm typically uses expert-adjudicated 12-lead ECG recordings. The document mentions "comparing similarity between Masimo W1 and gold-standard 12 lead ECG as reference" for waveform quality, which strongly implies 12-lead ECGs were used as a reference for rhythm classification as well.
- For ECG Waveform Quality: Gold-standard 12-lead ECG as reference.
8. Sample Size for the Training Set
The document does not specify the sample size for the training set. It only describes the test set used for clinical validation.
9. How the Ground Truth for the Training Set Was Established
The document does not specify how the ground truth for the training set was established. It focuses solely on the validation/test set.
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(122 days)
California 94043
Re: K240909
Trade/Device Name: Samsung ECG App v 1.3 (ECG) Regulation Number: 21 CFR 870.2345
|
| Classification: | QDA - Electrocardiograph software for over-the-counter use (21 CFR 870.2345
The Samsung ECG app with IHRN is an over-the-counter (OTC) software-only, mobile medical application operating on a compatible Samsung Galaxy Watch and Phone for informational use only in adults 22 years and older. The app analyzes pulse rate data to identify episodes of irregular heart rhythms suggestive of atrial fibrillation (AFib) and provides a notification suggesting the user record an ECG to analyze the heart rhythm. The Irregular Heart Rhythm Notification Feature is not intended to provide a notification on every episode of irregular rhythm suggestive of AFib and the absence of a notification is not intended to indicate no disease process is present; rather the feature is intended to opportunistically acquire pulse rate data when the user is still and analyze the data when determined sufficient toward surfacing a notification.
Following this prompt, or based on the user's own initiative, the app is intended to create, record, store, transfer, and display a single channel ECG, similar to a Lead I ECG. Classifiable traces are labeled by the app as sinus rhythm. AFib. high heart rate (non-AFib), or AFib with high heart rate with the intention of aiding heart rhythm identification.
The app is not intended for users with other known arrhythmias, and it is not intended to replace traditional methods of diagnosis or treatment. Users should not interpret or take clinical action based on the device output without consultation of a qualified healthcare professional.
The Samsung ECG App v1.3 is a software as a medical device (SaMD) that consists of a pair of mobile medical apps: one app on a compatible Samsung wearable and the other on a compatible Samsung phone, both general-purpose computing platforms.
When enabled, the wearable application of the SaMD uses a wearable photoplethysmography (PPG) sensor to background monitor cardiac signals from the user. The application examines beat-to-beat intervals and generates an irregular rhythm notification indicative of atrial fibrillation (AFib). Upon receiving an irregular rhythm notification or at their discretion, the user can record a single-lead ECG using the same wearable. The wearable application then calculates the average heart rate from the ECG recording and produces a rhythm classification. The wearable application also securely transmits the data to the ECG phone application on the paired phone. The phone application shows a time-stamped irregular rhythm notification history with heart rate information; ECG measurement history; and generates a PDF file of the ECG signal, which the user can share with their healthcare provider.
Acceptance Criteria and Device Performance for Samsung ECG App v1.3
1. Acceptance Criteria and Reported Device Performance
Parameter | Acceptance Criteria (Reference Device: Apple ECG 2.0 App K201525) | Reported Device Performance (Samsung ECG App v1.3) |
---|---|---|
Heart Rate 50-150 BPM | ||
AFib Sensitivity | 98.5% (95% CI 97.3%, 99.6%) | 96.0% (95% CI 94.0%, 97.8%) |
Sinus Rhythm Specificity | 99.3% (95% CI 98.4%, 100%) | 98.7% (95% CI 94.0%, 97.8%) |
Heart Rate 100-150 BPM | ||
AFib Sensitivity | 90.7% (95% CI 86.7%, 94.6%) | 93.6% (95% CI 88.5%, 97.5%) |
Sinus Rhythm Specificity | 83% (95% CI 77.8%, 88%) | 96.3% (95% CI 93.5%, 98.9%) |
Visually Interpretable Waveforms | Not explicitly stated for reference device, but implied by "sufficient" signal quality | 98.7% of cases |
Accuracy of Key Intervals (RR, PR, QRS) and R-wave amplitude | Not explicitly stated for reference device, but implied by "sufficient" signal quality | Accurately measured when compared against standard Lead I ECG |
Note: The reported performance for Samsung ECG App v1.3's "Sinus rhythm (HR 50-150 BPM)" and "AFib (HR 50-150 BPM)" is presented with the same 95% CI: (94.0%, 97.8%). This might be a transcription error in the document, as specificity and sensitivity for different conditions would typically have distinct confidence intervals. Assuming independent calculations, these values are presented as they appear in the source.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: 1,013 subjects. These subjects contributed to 453 AFib recordings (heart rate 50 to 150 BPM) and 691 Sinus rhythm recordings (heart rate 50 to 150 BPM) for the primary endpoint analysis.
- Data Provenance: The study was a multi-center study, implying data from multiple locations, likely within the US given the FDA submission context and the racial demographics provided (predominantly Caucasian). The study was likely prospective as it involved recruiting subjects and collecting data for validation.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
The document does not explicitly state the "number of experts" or their specific "qualifications" used to establish the ground truth for the test set. It mentions "Clinical Validation showing comparable clinical performance...compared to the reference device" and that the "ECG function accurately classified...compared against the standard Lead I ECG," implying that comparison was made to physician-adjudicated or expertly interpreted ECGs, but the details of the ground truth establishment are not provided.
4. Adjudication Method for the Test Set
The document does not explicitly state the adjudication method used for establishing the ground truth for the test set.
5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study
There is no mention of a Multi Reader Multi Case (MRMC) comparative effectiveness study being done, or any effect size of how much human readers improve with AI vs without AI assistance. The study focuses on the standalone performance of the device's ECG rhythm classification compared to a reference device.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
Yes, a standalone study was conducted. The "Clinical Validation" section details the performance of the "ECG rhythm classification of the Samsung ECG App v1.3" in terms of sensitivity and specificity against a clinical ground truth, without explicit human-in-the-loop interaction for the classification task itself. The device "accurately classified" recordings.
7. Type of Ground Truth Used
The ground truth used was clinical diagnosis based on "446 subjects diagnosed with AFib, 536 subjects without AFib, and 31 subjects diagnosed with another type of irregular rhythm." The performance was evaluated by comparing the device's classifications against "standard Lead I ECG" interpretation, implying expert consensus (from qualified healthcare professionals interpreting the standard ECGs) or clinical diagnosis as the ground truth.
8. Sample Size for the Training Set
The document does not specify the sample size for the training set. It focuses on the validation study.
9. How the Ground Truth for the Training Set Was Established
The document does not provide information on how the ground truth for the training set was established.
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(89 days)
|
| Classification: | • QDA - Electrocardiograph software for over-the-counter use (21 CFR 870.2345
The Samsung ECG Monitor Application with Irregular Heart Rhythm Notification is an over-the-counter (OTC) softwareonly, mobile medical application operating on a compatible Samsung Galaxy Watch and Phone for informational use only in adults 22 years and older. The app analyzes pulse rate data to identify episodes of irregular heart rhythms suggestive of atrial fibrillation (AFib) and provides a notification suggesting the user record an ECG to analyze the heart rhythm. The Irregular Heart Rhythm Notification Feature is not intended to provide a notification on every episode of irregular rhythm suggestive of AFib and the absence of a notification is not intended to indicate no disease process is present, rather the feature is intended to opportunistically acquire pulse rate data when the data when determined sufficient toward surfacing a notification.
Following this prompt, or based on the user's own initiative, the app is intended to create, record, store, transfer, and display a single-channel ECG. similar to a Lead I ECG. Classifiable traces are labeled by the app as either AFib or sinus rhythm with the intention of aiding heart rhythm identification.
The app is not intended for users with other known arrhythmias, and it is not intended to replace traditional methods of diagnosis or treatment. Users should not interpret or take clinical action based on the device of the of a qualified healthcare professional.
The Samsung ECG Monitor App with Irregular Heart Rhythm Notification (IHRN) Feature is a software as a medical device (SaMD) that consists of a pair of mobile medical apps: one app on a compatible Samsung wearable and the other on a compatible Samsung phone, both general-purpose computing platforms.
When enabled, the wearable application of the SaMD uses a wearable photoplethysmography (PPG) sensor to background monitor bio-photonic signals from the user. The application examines beat-to-beat intervals and generates an irregular rhythm notification indicative of atrial fibrillation (AFib). Upon receiving an irregular rhythm notification or at their discretion, the user can record a single-lead ECG using the same wearable. The wearable application then calculates the average heart rate from the ECG recording and produces a rhythm classification. The wearable application also securely transmits the data to the ECG phone application on the paired phone device. The phone application shows a time-stamped irregular rhythm notification history with heart rate information; ECG measurement history; and generates a PDF file of the ECG signal, which the user can share with their healthcare provider.
Here's a breakdown of the acceptance criteria and the study details for the Samsung ECG Monitor Application with Irregular Heart Rhythm Notification Feature, based on the provided text:
Acceptance Criteria and Device Performance
Acceptance Criteria (Targeted Performance) | Reported Device Performance (Samsung IHRN Feature) |
---|---|
Subject Level: | |
Sensitivity (for irregular rhythm notification) | 68.0% (C.I. 60.5 - 75.5) |
Specificity (for irregular rhythm notification) | 98.8% (C.I. 98.0 - 99.6) |
Tachogram Level: | |
Positive Predictive Value (PPV) | 95.7% (C.I. 94.7 - 96.7) |
ECG Function (inherited from K201168): | |
Atrial Fibrillation Sensitivity | 98.1% |
Sinus Rhythm Specificity | 100% |
The document states that Samsung's algorithm performance for the IHRN function is substantially equivalent to the predicate device (Apple IRN Feature DEN180042) at both subject and tachogram levels, indicating these reported values met the acceptance criteria. For the ECG function, the device inherited the performance from the previously cleared Samsung ECG Monitor App (K201168) and thus the reported values were assumed to meet their prior acceptance criteria.
Study Details
2. Sample size used for the test set and the data provenance:
-
IHRN Clinical Validation (PPG-based notification):
- Analyzable Dataset for primary and secondary endpoints: 810 subjects (from 888 enrolled).
- Tachogram-level assessment: 98 subjects with AFib episodes (over an hour) and 101 subjects with less than an hour of AFib or no AFib were randomly selected from the cardiologist-reviewed subjects. Up to 25 positive tachograms with reference ECG data were randomly selected from these subjects.
- Data Provenance: The document does not explicitly state the country of origin, but it is a clinical study. The phrasing "All recruited subjects were at risk for AFib and had experienced symptoms..." suggests prospective data collection.
-
ECG Function (on-demand):
- No new clinical, human factors, or ECG database tests were conducted as the function was unchanged from the K201168 clearance. Therefore, a new test set was not used for this specific clearance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- IHRN Clinical Validation:
- Subject-level ground truth: "clinician-adjudicated and cardiologist-reviewed patch ECG data." The exact number of clinicians/cardiologists for this overarching adjudication is not specified, but it implies multiple experts.
- Tachogram-level ground truth: "Two board-certified cardiologists reviewed each reference ECG for annotation with a third cardiologist serving as tie-breaker."
- Qualifications: "Board-certified cardiologists."
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Tachogram-level ground truth: 2+1 (Two board-certified cardiologists reviewed, with a third serving as a tie-breaker).
- Subject-level ground truth: Not explicitly stated as a specific numerical method (e.g., 2+1), but referred to as "clinician-adjudicated and cardiologist-reviewed," implying a consensus or expert-driven process.
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 involving human readers with and without AI assistance was mentioned or conducted. The study evaluated the device's performance (IHRN feature) against a clinical ground truth, not the improvement of human readers using the device.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Yes, the clinical validation study for the Irregular Heart Rhythm Notification (IHRN) feature primarily assesses the standalone performance of the PPG-based algorithm in identifying irregular rhythms and generating notifications. The "subject-level irregular rhythm notification accuracy" and "tachogram-level positive predictive value" are metrics of the algorithm's performance without direct human interpretation being part of the primary output.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- IHRN Clinical Validation: Expert consensus using reference ECG patch data reviewed and adjudicated by clinicians and board-certified cardiologists.
8. The sample size for the training set:
- The document does not specify the sample size for the training set. It focuses on the validation study.
9. How the ground truth for the training set was established:
- The document does not specify how the ground truth for the training set (if any) was established. It only details the ground truth establishment for the test/validation set.
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(205 days)
Street Olathe, Kansas 66062
Re: K221774
Trade/Device Name: Garmin ECG App Regulation Number: 21 CFR 870.2345
Classification Name | Electrocardiograph Software for Over-the-Counter Use |
| Regulation Number | 21 C.F.R. § 870.2345
|
| Regulation
Number | 21 C.F.R. § 870.2345
| 21 C.F.R. § 870.2345
device.
ECG Database Testing
In compliance with special controls established under 21 C.F.R. § 870.2345
The Garmin ECG app is a software-only, mobile medical application intended for use with compatible Garmin smartwatches to create, record, store, transfer, and display a single-channel electrocardiograph similar to a Lead I ECG. The ECG app determines the presence of atrial fibrillation (AFib) or sinus rhythm (SR) on a classifiable waveform. The ECG app is not recommended for users with other known arrhythmias.
The ECG app is intended for over-the-counter (OTC) use. The ECG data displayed by the ECG app is intended for informational use only. The user is not intended to interpret or take clinical action based on the device output without consultation of a qualified healthcare professional. The ECG waveform is meant to supplement rhythm classification for the purposes of discriminating AFib from normal SR, and it is not intended to replace traditional methods of diagnosis or treatment.
The ECG app is not intended for use by people under 22 years old.
The Garmin ECG App (ECG App) is a software-only, mobile medical application that has two components: (1) the Watch ECG App for compatible Garmin smartwatches ("Watch" or "Watches"), and (2) the Smartphone ECG App included within Garmin's consumer health and fitness application ecosystem, Garmin Connect allows users to store, manage, and share their respective health and fitness data.
The ECG App is intended to create, record, store, transfer, and display a single lead ECG signal similar to a Lead | ECG. The Watch ECG App acquires and analyzes the single lead ECG signal from electrodes built into each Watch and detects the presence of atrial fibrillation (AFib) or normal sinus rhythm (SR) in the adult wearer of the Watch ECG App then calculates the average heart rate and displays that value, along with the rhythm classification result, to the user on the Watch screen. The user may annotate the result by choosing from a provided list of symptoms.
Optionally, and only when directed by the user, the Watch ECG App can securely transmit the result to the Smartphone ECG App for the purposes of storing and viewing a history of ECG App results. The user may also export ECG App results as a PDF for easy sharing.
The Garmin ECG App is a software-only, mobile medical application intended for use with compatible Garmin smartwatches to detect the presence of atrial fibrillation (AFib) or sinus rhythm (SR) from a single-channel electrocardiograph (similar to Lead I ECG).
Here's a breakdown of the acceptance criteria and the study that proves the device meets them:
1. Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Garmin ECG App's clinical performance were based on its ability to accurately detect AFib and sinus rhythms. The reported device performance is presented in the table below:
Acceptance Criteria | Reported Device Performance |
---|---|
Atrial Fibrillation Sensitivity | 99.5% |
Sinus Rhythm Specificity | 100% |
AFib Detection (including inconclusive recordings) | 86.5% |
Sinus Rhythm Detection (including inconclusive recordings) | 91.1% |
2. Sample Size and Data Provenance
- Test Set Sample Size: Approximately 590 subjects.
- Data Provenance: The document does not explicitly state the country of origin or whether the study was retrospective or prospective. However, it describes a "clinical study," which typically implies a prospective design.
3. Number of Experts and Qualifications for Ground Truth
- Number of Experts: Not explicitly stated, but the ground truth for the test set was established by "board-certified cardiologists."
- Qualifications of Experts: Board-certified cardiologists.
4. Adjudication Method for the Test Set
The adjudication method is not explicitly detailed beyond stating that "12-Lead ECG rhythm classifications performed by board-certified cardiologists" were used as the comparison for the ECG app's classifications. It implies that these expert classifications served as the gold standard for comparison.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
There is no mention of a Multi-Reader Multi-Case (MRMC) comparative effectiveness study being conducted to assess how much human readers improve with AI vs. without AI assistance. The study focuses on the standalone performance of the Garmin ECG App compared to expert-classified 12-Lead ECGs.
6. Standalone Performance (Algorithm Only)
Yes, a standalone performance study (algorithm only without human-in-the-loop performance) was done. The reported sensitivities and specificities (99.5% AFib sensitivity, 100% SR specificity for classifiable waveforms, and 86.5% AFib detection, 91.1% SR detection overall) are for the device's algorithmic classification.
7. Type of Ground Truth Used
The ground truth used was expert consensus based on 12-Lead ECG rhythm classifications performed by board-certified cardiologists.
8. Sample Size for the Training Set
The document does not explicitly state the sample size used for the training set for the ECG app's algorithm. The provided information specifically refers to the clinical validation study (test set).
9. How Ground Truth for the Training Set Was Established
The document does not explicitly describe how the ground truth for the training set was established. It mentions that "Garmin conducted database testing using a previously adjudicated dataset as per ANSI/AAMI EC57:2012" under "Non-Clinical Testing." While this indicates the use of adjudicated data for some form of testing, it doesn't specify if this was the training dataset or how that adjudication was performed (e.g., expert review, specific criteria).
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(122 days)
Cupertino, California 94015
Re: K201525
Trade/Device Name: ECG 2.0 App Regulation Number: 21 CFR 870.2345 |
---|
Classification Name |
- ECG Database Testing per EC57 In compliance with special controls established under 21 CFR 870.2345
The ECG app is a software-only mobile medical application intended for use with the Apple Watch to create, record, store, transfer, and display a single channel electrocardiogram (ECG) similar to a Lead I ECG. The ECG app determines the presence of atrial fibrillation (AFib), sinus rhythm, and high heart rate (no detected AF with heart rate 100-150 bpm) on a classifiable waveform. The ECG app is not recommended for users with other known arrhythmias.
The ECG app is intended for over-the-counter (OTC) use. The ECG data displayed by the ECG app is intended for informational use only. The user is not intended to interpret or take clinical action based on the device output without consultation of a qualified healthcare professional. The ECG waveform is meant to supplement rhythm classification for the purposes of discriminating AFib from sinus rhythm and is not intended to replace traditional methods of diagnosis or treatment.
The ECG app is not intended for use by people under 22 years old.
The ECG 2.0 app comprises a pair of mobile medical apps - one on Apple Watch and the other on the iPhone.
The ECG Watch app analyzes data collected by the integrated electrical sensors on a compatible Apple Watch to generate an ECG waveform similar to a Lead I. calculate average heart rate, and provide a rhythm classification to the user for a given 30 second session. When a user opens the ECG Watch app while wearing the Watch on one wrist, and places the finger of the opposite hand on the digital crown, they are completing the circuit across the heart which begins a recording session.
Once the recording session is complete, the ECG Watch app performs signal processing, feature extraction and rhythm classification to generate a session result.
The resulting classification and average heart rate for the session, along with educational information, will be displayed to the user within the ECG Watch app.
The ECG iPhone app contains the on-boarding and educational materials that a user must review prior to taking an ECG reading. The ECG iPhone app is included in the Health App, which allows users to store, manage, and share health and fitness data, and comes pre-installed on every iPhone. The ECG 2.0 app expands the classifiable heart range, introduces new classification results, and introduces minor, non-userfacing algorithm updates. These changes will be reflected in both the Apple Watch app, and also on the corresponding iPhone app within the Health App.
Here's a summary of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of acceptance criteria and the reported device performance
Acceptance Criteria | Device Performance (ECG 2.0 App) |
---|---|
AFib Classification Sensitivity (HR 50-150 bpm) | 98.5% |
Sinus Rhythm Classification Specificity (HR 50-150 bpm) | 99.3% |
PQRST Waveform Visual Acceptability | 100% pass rating |
R-wave Amplitude Assessment | 97.2% total pass rating |
2. Sample size used for the test set and the data provenance
- Sample size: Approximately 546 subjects.
- 305 subjects were in the Atrial Fibrillation cohort.
- 241 subjects were in the normal sinus rhythm cohort.
- Data provenance: Prospective, multi-center clinical trial. The country of origin is not explicitly stated, but it is a "multi-center" trial, implying diverse participant recruitment.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of experts: Not explicitly stated, but the ground truth was established by "a cardiologist." This implies at least one, likely a panel or multiple, to ensure robustness, though the exact number isn't quantified.
- Qualifications of experts: "Cardiologist." Years of experience are not specified.
4. Adjudication method for the test set
- The text states: "Rhythm classification of a 12-lead ECG by a cardiologist was compared to the rhythm classification of a simultaneously collected ECG from the ECG 2.0 app." This indicates that the cardiologist's interpretation of a 12-lead ECG served as the ground truth. It does not explicitly describe an adjudication method like 2+1 or 3+1 if multiple cardiologists were involved. It implies a single definitive classification by the cardiologist.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, and the effect size of how much human readers improve with AI vs without AI assistance
- No, a multi-reader multi-case (MRMC) comparative effectiveness study comparing human readers with AI assistance versus without AI assistance was not conducted or reported in the provided text. The study focused on the standalone performance of the ECG 2.0 app against a cardiologist's interpretation.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Yes, a standalone performance study was done. The reported performance metrics (sensitivity, specificity, waveform acceptability) reflect the algorithm's direct classification capabilities compared to the ground truth established by a cardiologist. The device is intended for over-the-counter use, and its performance in classifying AFib and sinus rhythm was assessed directly.
7. The type of ground truth used
- The ground truth used was expert consensus / diagnosis from a cardiologist's interpretation of a 12-lead ECG.
8. The sample size for the training set
- The document does not explicitly state the sample size for the training set. It only mentions the test set (clinical trial of 546 subjects).
9. How the ground truth for the training set was established
- The document does not explicitly describe how the ground truth for the training set was established. It primarily focuses on the validation study. However, given that it states "Apple conducted database testing using a previously adjudicated dataset" for "ECG Database Testing per EC57," it is highly probable that the training data's ground truth was also established by expert cardiologists adjudicating ECGs in a similar manner to the test set, but this is not explicitly detailed for the training set.
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(156 days)
Francisco, California 94105
Re: K200948
Trade/Device Name: Fitbit ECG App Regulation Number: 21 CFR 870.2345
Rhythm Assessment, ECG |
| Regulation Number: | 21 CFR§870.2345
|
| FDA Product
Code and
Regulatory
Classification | QDA
21 CFR 870.2345
| QDA
21 CFR 870.2345
The Fitbit ECG App is a software-only mobile medical application intended for use with Fitbit wrist wearable devices to create, record, store, transfer, and display a single channel electrocardiogram (ECG) qualitatively similar to a Lead I ECG. The Fitbit ECG App determines the presence of atrial fibrillation (AFib) or sinus rhythm on a classifiable waveform. The AFib detection feature is not recommended for users with other known arrhythmias.
The Fitbit ECG App is intended for over-the-counter (OTC) use. The ECG data displayed by the Fitbit ECG App is intended for informational use only. The user is not interpret or take clinical action based on the device output without consultation of a qualified healthcare professional. The ECG waveform is meant to supplement rhythm classification for the purposes of discriminating AFib from normal sinus rhythm and not intended to replace traditional methods of diagnosis or treatment. The Fitbit ECG App is not intended for use by people under 22 years old.
The Fitbit ECG App is a software-only medical device used to create, record, display, store and analyze a single channel ECG. The Fitbit ECG App consists of a Device application ("Device app") on a consumer Fitbit wrist-worn product and a mobile application tile ("mobile app") on Fitbit's consumer mobile application. The Device app uses data from electrical sensors on a consumer Fitbit wrist-worn product to create and record an ECG. The algorithm on the Device app analyzes a 30 second recording of the ECG and provides results to the user. Users are able to view their past results as well as a pdf report of the waveform similar to a Lead I ECG on the mobile app.
Below is the information regarding the Fitbit ECG App's acceptance criteria and the study that proves it, based on the provided document:
1. Table of acceptance criteria and the reported device performance
Category | Acceptance Criteria | Reported Device Performance |
---|---|---|
AFib Detection (Sensitivity) | Not explicitly stated in the provided text as a numerical criterion, but implicitly expected to be high for AFib detection. The predicate device's performance often forms the basis for substantial equivalence. | 98.7% for AFib detection |
AFib Detection (Specificity) | Not explicitly stated in the provided text as a numerical criterion, but implicitly expected to be high for ruling out AFib. The predicate device's performance often forms the basis for substantial equivalence. | 100% for AFib detection |
ECG Waveform Morphological Equivalence to Lead I | ECG waveform "qualitatively similar to a Lead I ECG" and expected to meet specific morphological equivalence criteria. | 95.0% of AF and SR tracings deemed morphologically equivalent to Lead I of a 12-Lead ECG waveform. |
2. Sample size used for the test set and the data provenance
- Sample Size: 475 subjects.
- Data Provenance: Subjects were recruited across 9 US sites. This indicates prospective data collection from the United States.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of Experts: For subjects with a known history of AFib, a "single qualified physician" performed the screening and assigned them to the AFib cohort. The document doesn't specify how many experts reviewed the 12-lead ECGs for the ground truth of AFib or Sinus Rhythm (NSR) for all 475 subjects, beyond the single physician for the AFib cohort screening. For the overall study, it implies a 12-lead ECG was the reference, which would typically be interpreted by qualified cardiologists or electrophysiologists.
- Qualifications of Experts: For AFib screening, the expert was referred to as a "single qualified physician." Specific qualifications like "radiologist with 10 years of experience" are not provided.
4. Adjudication method for the test set
The document does not explicitly state an adjudication method (e.g., 2+1, 3+1). It mentions that subjects with a known history of AFib were screened by a "single qualified physician." For the simultaneous 12-lead ECG, it implies a clinical standard interpretation which often involves adjudicated reads, but this is not detailed in the provided text.
5. If a Multi-Reader, Multi-Case (MRMC) comparative effectiveness study was done
No, a Multi-Reader, Multi-Case (MRMC) comparative effectiveness study comparing human readers with and without AI assistance was not reported in this document. The study focuses on evaluating the standalone performance of the Fitbit ECG App against a clinical standard (12-lead ECG).
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, a standalone performance study was done. The document states: "The Fitbit ECG App software algorithm was able to detect AF with the sensitivity and specificity of 98.7% and 100%, respectively." This indicates a direct evaluation of the algorithm's performance.
7. The type of ground truth used
The ground truth was established using a simultaneous 30-second 12-lead ECG. This is a clinical gold standard for rhythm analysis.
8. The sample size for the training set
The document does not provide the sample size for the training set. It only details the clinical testing conducted for validation/evaluation of the device.
9. How the ground truth for the training set was established
The document does not provide information on how the ground truth for the training set was established, as it focuses on the validation study.
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(95 days)
California 94043
Re: K201168
Trade/Device Name: Samsung ECG Monitor Application Regulation Number: 21 CFR 870.2345
|
| Classification: | QDA - Electrocardiograph software for over-the-counter use (21 CFR 870.2345
The Samsung ECG Monitor Application is an over-the-counter (OTC) software-only, mobile medical application operating on a compatible Samsung Galaxy Watch and Phone. The app is intended to create, record, store, transfer, and display a single channel electrocardiogram (ECG), similar to a Lead I ECG, for informational use only in adults 22 years and older. Classifiable traces are labeled by the app as either atrial fibrillation (AFib) or sinus rhythm with the intention of aiding heart rhythm identification; it is not intended to replace traditional methods of diagnosis or treatment. The app is not intended for users with other known arrhythmias and users should not interpret or take clinical action based on the device output without consultation of a qualified healthcare professional.
The Samsung ECG Monitor Application consists of a pair of mobile medical apps: one on a compatible Samsung wearable and the other on a compatible Samsung phone. The compatible Samsung wearable application captures bioelectrical signals from the user and generates single lead ECG signals, calculates average heart rate and classifies the rhythm. The wearable application securely transmits the obtained data to the phone application on the paired phone device. The phone application shows the ECG measurement history and generates the PDF file for the received ECG signals which can be shared by the user.
The Samsung ECG Monitor Application was proven to be non-inferior to the predicate (Apple ECG App, DEN180044) in terms of rhythm classification accuracy and ECG signal quality sufficiency.
Here's the breakdown of the acceptance criteria and study details:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria Category | Acceptance Criteria (Non-inferiority Margin) | Reported Device Performance (Samsung ECG Monitor App) | Reference (Predicate Device) |
---|---|---|---|
AFib Sensitivity | Within pre-determined non-inferiority margin compared to predicate | 98.1% (95% CI: 96.3%, 99.9%) | 99.6% (95% CI: 98.7%, 100%) |
Sinus Rhythm Specificity | Within pre-determined non-inferiority margin compared to predicate | 100% (95% CI: 100%) | 99.6% (95% CI: 98.8%, 100%) |
Inconclusive Rate (AFib or SR truth) | Within pre-determined non-inferiority margin compared to predicate | 2.9% (95% CI: 1.1%, 4.7%) | 2.2% (95% CI: 0.7%, 3.7%) |
Cardiologist Interpretability of ECG Recordings | Within pre-determined non-inferiority margin compared to predicate | 98.5% (95% CI: 97.4%, 99.5%) | 99.4% (95% CI: 98.8%, 100%) |
Concordance between App Strip and 12-lead ECG | Within pre-determined non-inferiority margin compared to predicate | 99.4% (95% CI: 98.7%, 100%) | 99.8% (95% CI: 99.4%, 100%) |
Fiducial Point Annotation (Key ECG Features) | All key ECG features (QRS amplitude, RR interval, QRS duration, PR interval) within non-inferiority margin with statistical significance compared to 12-lead ECG. | Met non-inferiority margin with statistical significance. | N/A (compared to 12-lead reference) |
2. Sample size used for the test set and the data provenance
- Sample Size: 544 subjects.
- 268 AFib patients
- 261 Sinus Rhythm (SR) patients
- 15 with other arrhythmias
- Data Provenance: The document does not explicitly state the country of origin. However, the manufacturer is Samsung Electronics Co., Ltd in Korea. The study structure implies prospectively collected data for this clinical validation.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of Experts: Unspecified number of cardiologists and three blinded, independent ECG technicians.
- Qualifications of Experts:
- Cardiologists: Used for comparing the ECG App algorithm detection of AFib and SR to 12-lead ECG reference strips, and for interpreting the ECG Monitor App strips. No specific experience level provided.
- ECG Technicians: Three blinded, independent ECG technicians were used for fiducial point annotation. No specific experience level provided.
4. Adjudication method for the test set
- For rhythm classification, the ground truth was established by cardiologists' read of 12-lead ECG reference strips. This implies a consensus or authoritative read by these experts.
- For signal quality interpretability and concordance, cardiologists' interpretation served as the reference.
- For fiducial point annotation, three blinded, independent ECG technicians marked the points, implying their individual annotations were compared against the reference or potentially against each other for a form of consensus, though this is not explicitly detailed.
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
The document describes a clinical study where the algorithm's performance (Samsung ECG Monitor App) was compared to a reference standard (cardiologist-read 12-lead ECG), and also against a predicate device (Apple ECG App). It does not describe an MRMC comparative effectiveness study evaluating how human readers improve with AI vs without AI assistance. The focus was on the algorithm's standalone performance compared to expert ground truth and its non-inferiority to an existing cleared device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, a standalone study was done. The clinical study directly evaluated the Samsung ECG Monitor App algorithm's performance in detecting AFib and Sinus Rhythm against a cardiologist-read 12-lead ECG reference strip. The reported sensitivity, specificity, and inconclusive rates are for the algorithm's performance alone.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The primary ground truth used was expert consensus / expert interpretation from:
- Cardiologists (for rhythm classification based on 12-lead ECG reference strips and for interpretability and concordance studies).
- Blinded, independent ECG technicians (for fiducial point annotation).
8. The sample size for the training set
The document does not specify the sample size for the training set. It only details the clinical validation study (test set).
9. How the ground truth for the training set was established
The document does not provide information on how the ground truth for the training set was established, as it focuses solely on the clinical validation (test set) and device performance evaluation.
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(241 days)
KardiaMobile System has undergone evaluation in accordance to the Special Controls associated with 21CFR§ 870.2345
The KardiaMobile System is intended to record, store and transfer single-channel electrocardiogram (ECG) rhythms. The KardiaMobile System also displays ECG rhythms and output of ECG analysis from AliveCor's KardiaAl platform including detecting the presence of normal sinus rhythm, atrial fibrillation, bradycardia, and others. The KardiaMobile System is intended for use by healthcare professionals, patients with known or suspected heart conditions and health conscious individuals. The device has not been tested and is not intended for pediatric use.
The KardiaMobile System is a trans-telephonic (transmission by telephone) ECG (electrocardiogram) event recorder that records, stores and transfers single-channel electrocardiogram rhythms. The device utilizes the computing power of Apple iOS- and Google Android-based smartphones to obtain and analyze single-channel ECG. These smartphones are termed Mobile Computing Platforms (MCPs). The device consists of the hardware (that has the electrodes), and the Kardia phone app (installed on an MCP). The same software is implemented in the iOS and Android MCP. In either configuration, the same hardware is used to sense the ECG. The KardiaMobile Hardware transmits the ECG signal from the electrode to the Kardia phone app on the MCP to be analyzed and presented to the user. All ECGs are synced with the user's account.
The provided text describes the acceptance criteria and the study conducted for the KardiaMobile System, primarily focusing on proving that the device meets special controls for Electrocardiograph Software for Over-the-Counter Use, especially after the removal of a "clinician overread" function.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not provide a direct table of numerical "acceptance criteria" (e.g., minimum sensitivity/specificity percentages) and corresponding "reported device performance" values for the AI algorithm suite (KardiaAI SaMD). Instead, it states that the performance characteristics (sensitivity and specificity) were "tested to meet the system requirements" against ANSI/AAMI EC57:2012 databases and AliveCor's proprietary databases.
However, the "Special Control" table implicitly functions as acceptance criteria for different aspects of the device's performance and the "Summary of Conformance" column indicates the reported performance/compliance.
Acceptance Criteria (Implicit from Special Controls) and Reported Device Performance (Summary of Conformance):
Acceptance Criteria (Special Control) | Reported Device Performance (Summary of Conformance) |
---|---|
1. Clinical performance testing under anticipated conditions of use must demonstrate: | |
(a) The ability to obtain an ECG of sufficient quality for display and analysis; and | The KardiaMobile device has demonstrated its ability to obtain ECGs of sufficient quality for display and analysis through both bench and clinical performance testing. (Long history of real-world use and real-world use data supports that representative users can record ECG of equivalent quality to 12-lead ECG). |
(b) The performance characteristics of the detection algorithm as reported by sensitivity and either specificity or positive predictive value. | The KardiaMobile System leverages the KardiaAI SaMD (K181823) for ECG analysis. KardiaAI algorithm suite ECG detection algorithm outputs of Atrial Fibrillation, Normal, Bradycardia, Tachycardia, and Noise as well as the heart rate calculations were tested to meet the system requirements for sensitivity and specificity. Testing was conducted to ANSI/AAMI EC57:2012 databases and AliveCor's proprietary databases. |
2. Software verification, validation, and hazard analysis must be performed. Documentation must include a characterization of the technical specifications of the software, including the detection algorithm and its inputs and outputs. | Software documentation for the KardiaMobile software was prepared and provided in accordance with FDA's Guidance titled, Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 11, 2015). (Further specifically stated that software V&V was done per FDA's "General Principles of Software Validation," Jan 11, 2002.) |
3. Non-clinical performance testing must validate detection algorithm performance using a previously adjudicated data set. | KardiaAI algorithm suite ECG detection algorithm outputs of Atrial Fibrillation, Normal, Bradycardia, Tachycardia, and Noise as well as the heart rate calculations were tested to meet the system requirements for sensitivity and specificity. Testing was conducted to ANSI/AAMI EC57:2012 databases and AliveCor's proprietary databases. These validation datasets are representative of the patient population of the proposed device. |
4. Human factors and usability testing must demonstrate the following: | |
(a) The user can correctly use the device based solely on reading the device labeling; and | |
(b) The user can correctly interpret the device output and understand when to seek medical care. | Human factors evaluation was performed in accordance with recommendations in IEC62366-1:2015 and FDA's Guidance Document; Applying Human Factors and Usability Engineering to Medical Devices. |
The study found that the user can correctly use the device solely based on on-screen guidance and the users understand the device output. The study also found that users understand when to seek care regardless of the output of the device. (Specifically tested addressing the removal of "unlock overread" function). | |
Labeling must include specific information (hardware/OS requirements, performance limitations, clinical performance summary, device measures/outputs, guidance on interpretation). | Provided within applicable sections of the KardiaMobile Instructions for Use and User Manual documents and within on-screen instructions to the user within the software. |
2. Sample Sizes Used for the Test Set and Data Provenance
- Sample Size for Algorithmic Performance (KardiaAI SaMD): The document states that the KardiaAI SaMD (K181823), leveraged by the KardiaMobile System for ECG analysis, was validated using "ANSI/AAMI EC57:2012 databases and AliveCor's proprietary databases." It also notes that these "validation datasets are representative of the patient population of the proposed device."
- Specific sample sizes are NOT provided for these databases.
- Data Provenance: Not explicitly stated regarding country of origin. The use of "ANSI/AAMI EC57:2012 databases" suggests a standardized, likely diverse, source, while "AliveCor's proprietary databases" could be from various global or specific regions. The document does not specify if the data was retrospective or prospective for the algorithmic validation, but typically such databases are compiled retrospectively.
- Sample Size for Human Factors and Usability Testing: Not explicitly stated, but it refers to "representative users."
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- For Algorithmic Performance (KardiaAI SaMD): The document states that the detection algorithm performance was validated using a "previously adjudicated data set" (Special Control 3) and mentions that for the primary predicate, the "overread unlock" mechanism involved review by a "board-certified cardiologist." However, it does not explicitly state the number or specific qualifications (e.g., years of experience) of experts used to establish the ground truth for the test sets used for the KardiaAI algorithm validation. Adjudicated data implies expert review, but details are absent.
4. Adjudication Method for the Test Set
- For Algorithmic Performance (KardiaAI SaMD): The document mentions "previously adjudicated data set." No specific adjudication method (e.g., 2+1, 3+1) is detailed.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No MRMC comparative effectiveness study, comparing human readers with AI vs. without AI assistance, is mentioned. The focus of the changes and testing described is on the device's standalone performance and human factors/usability for over-the-counter use after removing the "overread" requirement.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Yes. The document explicitly states: "The KardiaMobile System leverages the KardiaAI SaMD (K181823) for ECG analysis. KardiaAI algorithm suite ECG detection algorithm outputs of Atrial Fibrillation, Normal, Bradycardia, Tachycardia, and Noise as well as the heart rate calculations were tested to meet the system requirements for sensitivity and specificity." This indicates that the core AI algorithm's performance was evaluated independently (without human-in-the-loop for its direct analytical output).
7. The Type of Ground Truth Used
- For Algorithmic Performance (KardiaAI SaMD): "Previously adjudicated data set." This typically implies expert consensus (e.g., cardiologists reviewing ECGs). It does not mention pathology or outcomes data as the ground truth directly for the AI algorithm's performance.
8. The Sample Size for the Training Set
- Not specified. The document focuses on the validation/test sets (ANSI/AAMI EC57:2012 and AliveCor's proprietary databases) for the KardiaAI algorithm. Information regarding the training set's size is not provided.
9. How the Ground Truth for the Training Set Was Established
- Not specified. As the training set size itself is not mentioned, neither is the method for establishing its ground truth.
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