Search Results
Found 66 results
510(k) Data Aggregation
(192 days)
Hampshire 03079
Re: K250689
Trade/Device Name: CloudTMS Edge
Regulation Number: 21 CFR 882.5805
stimulation system |
| Classification Name | Transcranial Magnetic Stimulator |
| Regulation Number | 882.5805
The CloudTMS Edge system is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medications in the current episode.
The CloudTMS Edge is a repetitive transcranial magnetic stimulation (rTMS) system. This computerized medical device produces non-invasive, repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex for the treatment of Major Depressive Disorder.
It can be used in patient care institutions, diagnostics centers, neurosurgical hospitals.
The CloudTMS Edge principle of operation is based on the discharge of high voltage capacitor (1.8 kV) through stimulation coil; the pulsed magnetic field generated by the discharge current (up to 10 kA) penetrates through neuromuscular tissues nearby to induce electrical currents in cortical neurons.
Area of the brain to be stimulated for MDD treatment is Left Dorsolateral Prefrontal Cortex.
N/A
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(127 days)
Israel
Re: K251449
Trade/Device Name: BrainsWay Deep TMS System
Regulation Number: 21 CFR 882.5805
Name:** Transcranial Magnetic Stimulation System
Classification Name: CFR Classification section 882.5805
The BrainsWay Deep TMS™ System is indicated for the treatment of depressive episodes and for decreasing anxiety symptoms for those who may exhibit comorbid anxiety symptoms in adult patients suffering from Major Depressive Disorder (MDD) and who failed to achieve satisfactory improvement from previous antidepressant medication treatment in the current episode.
The BrainsWay Deep TMS™ System enables direct non-invasive activation of deep brain structures. Transcranial magnetic stimulation (TMS) is a non-invasive technique used to apply brief magnetic pulses to the brain. The pulses are administered by passing high currents through an electromagnetic coil placed adjacent to a patient's scalp. The pulses induce an electric field in the underlying brain tissue. When the induced field is above a certain threshold and is directed in an appropriate orientation relative to the brain's neuronal pathways, localized axonal depolarizations are produced, thus activating neurons in the targeted brain structure.
The BrainsWay Deep TMS™ System is composed of the following main components:
- Cart
a) TMS Neurostimulator
b) Cooling System
c) Positioning Device - Helmet
a) Aiming Apparatus (i.e., ruler/grid)
b) Electromagnetic Coil (H Coil)
c) Cap
The BrainsWay Deep TMS™ System is identical to the previously cleared BrainsWay Deep TMS™ Systems.
The purpose of this 510(k) submission is to enable modifications to the device software and expansion of the treatment stimulation protocols, to include the accelerated iTBS stimulation protocol.
N/A
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(279 days)
Re: K243700
Trade/Device Name: Apollo TMS Therapy System
Regulation Number: 21 CFR 882.5805
rTMS) System
Classification Name: Repetitive Transcranial Magnetic Stimulation Device
21 CFR 882.5805
patients age 15-21 | Adult patients |
| Product Code | OBP | OBP | OBP |
| Classification | 21 CFR 882.5805
| 21 CFR 882.5805 | 21 CFR 882.5805 |
Standard Treatment Stimulation Parameters
| Area of brain
The Apollo TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode and as an adjunct for the treatment of MDD in adolescent patients (age 15-21).
The Apollo TMS Therapy System is an electromagnetic device that non-invasively delivers a rapidly pulsed magnetic field to the cerebral cortex in order to activate neurons within a limited volume without inducing a seizure. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation (TMS). The Apollo TMS Therapy System is comprised of the following principal components: User Interface, Main Unit (with or without housing), Stimulation Coil, Coil Positioning System. The operator controls the Apollo TMS Therapy System via the user interface (application software "Stimware"). "Stimware" is a treatment and data management software that administrates treatment protocols and the patient´s individual stimulation dose determined by the patient´s individual motor threshold. Stimulation is applied via the stimulation coil. For the treatment of major depressive disorder, the stimulation coil is positioned to the left dorsolateral prefrontal cortex (DLPFC) by means of the coil positioning system.
N/A
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(276 days)
Re: K243539
Trade/Device Name: Apollo TMS Therapy System
Regulation Number: 21 CFR 882.5805
Usual Name:** Repetitive Transcranial Magnetic Stimulation (rTMS) System
Classification: 21 CFR 882.5805
medication in the current episode. |
| Product code | OBP, QCI | OBP, QCI | OBP |
| Classification | 21 CFR 882.5805
| 21 CFR 882.5805 | 21 CFR 882.5805 |
Page 10
510(k) Summary Apollo TMS Therapy System
The Apollo TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
The Apollo TMS Therapy System is an electromagnetic device that non-invasively delivers a rapidly pulsed magnetic field to the cerebral cortex in order to activate neurons within a limited volume without inducing a seizure. This method of cortical stimulation by application of brief magnetic pulses to the head is known as Transcranial Magnetic Stimulation (TMS).
The Apollo TMS Therapy System is comprised of the following principal components:
- User Interface
- Main Unit (with or without housing)
- Stimulation Coil
- Coil Positioning System
The operator controls the Apollo TMS Therapy System via the user interface (application software "Stimware"). "Stimware" is a treatment and data management software that administrates treatment protocols and the patient´s individual stimulation dose determined by the patient´s individual motor threshold. Stimulation is applied via the stimulation coil. For the treatment of major depressive disorder, the stimulation coil is positioned to the left dorsolateral prefrontal cortex (DLPFC) by means of the coil positioning system. The observed and documented increase in cortical excitability after high frequency rTMS has been shown to persist beyond the duration of the train of stimulation. For treatment of OCD, the stimulation coil is positioned to the dorsomedial prefrontal cortex (DMPFC).
The provided FDA 510(k) clearance letter and summary for the Apollo TMS Therapy System (K243539) indicate that the device is substantially equivalent to predicate devices. This clearance is based on non-clinical performance data and a comparison to existing cleared devices rather than a de novo clinical comparative effectiveness study.
Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for this 510(k) submission are primarily based on demonstrating substantial equivalence to existing legally marketed predicate devices, particularly for the extended indication of Obsessive-Compulsive Disorder (OCD) treatment. The criteria are therefore focused on matching or being demonstrably similar to the predicate device's performance, especially for the OCD treatment parameters, and adhering to recognized safety and performance standards.
| Acceptance Criteria (Inferred from 510(k) Summary) | Reported Device Performance (Apollo TMS Therapy System K243539) |
|---|---|
| Intended Use Equivalence: Identical intended use as predicate devices. | The Apollo TMS Therapy System is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode, as well as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD). This matches the intended use of the primary predicate device (HORIZON® 3.0 TMS Therapy System K222171) for OCD, and the secondary predicate (Apollo TMS Therapy System K232639) for MDD. |
| OCD Treatment Stimulation Parameters Equivalence: Identical brain area, intensity (100% leg MT), frequency (20 Hz), pulse train duration (2 sec), inter-train interval (20 sec), trains per session (50), max no. of pulses (2000), and treatment schedule (5 daily sessions for 5 weeks, 4 daily sessions for 1 week) as the primary predicate device. | Area of brain to be stimulated: DMPFC (Identical to predicate) Stimulation intensity: 100 % of leg MT (Identical to predicate) Stimulation frequency: 20 Hz (Identical to predicate) Pulse train duration: 2 sec (Identical to predicate) Inter-train interval: 20 sec (Identical to predicate) Trains per session: 50 (Identical to predicate) Max no. of pulses: 2000 (Identical to predicate) Treatment schedule: 5 daily sessions for 5 weeks, 4 daily sessions for 1 week (Identical to predicate) |
| Consistent Intensity of Individual Stimuli during OCD Protocol: The intensity of each stimulus during the OCD protocol is equal and kept constant throughout the delivery of the full treatment. | Successfully demonstrated for the subject device. |
| Safety Temperature Limits Adherence: Remaining within recognized safety temperature limits at maximum output. | Remaining within recognized safety temperature limits. (Identical to predicates) |
| Electrical Safety: Conformance to IEC 60601-1. | Conforms to IEC 60601-1. |
| Electromagnetic Compatibility (EMC): Conformance to IEC 60601-1-2. | Conforms to IEC 60601-1-2. |
| Usability: Conformance to IEC 60601-1-6. | Conforms to IEC 60601-1-6. |
| Software Life Cycle Processes: Conformance to IEC 62304 and FDA guidance for software. | Software verification and validation testing conducted and documented in accordance with IEC 62304 and internal quality procedures. Software documentation considered "basic documentation" (supported by Special Controls Guidance "rTMS Class II"). |
| Risk Management: Application of ISO 14971 and IEC 62304 throughout the product development lifecycle with no new hazards/harms compared to predicates. | Risk assessment applied. Results indicate no new hazards, harms, or safety risks introduced when compared to the predicate devices. |
| Output Stimulation Parameters: Adequately similar output stimulation parameters (amplitude, pulse width, frequency, pulse train duration, ITI range, max # of pulses per session) to enable substantial equivalence determination. | Detailed comparison provided in the summary. While pulse width differs, the output stimulation is considered "adequately similar" to the primary predicate for OCD treatment. Other parameters within acceptable ranges or directly comparable. |
| Stimulation Coil Parameters: Similar coil configuration (figure-of-eight), output waveform (biphasic), E-Field at 1.0 SMT (130 V/m). | All identical to predicates. |
| Coil Positioning System: Comparable in function and method to predicate devices. | Integrated into Head-and-Neck-Support System (HANS), Landmark-Aided Coil Placement, TMS Cap for standardized 10-20-EEG Positioning with Coil Positioning Arm. Considered comparable or improved over predicate. |
2. Sample size used for the test set and the data provenance
The submission does not detail a specific "test set" sample size with patient data for efficacy, as it claims substantial equivalence primarily through non-clinical performance testing and direct comparison of specifications and treatment parameters to already cleared devices.
The "study" relies on:
- Non-clinical performance testing: This would involve engineering and laboratory testing for electrical safety, EMC, usability, temperature, and stimulation intensity, rather than a sample size of patients.
- Leveraged data from prior clearances (K180313 and K232639): This indicates that data from previously cleared versions of the Apollo TMS Therapy System was used as a basis.
- Primary predicate device (HORIZON® 3.0 TMS Therapy System K222171): The effectiveness of the OCD treatment protocol is derived from the established effectiveness of this predicate device, which was itself cleared based on its own clinical or non-clinical data.
Data Provenance: Not specified in terms of country of origin or retrospective/prospective for patient data, as direct clinical effectiveness data for the subject device was not required for this 510(k) clearance due to the substantial equivalence claim. The non-clinical testing would have been conducted by the manufacturer (MAG & More GmbH, Germany).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable as the submission does not describe a clinical study where experts established ground truth for a test set of patient data. The clearance is based on comparison to a predicate device and non-clinical engineering tests.
4. Adjudication method for the test set
This information is not applicable as there was no clinical test set requiring expert adjudication.
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
This information is not applicable. The Apollo TMS Therapy System is a therapeutic device that directly applies magnetic stimulation, not an imaging analysis or diagnostic AI device that involves "human readers" or AI assistance in interpretation. No MRMC study was conducted or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This information is not applicable in the context of an "algorithm only" performance study. The Apollo TMS Therapy System is a hardware device with controlling software. Its performance is always "standalone" in the sense that the device itself (hardware+software) delivers the therapy; there isn't a separate "human-in-the-loop" performance associated with its direct therapeutic action, but rather clinical oversight and operation by a healthcare professional. The software verification and validation are noted, but this is for the control system's reliability, not an "algorithm-only performance" in the diagnostic AI sense.
7. The type of ground truth used
For the effectiveness of the OCD treatment, the "ground truth" is essentially the established clinical efficacy of the primary predicate device (HORIZON® 3.0 TMS Therapy System K222171), whose OCD treatment protocol the Apollo TMS Therapy System replicates. The substantial equivalence claim means that because the subject device's treatment parameters are identical and its output stimulation is adequately similar, it can be expected to achieve the same therapeutic effect.
For the safety and performance of the device itself (e.g., electrical safety, temperature limits, consistent stimulus delivery), the "ground truth" is established through adherence to recognized consensus standards (e.g., IEC 60601-1) and successful non-clinical engineering tests.
8. The sample size for the training set
This information is not applicable. The Apollo TMS Therapy System is not an AI/ML device in the sense of requiring a large "training set" of patient data for its primary function. Its software (Stimware) manages protocols and patient data, but it's not "trained" on patient outcomes to learn or adapt therapeutic delivery in an AI sense.
9. How the ground truth for the training set was established
This information is not applicable for the same reasons as point 8.
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(122 days)
Re: K251125**
Trade/Device Name: MagVenture TMS Therapy System
Regulation Number: 21 CFR 882.5805
Classification Names:** Repetitive transcranial magnetic stimulation system
Regulation: 21 CFR 882.5805
NeuroStar Advanced Therapy System
Predicate 510(k): K231926
Predicate Regulation: 21 CFR 882.5805
Predicate 510(k):** K150641, K170114, K171481, K171967, K172667, K173620
Predicate Regulation: 21 CFR 882.5805
MagVenture TMS Therapy System is indicated as an adjunct for the treatment of Major Depressive Disorder in adolescent patients (age 15-21).
The MagVenture TMS Therapy System is a transcranial magnetic stimulation device. Specifically, it is a computerized, electromechanical medical device that produces and delivers non-invasive magnetic fields to induce electrical currents targeting specific regions of the cerebral cortex. Transcranial magnetic stimulation (TMS) is a non-invasive technique used to apply brief magnetic pulses to the brain. The pulses are administered by passing high currents through an electromagnetic coil placed adjacent to a patient's scalp.
The pulses generate an electric field in the underlying brain tissue. When this field surpasses a specific threshold and aligns appropriately with the brain's neuronal pathways, it induces localized axonal depolarization, leading to neuron activation in the targeted brain region.
The MagVenture TMS Therapy System represents an integrated system comprised of the following components:
- Magnetic Stimulator (MagPro Family)
- Coil for motor threshold determination: C-B60, C-B70
- Treatment Coils: Cool-B65, Cool-B70, Cool D-B80
- Accessories:
- Trolley with mounting for super flexible arm and coil holder arrangement)
- Patient head fixation
- Super flexible arm or Flow Arm for coil fixation
- Isolation transformer
- Cooler Unit
- Caps and Marking accessory (marking plate, pen, ruler) – Beam F3 or 5.5 cm Coil Placement
- Vacuum pump and Vacuum pillow with Pillow Case for patient head fixation (Optional)
- Treatment Chair (Optional)
- Coil Hub (Optional)
- MagVenture TMS Atlas Neuro Navigation System (Optional)
Except for the Beam F3 marking plate, all components have previously received FDA clearance. The MagVenture TMS Therapy System and its technological characteristics remain equivalent to those cleared under K150641, K170114, K171481, K171967, K172667, K173620.
This submission introduces the following modifications:
- Expanded Indications: MagVenture TMS Therapy System is indicated as an adjunct for the treatment of Major Depressive Disorder (MDD) in adolescent patients (age 15-21)
- Coil Approval Expansion: Inclusion of Cool D-B80 for MDD in adolescent patients (age 15-21).
- Beam F3 Marking Method: Introduces the Beam F3 marking plate as an alternative to the standard 5.5 cm method for coil positioning in the dorsolateral prefrontal cortex (DLPFC).
Apart from the modifications outlined above, the core design, fundamental operating principles, and safety characteristics remain substantially equivalent to the previously cleared MagVenture TMS Therapy System.
The provided FDA 510(k) clearance letter and associated summary pertain to the MagVenture TMS Therapy System. However, this documentation does not describe an acceptance criteria table or a study that specifically proves the device meets such criteria in the context of an Artificial Intelligence (AI) / Machine Learning (ML) enabled medical device.
The document primarily focuses on demonstrating substantial equivalence to predicate devices for the treatment of Major Depressive Disorder (MDD) in adolescent patients, expanding indications, and introducing a new coil positioning method. It highlights non-clinical performance testing against electrical safety and performance standards (e.g., IEC 60601-1) and a clinical literature review to support safety and effectiveness.
Therefore, I cannot fulfill the request to describe the acceptance criteria and the study that proves the device meets the acceptance criteria for an AI/ML enabled medical device, as the provided text relates to a Transcranial Magnetic Stimulation (TMS) system, which is a hardware-based therapy device, not an AI/ML diagnostic or prognostic tool.
The questions you've asked are highly relevant for the clearance of AI/ML medical devices (e.g., in medical imaging or diagnostics), which require rigorous validation of their algorithmic performance. The provided document does not contain this information because the MagVenture TMS Therapy System is not an AI/ML enabled device.
To answer your request accurately, based on the provided text, I can only state that the document does not contain the information required to populate the fields related to AI/ML device acceptance criteria and validation studies.
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(119 days)
Re: K251119**
Trade/Device Name: MagVenture TMS Therapy System
Regulation Number: 21 CFR 882.5805
Regulation: 21 CFR 882.5805, 21 CFR 882.5802
Regulatory Class: Class II
Device Panel:
NeuroStar Advanced Therapy System
Predicate 510(k): K230029
Predicate Regulation: 21 CFR 882.5805
K251119 | K230029 | |
| Product codes/Classification | OBP | OBP | Same |
| Regulation Numbers | 21 CFR 882.5805
| 21 CFR 882.5805 | Same |
CLINICAL CHARACTERISTICS
| Items | New device | Predicate device |
MagVenture TMS Therapy is indicated for the treatment of depressive episodes and for decreasing anxiety symptoms for those who may exhibit comorbid anxiety symptoms in adult patients suffering from Major Depressive Disorder (MDD) and who have failed to achieve satisfactory improvement from prior antidepressant medication in the current episode.
The MagVenture TMS Therapy system is intended to be used as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD).
The MagVenture TMS Therapy System is a transcranial magnetic stimulation device. Specifically, it is a computerized, electromechanical medical device that produces and delivers non-invasive magnetic fields to induce electrical currents targeting specific regions of the cerebral cortex.
Transcranial magnetic stimulation (TMS) is a non-invasive technique used to apply brief magnetic pulses to the brain. The pulses are administered by passing high currents through an electromagnetic coil placed adjacent to a patient's scalp.
The pulses generate an electric field in the underlying brain tissue. When this field surpasses a specific threshold and aligns appropriately with the brain's neuronal pathways, it induces localized axonal depolarization, leading to neuron activation in the targeted brain region.
The MagVenture TMS Therapy System represents an integrated system comprised of the following components:
- Magnetic Stimulator (MagPro Family)
- Coil for motor threshold determination: C-B60, C-B70
- Treatment Coils: Cool-B65, Cool-B70, Cool D-B80
- Accessories:
- Trolley with mounting for super flexible arm and coil holder arrangement)
- Patient head fixation
- Super flexible arm or Flow Arm for coil fixation
- Isolation transformer
- Cooler Unit
- Caps and Marking accessory (marking plate, pen, ruler) – Beam F3 or 5.5 cm Coil Placement
- Vacuum pump and Vacuum pillow with Pillow Case for patient head fixation (Optional)
- Treatment Chair (Optional)
- Coil Hub (Optional)
- MagVenture TMS Atlas Neuro Navigation System (Optional)
Except for the Beam F3 marking plate, all components have previously received FDA clearance. The MagVenture TMS Therapy System and its technological characteristics remain equivalent to those cleared under K150641, K171481, K171967, K173620, K193006 for Major Depressive Disorder (MDD) and Obsessive-Compulsive Disorder (OCD) indications.
This submission introduces the following modifications:
- Expanded Indications: Includes treatment for depressive episodes and comorbid anxiety symptoms in adult patients with MDD who have not responded satisfactorily to prior antidepressant medication.
- Coil Approval Expansion: All three MagVenture treatment coils are now included for MDD, MDD w/ comorbid anxiety symptoms, depressive episodes, and OCD treatment.
- Beam F3 Marking Method: Introduces the Beam F3 marking plate as an alternative to the standard 5.5 cm method for coil positioning in the dorsolateral prefrontal cortex (DLPFC).
All other aspects of the device compared to the currently marketed MagVenture TMS Therapy remain unchanged.
The provided FDA 510(k) clearance letter for the MagVenture TMS Therapy System does not contain any information about acceptance criteria or a study proving that the device meets those criteria, especially in the context of AI/algorithm performance.
This document is a traditional 510(k) submission, which focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting detailed performance study results against specific acceptance criteria for a new, AI-driven diagnostic or therapeutic system.
Here's a breakdown of why the requested information cannot be extracted from this document:
- Device Type: The MagVenture TMS Therapy System is a Transcranial Magnetic Stimulation device, an electromechanical medical device that physically delivers magnetic pulses. It is not an AI-driven diagnostic or therapeutic algorithm. The "AI" context in your prompt is not relevant to this specific device.
- Focus of 510(k): The core of this 510(k) summary is to demonstrate that the MagVenture TMS Therapy System, with its introduced modifications, is "substantially equivalent" to an existing predicate device (NeuroStar Advanced Therapy System, K230029). This is shown by comparing technological characteristics, indications for use, and treatment parameters, not by conducting novel clinical trials to establish its own efficacy against predefined acceptance criteria for AI performance.
- "Performance Data" Section (Page 16): This section explicitly states:
- "No clinical performance data were included in this submission."
- Performance testing summarized relates to electrical safety, electromagnetic compatibility (compliance with IEC standards), and quality/risk management (ISO standards).
- Computational modeling (SimNIBS v4.0.1) was used to compare electric field strength of coils, which is a physical characteristic, not a clinical efficacy or AI performance metric.
Therefore, I cannot provide the requested information based on the provided document. The document discusses the device's technical specifications and its equivalence to a predicate device, but not how it meets acceptance criteria for an AI or imaging-based clinical outcome.
Specifically, the following points from your request cannot be addressed as they pertain to AI/algorithm performance studies which are not described in this 510(k):
- Table of acceptance criteria and reported device performance (for AI performance): Not applicable. The "performance" discussed is electrical and safety compliance, not AI accuracy or efficacy.
- Sample size for test set and data provenance: No clinical test set data for algorithm performance is mentioned.
- Number of experts and qualifications for ground truth: No expert-driven ground truth establishment for AI is mentioned.
- Adjudication method: Not applicable.
- Multi-reader multi-case (MRMC) comparative effectiveness study: Not applicable, as there's no AI component or human-in-the-loop study discussed.
- Standalone (algorithm only) performance: Not applicable.
- Type of ground truth used: Not applicable in the context of AI/algorithm performance.
- Sample size for training set: No training set for an algorithm is mentioned.
- How ground truth for training set was established: Not applicable.
This 510(k) clearance is for a physical medical device, not an AI software.
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(30 days)
DK-3520
Denmark
Re: K252032
Trade/Device Name: T65 (9016E0611)
Regulation Number: 21 CFR 882.5805
Classification Names:** Repetitive transcranial magnetic stimulation system
Regulation: 21 CFR 882.5805
Treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
The MagVenture Coil T65 is a figure-of-eight, actively cooled coil designed for use in transcranial magnetic stimulation (TMS) therapy as part of the MagVenture TMS Therapy System. The system delivers magnetic pulses for generating evoked responses, assessing motor thresholds (MT), and administering therapeutic treatments.
The T65 is a redesign of the treatment coil Cool-B65, to include the motor threshold (MT) determination capability of the C-B60 coil. This reduces the need for coil exchange during patient sessions, supporting a more streamlined workflow for clinicians.
The T65 incorporates several ergonomic and functional enhancements compared to the existing coil:
- Integrated intensity control wheel allowing direct manual adjustment of stimulation output.
- Built-in trigger button with LED status indication to display coil readiness.
- Reduced weight for improved maneuverability and ease of use.
- Strain relief mechanisms at both the coil and connector ends to improve durability and reduce cable stress.
The provided FDA 510(k) clearance letter for the T65 Repetitive Transcranial Magnetic Stimulation System does not contain any information about acceptance criteria or a study proving the device meets those criteria in the context of AI/algorithm performance.
This document is a Special 510(k) submission, which signifies that the device (T65 coil) is a modification of an existing cleared device (Cool-B65 coil) and that the modifications do not raise new questions of safety or effectiveness. The core of such a submission is to demonstrate substantial equivalence to a predicate device.
Specifically, the document states:
- "No clinical testing is required to support this submission." This explicitly indicates that no comparative effectiveness study (like an MRMC study) or standalone performance study was performed or needed.
- The comparison focuses on technological characteristics (weight, integrated intensity control, trigger button, materials, electrical safety, etc.) and states that these differences "does not raise different questions of safety and effectiveness compared to the existing device."
- The non-clinical testing focuses on compliance with general safety and performance standards (IEC 60601-1, IEC 60601-1-2, ISO 13485, ISO 14971) and ensuring magnetic field characteristics are within a ±5% tolerance of the predicate device. This is a performance verification of the physical device components, not an AI or algorithm performance evaluation.
Therefore, I cannot provide the requested information regarding acceptance criteria, study details, expert involvement, or AI performance metrics because this information is not present in the provided text. The device is a physical medical device (a TMS coil), not an AI-powered diagnostic or therapeutic algorithm.
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(70 days)
55114
Re: K251210
Trade/Device Name: Ampa One System (AMPA-001)
Regulation Number: 21 CFR 882.5805
stimulation system |
| Classification Name | Transcranial Magnetic Stimulator |
| Regulation Number | 882.5805
The Ampa One System is intended for treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
The Ampa One System is a computerized, electromechanical medical device that produces and delivers non-invasive, magnetic fields to induce electrical currents in brain tissues to target specific regions of the cerebral cortex. The system contains two different coils for targeting different regions of the brain. The L Coil is designed to target the left dorsolateral prefrontal cortex (DLPFC). The M Coil is designed to target the bilateral prefrontal cortex (DMPFC). Both coils are used within the Ampa One System to treat Major Depressive Disorder (MDD) in adult patients who have failed to receive satisfactory improvement from prior antidepressant medication in the current episode.
The Ampa One System is an integrated system composed of the following hardware and software components with associated functions to enable its intended use:
- Ampa L and M Coils - MT determination and Depression treatment
- Ampa Pulse Generator - Provide Electrical power to the coils
- Ampa Control Pad - The software interface for operators to control TMS treatment
- Axon Cable - Provides connections between the Ampa Pulse Generator and Ampa Control Pad
- Ampa Magic Arm - Support system to securely hold the coils in place during treatment
- Neuronavigation Cap - Fabric cap worn by patient with integrated markings for determination of cerebral cortex treatment targets
The system comes preloaded with a mobile app on the Ampa Control Pad containing the software interface for operation of the system.
This FDA 510(k) clearance letter pertains to a modification of an existing device, the Ampa One System (AMPA-001), specifically replacing a bridging connector and external pulse generator with an integrated Ampa Pulse Generator. The clearance relies on demonstrating substantial equivalence to the previously cleared Ampa One System (K243319).
Based on the provided document, here's a breakdown of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a "table of acceptance criteria" with specific quantitative thresholds. Instead, it states that the acceptance criteria are based on demonstrating "substantially equivalent magnetic characteristics compared to the predicate devices" and "equivalent in terms of safety and effectiveness." The reported performance is articulated through comparative testing against the predicate device.
| Category | Acceptance Criteria (Inferred from Document) | Reported Device Performance |
|---|---|---|
| Magnetic Characteristics (Effectiveness) | Substantial equivalence in the amplitude of magnetic field strength as a function of power input; substantial equivalence in spatial characteristics of the magnetic field. | Testing demonstrated that the Ampa One System (new configuration) produced substantially equivalent magnetic characteristics compared to the predicate devices (Ampa One System with MagVenture MagPro R30). Specifically, tests confirmed equivalence in: - Amplitude of the magnetic field strength as a function of power input. - Spatial characteristics of the magnetic field. - Waveforms (210 μs biphasic sinusoid for both L and M coils with the new system vs. 290 μs with predicate, deemed substantially equivalent) |
| Safety | The device is able to function as intended, with risks assessed of TMS therapy mitigated through design. | Safety testing established that the Ampa One System (new configuration) is able to function in its configuration with the Ampa One pulse generator to perform its intended use. Development and testing performed in conformance with FDA Special Controls Guidance on Transcranial Magnetic Stimulator devices and voluntary consensus standards (e.g., IEC 60601-1 and IEC 60601-1-2 for electrical safety). |
| Treatment Protocol Parameters | Identical or substantially equivalent to the predicate device's parameters. | Identical: Repetition rate, pulses per train, number of trains, inter train interval, treatment time, coil configuration, patient contacting materials, coil positioning system. Substantially Equivalent: L Coil SMT range (0-1.7 SMT vs 0-2.0 SMT for predicate), M Coil SMT range (0-1.4 SMT vs 0-1.7 SMT for predicate). These differences are considered substantially equivalent. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document explicitly states: "Clinical Data was not applicable for this submission."
Therefore, there was no clinical test set in the traditional sense, and thus no sample size for clinical efficacy or safety, nor data provenance information for such a test set. The testing conducted was non-clinical (bench testing) to demonstrate substantial equivalence of the modified device's performance to the predicate device.
3. 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)
Since no clinical data or human evaluation of the device's diagnostic or therapeutic outcome was conducted for this 510(k), there were no experts used to establish a "ground truth" in the context of a clinical test set. The validation was based on engineering and performance specifications compared against the predicate device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. As per point 3, no clinical test set requiring expert adjudication was utilized for this submission.
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
Not applicable. This device is a Repetitive Transcranial Magnetic Stimulation System, not an AI-assisted diagnostic or imaging system. Therefore, an MRMC comparative effectiveness study involving human readers or AI assistance is not relevant to this 510(k) submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The "standalone" performance in this context would refer to the performance of the Ampa One System itself, measured through its magnetic characteristics and functional safety. This type of non-clinical, standalone performance testing was indeed done. The effectiveness testing specifically focused on the magnetic characteristics of the Ampa One System with the new pulse generator, comparing them to the predicate device.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
For this non-clinical submission, the "ground truth" for demonstrating substantial equivalence was effectively the established performance characteristics of the legally marketed predicate device (Ampa One System K243319), as defined by its prior FDA clearance and the relevant FDA Special Controls Guidance. The new device's performance was measured and compared against these established characteristics to prove it met the same reasonable expectation of safety and effectiveness.
8. The sample size for the training set
Not applicable. This 510(k) pertains to a hardware modification of an existing medical device, not a machine learning or AI-driven system that requires a "training set."
9. How the ground truth for the training set was established
Not applicable, as there was no training set for this submission.
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(160 days)
specifically list in its scope the subject device of this submission (Product Code QCI, Regulation 882.5805
) and thus is applicable to a very similar device (Product Code QCI, Regulation 882.5805) and thus satisfies
The Ultimate rTMS for OCD is intended to be used as an adjunct for the treatment of adult patients suffering from Obsessive-Compulsive Disorder(OCD).
The Ultimate rTMS for OCD is a repetitive transcranial magnetic stimulation (rTMS) system. This computerized medical device produces non-invasive, repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex for the treatment of Obsessive-Compulsive Disorder (OCD).
It can be used in patient care institutions, diagnostics centers, neurosurgical hospitals and experimental laboratories of research institutions.
The Ultimate rTMS principle of operation is based on the discharge of high voltage capacitor through stimulation coil; the pulsed magnetic field generated by the discharge current penetrates through neuromuscular tissues nearby to induce electrical currents in cortical neurons.
Area of the brain to be simulated for ODC treatment is the Dorsomedial Prefrontal Cortex.
The provided FDA 510(k) clearance letter and summary for the "Ultimate rTMS for OCD (M-series)" device focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance characteristics, rather than a clinical study evaluating the device's efficacy in treating OCD. Therefore, it does not contain the detailed information about clinical acceptance criteria, study design (sample size, data provenance, expert adjudication, MRMC, standalone performance, ground truth for test/training sets) that would typically be found in a clinical trial report.
The document primarily shows that the new device's technical specifications and physical/magnetic properties are comparable to a previously cleared device. It asserts that the proposed device does not introduce new safety concerns and has equivalent performance characteristics based on bench testing.
Here's an attempt to answer the questions based on the provided text, with many fields marked as "Not Applicable" or "Not Provided" due to the nature of the submission:
1. Table of acceptance criteria and the reported device performance
The acceptance criteria are implicitly defined by the demonstration of substantial equivalence to the predicate device (MagVenture TMS Therapy system K193006) through close matching of technological characteristics and non-clinical performance (bench testing) according to FDA guidance. The "reported device performance" are the measured values for the Ultimate rTMS for OCD (M-series) in comparison to the predicate.
| Criteria (Implicit Acceptance based on Predicate Equivalence) | Proposed Device Ultimate rTMS for OCD Performance (Reported) | Predicate Device MagVenture TMS Therapy system (K193006) Performance (Reported) | Equivalence Comments (Context of Acceptance) |
|---|---|---|---|
| Intended Use | Treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD) | Treatment of adult patients suffering from Obsessive-Compulsive Disorder (OCD) | Identical |
| Treatment Protocol (Magnetic Field Intensity, Frequency, Train/Inter-train duration, Pulses/Session, Session Duration, Sessions/week, Treatment Schedule, Area of brain to be stimulated) | All match predicate values | All specified | Identical |
| Coil Configuration | Double-cone coil | Double-cone coil | Identical |
| Coil Materials of Construction | Copper tubing (GIS-C1100), Polycarbonate (Covestro Makrolon PC 2805) | Copper tubing (unknown), Polycarbonate (unknown) | Equivalent, no additional concerns for safety and effectiveness. |
| Core material | Air core | Air core | Identical |
| Cooling | Liquid cooling | Liquid cooling | Identical |
| Coil for MT determination | Used for both MT determination and treatment. | Used for both MT determination and treatment. | Identical |
| Number of Turns/Wing | 8 (Upper: 4, Lower: 4) | 7 (Upper: 4, Lower: 3) | Equivalent (See Note A for explanation). |
| Inner/Outer Diameter of Winding | Inner: 50 mm, Outer: 105 mm | Inner: 67 mm, Outer: 95 mm | Equivalent (See Note A for explanation). |
| Amplitude in SMT units | 0-2.22 SMT (45% intensity → 1 SMT) | 0-2.38 SMT (42% intensity → 1 SMT) | Comparable, within variations seen across cleared TMS devices (See Note B). |
| Waveform | Biphasic sinusoid | Biphasic sinusoid | Identical |
| Active pulse width (μs) | Measured: 308.6 (spec: 300 ±5%) | Measured: 302.2 (spec: 290 ±5%) | Equivalent, compensated by MT settings (See Note C). |
| Max magnetic field strength 3 cm from coil (T) | At 25%: 0.147; 50%: 0.225; 75%: 0.297; 100%: 0.380 | At 25%: 0.119; 50%: 0.212; 75%: 0.301; 100%: 0.391 | Equivalent, narrow range, similar slope and intercept. Compensated by MT settings (See Note D). |
| Max initial dB/dt (kT/s) near coil surface (z=0 cm) | 21.4 | 21.9 | Sufficiently close, compensated by MT settings (See Note E). |
| Max initial dB/dt (kT/s) 3 cm from coil surface (z=3 cm) | 7.73 | 8.12 | Sufficiently close, compensated by MT settings (See Note E). |
| Coil temperature exceed auto-disable | 40°C (104°F) | 41°C (106°F) | Slightly enhanced safety for proposed device. |
| Frequency range (Hz) | 0.1 - 100 | 0.1 - 30 or 0.1 - 100 (model dependent) | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
| Pulse train duration range (s) | Up to 2000 pulses in train | Up to 1000 pulses in train | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
| Inter-train interval range (s) | 0-60s | 0-120s | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
| Maximum trains per session | 250 | 500 | Differences in overall capabilities, but both encompass recommended OCD treatment parameters. |
| Maximum number of pulses per session | 500,000 | 500,000 | Identical maximum. |
| Electrical safety | Complies with IEC 60601-1, IEC 60601-1-2 | Complies with IEC 60601-1, IEC 60601-1-2 | N/A |
| ISO Standards met | ISO 13485:2016, ISO 14971 | ISO 13485:2016 | N/A |
2. Sample size used for the test set and the data provenance
- Sample size: Not applicable. The submission is based on non-clinical (bench) testing of the device's physical and magnetic characteristics rather than a clinical test set of patients.
- Data provenance: Not applicable. The data arises from engineering measurements and comparative bench testing of the physical device components (coils, stimulator output).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Number of experts: Not applicable. Ground truth for clinical efficacy or diagnosis using patient data is not established in this non-clinical submission.
- Qualifications of experts: Not applicable. Engineering and technical experts would have conducted and verified the bench tests.
4. Adjudication method for the test set
- Adjudication method: Not applicable. This was a non-clinical (bench) testing comparison, not a clinical study requiring adjudication of patient outcomes or diagnoses.
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
- MRMC study: No. This is not an AI-assisted diagnostic or therapeutic device that involves human "readers" or image interpretation. It is a TMS system for direct treatment.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone performance: Not applicable. This is a medical device, not a software algorithm in the context of interpretation. Its "standalone" performance is assessed by its physical and magnetic output characteristics in bench tests.
7. The type of ground truth used
- Type of ground truth: The "ground truth" in this context is the measured physical and electromagnetic properties of the new Ultimate rTMS device compared to the established properties of the predicate MagVenture TMS Therapy system, as well as adherence to recognized safety standards (IEC, ISO). The substantial equivalence is built upon the premise that if the new device behaves physically like the predicate, and the predicate is known to be safe and effective, then the new device is also considered safe and effective for the stated indications.
8. The sample size for the training set
- Sample size for training set: Not applicable. This is a conventional medical device whose performance is characterized by its engineering specifications and bench test results. It does not involve machine learning or AI that requires a "training set."
9. How the ground truth for the training set was established
- Ground truth for training set: Not applicable (as above).
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(160 days)
Hampshire 03079
Re: K243460
Trade/Device Name: Ultimate rTMS
Regulation Number: 21 CFR 882.5805
stimulation system |
| Classification Name | Transcranial Magnetic Stimulator |
| Regulation Number | 882.5805
The Ultimate rTMS is indicated for the treatment of Major Depressive Disorder in adult patients who have failed to receive satisfactory improvement from prior antidepressant medications in the current episode.
The Ultimate rTMS is a repetitive transcranial magnetic stimulation (rTMS) system. This computerized medical device produces non-invasive, repetitive pulsed magnetic fields of sufficient magnitude to induce neural action potentials in the prefrontal cortex for the treatment of Major Depressive Disorder.
It can be used in patient care institutions, diagnostics centers, neurosurgical hospitals and experimental laboratories of research institutions.
The Ultimate rTMS principle of operation is based on the discharge of high voltage capacitor through stimulation coil; the pulsed magnetic field generated by the discharge current penetrates through neuromuscular tissues nearby to induce electrical currents in cortical neurons.
Area of the brain to be simulated for MDD treatment is Left Dorsolateral Prefrontal Cortex.
This 510(k) clearance letter details the substantial equivalence of the Ultimate rTMS device to its predicate devices, Mag Vita TMS Therapy System. The provided information primarily focuses on non-clinical performance and technological comparisons, rather than a clinical trial with human subjects. Therefore, some information requested in your prompt regarding clinical study elements (like sample size for test sets, ground truth establishment for test sets, expert adjudication, or MRMC studies) is not explicitly detailed or applicable in the provided document.
Here's the breakdown of the acceptance criteria and the study (non-clinical performance tests) that proves the device meets them, based on the provided text:
Acceptance Criteria and Reported Device Performance
The acceptance criteria are not explicitly listed in a separate table, but rather implied through the "Equivalence Comments" in the "Technological Comparison" and the "Non-clinical and/or Clinical Tests Summary & Conclusions" sections. The core acceptance criterion is substantial equivalence to the predicate devices, meaning the Ultimate rTMS device performs similarly and does not raise new safety or effectiveness concerns.
Here's a table summarizing the key performance metrics and their comparison to predicates, which serve as the "acceptance criteria" through equivalence:
| Criteria | Acceptance Criteria (Equivalent to Predicate) | Reported Ultimate rTMS Performance |
|---|---|---|
| Magnetic Field Intensity (SMT units) | Comparable to predicate (e.g., 0-2.1 to 0-2.4 SMT range, with 1 SMT achieved at similar % intensity settings). | BY90A, BF90A, BY90B Coils: 0 – 2.4 SMT (41% intensity → 1 SMT). (Predicate MagVita: 0 – 2.1 SMT, 47% intensity → 1 SMT). Comment: Slightly lower intensity setting needed for Ultimate rTMS to achieve same induced current, indicating favorable performance. |
| Waveform | Biphasic sinusoid. | Biphasic sinusoid. |
| Active Pulse Width (µs) | Comparable to predicate (e.g., 290 µs ± 5% for MagVita) within typical variations among cleared TMS devices. | BY90A, BF90A, BY90B Coils: 320 µs ± 10%. (Predicate MagVita: 290 µs ± 5%). Comment: Difference is comparable to other cleared devices. Higher pulse width means lower intensity needed to reach MT, aligned with SMT comparison. |
| Max Magnetic Field Strength 2 cm (T) | Comparable values to predicate across intensity settings, with equivalent slope and intercept values. | At 25% Intensity: BY90A: 0.172 T, BF90A: 0.182 T, BY90B: 0.117 T. At 50% Intensity: BY90A: 0.291 T, BF90A: 0.287 T, BY90B: 0.244 T. At 75% Intensity: BY90A: 0.403 T, BF90A: 0.395 T, BY90B: 0.369 T. At 100% Intensity: BY90A: 0.498 T, BF90A: 0.494 T, BY90B: 0.481 T. (Predicates values provided for comparison). Comment: Values are in a narrow range and show equivalent behavior despite slight differences. |
| Max Initial dB/dt (kT/s) (near/2cm from coil) | Sufficiently close to predicate values. | Near Coil (z=0cm): BY90A: 13.44, BF90A: 13.76, BY90B: 12.10. 2cm from Coil (z=2cm): BY90A: 3.59, BF90A: 4.27, BY90B: 6.78. (Predicates values provided for comparison). Comment: Considered equivalent; differences compensated by differing % power for 120% MT. |
| Output Intensity Stability within Burst | Max change < 1% among pulses in a burst (essential for iTBS protocol). | BY90A: 0.563%, BF90A: 0.580%, BY90B: 0.679%. (Predicate C-B70: 0.615%). Comment: All coils show less than 1% variation, meeting the established requirement. |
| Coil Temperature Safety Feature | System automatically disabled when coil temperature exceeds a threshold (e.g., 41°C / 106°F for predicates). | Shuts down system when coil temperature exceeds 40°C (104°F). Comment: Provides slightly enhanced safety compared to 41°C for predicate. |
| Positioning Method Reliability | Based on direct relationship of cortical brain anatomy to scalp, and at least as effective as predicate. | "The reliability of the positioning method used by the subject device is based on the direct relationship of the underlying cortical brain anatomy to the patient's scalp, as is the method used in the predicate devices. The method for identifying the correct treatment position in the subject device is at least as effective as the method employed by the predicate device." |
| Safety and EMC Standards Compliance | Compliance with IEC 60601-1 and IEC 60601-1-2. Patient caps biocompatibility (exempt from ISO 10993-1). | Complies with IEC 60601-1:2005/(R)2012 and IEC 60601-1-2:2014. Patient caps are textile, exempt from ISO 10993-1. |
| Coil Material Safety | Equivalent materials and no additional safety concerns. | Copper tubing (GIS-C1100) and polycarbonate (Covestro Makrolon PC 2805). Comment: Equivalent to predicate materials, no additional safety concerns. |
| Coil Configuration | Figure-of-eight coil. | Figure-of-eight coil (BY90A, BF90A, BY90B). BY90B has 120° angle. Comment: Same figure-of-eight configuration across all coils. Differences are typical variations among manufacturers. |
| Coil Cooling | Equivalent cooling methods to predicates (liquid, forced air, or uncooled). | BY90A: Liquid cooling; BF90A: Forced Air cooling; BY90B: Liquid cooling. Comment: Equivalent to predicate options. |
Study Details (Non-Clinical Performance Tests)
The document refers to non-clinical performance tests rather than a clinical study with human participants. These tests were conducted to demonstrate the substantial equivalence of the Ultimate rTMS device to its predicate devices concerning its physical and electrical characteristics.
-
Sample Size Used for the Test Set and Data Provenance:
- Test Set: No specific "sample size" of devices or units is mentioned for the non-clinical tests. These are typically characterization tests performed on representative units of the device and its components (coils).
- Data Provenance: The data originates from internal tests conducted by Brain Ultimate, Inc., or its contracted labs, as indicated by the "Coils Test Report" mentioned. The country of origin is not explicitly stated but implied to be where Brain Ultimate, Inc. operates (Alpharetta, GA, United States). These are prospective engineering tests performed specifically for this 510(k) submission.
-
Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- This question is not applicable as the "ground truth" for non-clinical performance tests is established by engineering and physics principles, not expert human interpretation of medical images or patient outcomes. The "ground truth" is typically the measured physical properties themselves, compared against established ranges or predicate device specifications.
-
Adjudication Method for the Test Set:
- Not applicable. Adjudication methods (like 2+1 or 3+1) are used in clinical studies where human experts interpret data (e.g., radiology reads) and their agreement/disagreement needs resolution. For non-clinical performance tests, measurements are taken by instruments, and compliance is determined by comparing measured values against predefined engineering specifications and predicate device data.
-
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, this was not done. The document explicitly states "Non-Clinical and/or Clinical Tests Summary & Conclusions," and the subsequent details focus entirely on non-clinical performance (electric/magnetic field characteristics, safety standards, etc.). There is no mention of a human reader study or clinical effectiveness trial for the Ultimate rTMS device in this 510(k) summary. Therefore, an effect size of how human readers improve with AI vs. without AI assistance is not applicable here.
-
Standalone (Algorithm Only Without Human-in-the-loop Performance) Study:
- Yes, in essence, the non-clinical performance studies represent a standalone evaluation. The device's physical and electrical characteristics are evaluated intrinsically, without human interaction influencing the outputs or measurements. The software mentioned (part of the TMS stimulator) enables the device's function, and its performance (e.g., maintaining pulse stability) is tested as part of the overall system.
-
Type of Ground Truth Used:
- For the non-clinical tests, the "ground truth" is objective physical measurements and established engineering parameters. These include:
- Measured electrical and magnetic field characteristics (amplitude, waveform, pulse width, field strength, dB/dt).
- Compliance with recognized international standards (IEC 60601-1, IEC 60601-1-2).
- Comparison to the established performance characteristics of the legally marketed predicate devices.
- For the non-clinical tests, the "ground truth" is objective physical measurements and established engineering parameters. These include:
-
Sample Size for the Training Set:
- Not applicable. This device is a hardware system, not an AI/ML algorithm that requires a "training set" of data in the conventional sense. The "knowledge" embedded in the device comes from engineering design, specifications, and physical principles, not machine learning from a dataset.
-
How the Ground Truth for the Training Set Was Established:
- Not applicable. As above, there is no "training set" or corresponding ground truth establishment process for a machine learning model. The device's functionality is based on its physical construction and control software.
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