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510(k) Data Aggregation

    K Number
    K243782
    Manufacturer
    Date Cleared
    2025-07-16

    (219 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    K243782**
    Trade/Device Name: StimTrial Neuromodulation System
    Regulation Number: 21 CFR 882.5870
    Common Name:** Implantable Neurostimulator
    Product Code: GZF
    Regulation Number: 21 CFR §882.5870
    StimRouter Neuromodulation System | Smartpatch PNS System | |
    | Regulation and Product Codes | 21 CFR 882.5870
    GZF | 21 CFR 882.5870 GZF | 21 CFR 882.5870 GZF | 21 CFR 882.5890 NHI | |
    | Indications for Use

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

    The StimTrial System is indicated for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for the StimRouter Neuromodulation System's permanent (long term) implant indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy used in a multidisciplinary approach and not intended to treat pain in the craniofacial region.

    Device Description

    The StimTrial Neuromodulation System is to be used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) implant for a system indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy used in a multidisciplinary approach and not intended to treat pain of craniofacial nerve origin.

    The StimTrial Neuromodulation System is intended to help determine patient candidacy for a permanent implant to help manage pain of peripheral nerve origin. The StimTrial System works by sending electrical impulses from an external stimulator to a lead that is percutaneously placed next to a target nerve. These impulses are intended to interrupt or change the pain signals, inducing the feeling of tingling or numbness (paresthesia), and possibly reducing or replacing the feeling of pain.

    The StimTrial Neuromodulation System consists of three main parts - the percutaneous StimTrial Lead, the StimTrial Lead Adaptor Cable, and the StimTrial External Stimulator. The StimTrial Lead is percutaneously placed with the distal, stimulating end located at or near the targeted peripheral nerve and with the proximal end remaining outside of the body for the trial duration. The StimTrial Lead Adaptor Cable is an external cable that directly connects the StimTrial Lead to the StimTrial External Stimulator providing a direct electrical pathway from the External Stimulator to the Lead. The StimTrial External Stimulator is a device which, when connected to the Lead Adaptor Cable and the StimRouter Electrode (a hydrogel patch electrode) attached to the skin near the implant site, generates electrical stimulation pulses that travel to the StimTrial Lead. Accessories for the StimTrial System include the StimRouter Electrode (a disposable electrode patch, cleared most recently in K211965), the StimTrial Clinician Programmer with Software (CPS) and the optional StimTrial Mobile Application (MAPP) installed on a Smartphone.

    The StimTrial System incorporates both commercially available and specially designed components. The materials used in the StimTrial Lead have a long history of use in implanted devices; the insertion tools are also constructed from materials with a long history of surgical use. Materials in the external accessories are commonly used in both medical and non-medical applications. The powered components of the StimTrial System use commercially available IEC and UL approval rechargeable batteries. There are no components which are plugged into a wall socket during the use of the system by the patient.

    AI/ML Overview

    This document outlines the acceptance criteria and the study conducted to prove that the StimTrial Neuromodulation System meets these criteria, based on the provided FDA 510(k) Clearance Letter.

    Summary of Device Performance Study Information:

    The provided document details various performance tests conducted for the StimTrial Neuromodulation System, but it does not include a clinical study with specific acceptance criteria and reported performance metrics in the format typically used for demonstrating efficacy or performance against a clinical endpoint (e.g., accuracy, sensitivity, specificity, or improvement in patient outcomes).

    Instead, the listed "Performance Testing" are focused on engineering, safety, and regulatory compliance aspects:

    • Labeling Validation
    • Software verification and validation (for External Stimulator, MAPP and CPS software devices)
    • EMC, Wireless Co-Existence and Electrical Safety
    • Usability testing (for Implanting Physician, Treating Clinician and Patient)
    • Bench testing (Tests of the StimTrial Lead, External Stimulator, StimTrial System)
    • Animal testing (Acute and Long-term studies in porcine animal model)
    • Sterilization and Shelf Life (StimTrial Surgical Kit)
    • Biocompatibility (for StimTrial Lead, Insertion Tools and External Stimulator)

    This type of submission for a Class II device like a neuromodulation system for trial stimulation often relies heavily on demonstrating substantial equivalence to predicate devices through technical comparisons and non-clinical performance testing. The purpose of this "StimTrial System" is for trial stimulation to determine efficacy before a permanent implant, meaning its primary function in this context is to safely and effectively deliver electrical stimulation within defined parameters to aid in patient selection for a long-term device. It is not an AI/ML powered device, so many of the questions regarding ground truth, expert adjudication, MRMC studies, and training/test set sample sizes are not directly applicable in the typical sense of an AI/ML performance study.

    Given the information, a detailed table of "acceptance criteria and reported device performance" related to clinical efficacy or AI/ML performance metrics cannot be constructed from the provided text. The "acceptance criteria" for a 510(k) clearance in this context primarily revolve around demonstrating that the device is as safe and effective as its predicate devices, which is achieved through the enumerated non-clinical tests and technical comparisons.

    However, answering the questions as best as possible based on the implied purpose of such a device and the provided text:


    Implied Acceptance Criteria and Study to Prove Device Meets Criteria (Based on information provided)

    The "StimTrial Neuromodulation System" is a medical device for trial stimulation. Its acceptance criteria are implicitly tied to demonstrating safety and performance characteristics that are substantially equivalent to legally marketed predicate devices, as this is a 510(k) submission. The study proving this typically involves a combination of bench testing, software validation, biocompatibility, and animal studies, rather than large-scale clinical trials for efficacy.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Since the document focuses on demonstrating substantial equivalence through technical specifications and non-clinical testing rather than clinical performance metrics, a table of "acceptance criteria" for a clinical outcome (e.g., sensitivity, specificity, accuracy) is not present. The acceptance criteria relate to meeting specific engineering, safety, and biocompatibility standards, and these are largely reported as successful completion of the tests mentioned in Section VII.

    Category/TestAcceptance Criteria (Implied)Reported Performance (Implied from "Conclusion")
    Labeling ValidationLabeling is clear, accurate, and compliant with regulatory requirements.Successfully completed.
    Software Verification & ValidationSoftware (External Stimulator, MAPP, CPS) functions as intended, is safe, secure, and reliable.Successfully completed.
    EMC, Wireless Co-existence, Electrical SafetyDevice meets relevant electrical, electromagnetic compatibility, and wireless co-existence standards.Successfully completed.
    Usability TestingDevice can be used safely and effectively by intended users (Physician, Clinician, Patient) without excessive errors.Successfully completed.
    Bench Testing (Lead, Stimulator, System)Device components and system meet all defined performance specifications (e.g., stimulation parameters: amplitude, frequency, pulse width, charge, current density are within acceptable ranges and comparable to predicates).Successfully completed. (Comparison tables in Section VI support this). For instance, Amplitude (max) 10mA, Pulse frequency 1-200 Hz, Pulse width 100-500 µsec, Max charge per pulse 5.0 µC, etc., are within ranges of predicates.
    Animal Testing (Acute & Long-term)Device performance and tissue response are acceptable over the trial duration (up to 30 days) in a relevant animal model. No unacceptable adverse biological effects.Successfully completed (in porcine model).
    Sterilization & Shelf LifeDevice remains sterile and functional over its stated shelf life.Successfully completed.
    BiocompatibilityDevice materials in contact with the body are biocompatible.Successfully completed.
    Substantial Equivalence (Overall)The device is as safe and effective as predicate devices and does not raise new safety or effectiveness concerns.Bioventus concludes the StimTrial System is substantially equivalent to the Nalu Neurostimulation System predicate device and does not raise any new issues or concerns of safety or effectiveness. (Section VIII)

    2. Sample Size Used for the Test Set and Data Provenance:

    • Test Set Sample Size: The document does not specify a "test set" in the context of a clinical study for performance evaluation (e.g., accuracy of diagnosis). The "tests" performed are largely engineering validations or animal studies.
      • For Animal Testing, "Acute and Long-term studies in porcine animal model" were conducted. The specific number of animals is not stated.
      • For Usability Testing, the number of "Implanting Physician, Treating Clinician and Patient" participants is not specified.
      • For Bench Testing, the number of units or tests performed is not specified, but it implies a sufficient number to validate performance.
    • Data Provenance: Not explicitly stated for any clinical data as it's not a clinical performance study. Animal studies are typically conducted in a controlled lab environment.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

    Not applicable in the typical sense of AI/ML ground truth establishment. The "ground truth" for this device's performance would be established by objective measurements in bench testing (e.g., output electrical parameters matching specifications), and pathological/physiological observations in animal models (e.g., tissue response). These are based on established engineering and biological standards, not human expert consensus on interpretations of images or signals.

    4. Adjudication Method for the Test Set:

    Not applicable. There is no mention of human-interpreted data that would require an adjudication process.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size of Improvement with AI vs. Without AI Assistance:

    Not applicable. This device is a neuromodulation system, not an AI/ML algorithm for diagnostic or prognostic purposes, and therefore, an MRMC study comparing human readers with and without AI assistance is not relevant.

    6. If a Standalone (i.e., Algorithm Only Without Human-in-the-Loop Performance) Was Done:

    Not applicable. This device is a physical neuromodulation system with accompanying software for control, not a standalone algorithm for independent task execution (like image analysis). Its function inherently involves human-in-the-loop operation (clinician programming, patient use).

    7. The Type of Ground Truth Used:

    The "ground truth" for the various performance tests would be:

    • Bench Testing: Engineering specifications and physical measurements (e.g., electrical parameter values, mechanical properties).
    • Biocompatibility: ISO standards for medical device materials.
    • Sterilization: Sterility assurance levels (SAL) based on validated methods.
    • Animal Testing: Histopathological analysis of tissues, physiological responses, and adverse event monitoring.

    8. The Sample Size for the Training Set:

    Not applicable. This device does not involve a machine learning component that requires a "training set" in the conventional sense.

    9. How the Ground Truth for the Training Set Was Established:

    Not applicable, as there is no training set for an AI/ML model.

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    K Number
    K243678
    Manufacturer
    Date Cleared
    2025-07-03

    (218 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Re: K243678
    Trade/Device Name: TalisMann Neuromodulation System
    Regulation Number: 21 CFR 882.5870
    Common Name:** Implantable Neurostimulator
    Product Code: GZF
    Regulation Number: 21 CFR §882.5870
    Peripheral Nerve Stimulation | Renew Neurostimulation System | |
    | Regulation and Product Codes | 21 CFR 882.5870
    GZF | 21 CFR 882.5870 GZF | 21 CFR 882.5870 GZF | 21 CFR 882.5870 GZF | |
    | Indication for Use | The

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

    The TalisMann Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The TalisMann Neuromodulation System is not intended to treat pain in the craniofacial region.

    Device Description

    The TalisMann Neuromodulation System is intended to provide electrical stimulation via an implanted lead to a target peripheral nerve, for aid in the pain management of adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The TalisMann Neuromodulation System is not intended to treat pain in the craniofacial region.

    The TalisMann Neuromodulation System works by providing electrical impulses to a target area in the body. These impulses may interrupt or change the pain signals, inducing the feeling of tingling or numbness (paresthesia), and possibly reducing or replacing the feeling of pain.

    The TalisMann Neuromodulation System consists of three main parts – the implantable StimRouter Lead (cleared most recently in K211965), the implantable TalisMann Pulse Generator/Receiver that is connected to the implantable Lead, and the external (to the body) components. The Lead is implanted with the stimulation end located at or near the targeted peripheral nerve, whereas the end with the Pulse Generator/Receiver is located near the skin surface. Accessories for the TalisMann include the Clinician Programmer with Software (CPS), the optional Mobile Application (MAPP) installed on a SmartPhone, the StimRouter Electrode (a disposable electrode patch, cleared most recently in K221965), and the TalisMann External Electrical Field Conductor (E-EFC).

    The TalisMann System incorporates both commercially available and specially designed components. The materials used in the TalisMann Pulse Generator/Receiver and Lead have a long history of use in implanted devices; the insertion tools are also constructed from materials with a long history of surgical use. Materials in the external accessories are commonly used in both medical and non-medical applications. The powered components of the TalisMann System use commercially available IEC and UL approval rechargeable batteries. There are no components which are plugged into a wall socket during the use of the system by the patient.

    The TalisMann uses the following components unchanged from the StimRouter System (K211965): the StimRouter Lead, the MAPP software, the E-EFC, and the StimRouter (Hydrogel Patch) Electrodes. The new components of the TalisMann System are: the TalisMann Pulse Generator/Receiver, new implant tools, and the updated Clinician Programmer Software (updated to enable TalisMann parameters).

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the TalisMann Neuromodulation System does not contain the detailed acceptance criteria or a study proving that the device meets specific performance criteria in terms of accuracy, precision, or clinical efficacy.

    The document primarily focuses on establishing substantial equivalence to predicate devices by comparing technological characteristics and listing the types of performance testing conducted for safety and effectiveness. It does not provide quantitative acceptance criteria for device performance nor the results of studies that would demonstrate the device meets such criteria.

    The information provided confirms that the device underwent various forms of testing to demonstrate safety and general performance characteristics relative to its predicates, but not specific performance metrics such as accuracy or efficacy in pain relief that would typically have acceptance criteria.

    Therefore, many of the requested fields cannot be filled based on the provided text.

    Here's an analysis of what information is available and what is missing:

    1. A table of acceptance criteria and the reported device performance

    • Not provided. The document does not specify quantitative acceptance criteria for device performance (e.g., a specific percentage reduction in pain, or a certain accuracy for a diagnostic component). It focuses on direct comparisons of design and general safety/electrical parameters to predicate devices.

    2. Sample size used for the test set and the data provenance

    • Not provided for human clinical studies demonstrating efficacy.
    • Animal Testing: Mentioned as "Acute and Long-term studies in porcine animal model" but sample size is not specified.
    • Provenance: Not specified for any potential clinical data, as no clinical efficacy data is detailed.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Not applicable/Not provided. The document discusses performance testing for safety, electrical characteristics, software validation, and usability. It does not describe a test set requiring expert-established ground truth for a diagnostic or efficacy claim. Usability testing involved "Implanting Physician, Treating Clinician and Patient" but specific numbers or qualifications are not given.

    4. Adjudication method for the test set

    • Not applicable/Not provided. No adjudication method is mentioned as there isn't a stated clinical efficacy or diagnostic performance study requiring ground truth establishment through expert review.

    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. This device is a neuromodulation system for pain relief, not an AI-assisted diagnostic or imaging interpretation tool. Therefore, an MRMC study is not relevant and was not conducted.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not applicable. This device is an implanted neuromodulation system used by a patient, with programming by a clinician. It's not an algorithm that performs a standalone function without human interaction in its therapeutic application. Software verification and validation were performed for the E-EFC, MAPP, and CPS, which are components of the system, but this is a different type of "standalone" than algorithm performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Not explicitly stated for efficacy/clinical performance. For safety and engineering tests, the "ground truth" would be established engineering standards, biocompatibility testing results, and functional requirements. For software, it would be validation against specified requirements. No specific clinical outcomes data or pathology as a "ground truth" for device efficacy is mentioned in the context of performance criteria.

    8. The sample size for the training set

    • Not applicable/Not provided. The device is not described as involving machine learning or AI models that would require a "training set" in the traditional sense for an algorithmic performance claim.

    9. How the ground truth for the training set was established

    • Not applicable/Not provided. (See point 8).

    Summary of what is present:

    The document outlines a substantial equivalence argument based on:

    • Comparison of Indications for Use: Similar to predicates for severe intractable chronic peripheral nerve pain, excluding craniofacial region.
    • Comparison of Technological Characteristics: Detailed tables comparing the subject device (TalisMann Neuromodulation System) to three predicate devices (StimRouter, Nalu, Renew) across components like transmitter/receiver, leads, externally worn devices, clinician programmer, and patient remote control. These comparisons highlight similarities in mode of action, implant site, power sources, stimulation parameters (frequency, duration, charge, power), materials, and software configuration.
    • Performance Testing Categories: A list of testing performed to support safety and effectiveness, including:
      • Labeling Validation
      • Software verification and validation (for E-EFC, MAPP, and CPS)
      • EMC, Wireless Co-Existence, and Electrical Safety
      • Usability testing (for Implanting Physician, Treating Clinician, and Patient)
      • Bench testing (TalisMann implant, external modules, system testing)
      • Animal testing (Acute and Long-term studies in porcine model)
      • Sterilization and Shelf Life
      • Biocompatibility

    Conclusion based on the provided text:

    The FDA 510(k) clearance letter focuses on establishing substantial equivalence for the TalisMann Neuromodulation System by demonstrating that its technological characteristics, intended use, and performance testing (with a focus on safety and established engineering principles) are comparable to legally marketed predicate devices. It does not present a study with specific, quantitative acceptance criteria for clinical performance or efficacy metrics against which the device's performance is measured and reported. The "performance testing" described is primarily geared towards validating individual components and system safety/functionality rather than an overarching clinical effectiveness study with defined endpoints and acceptance criteria in the context often seen for diagnostic or AI-driven devices.

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    K Number
    K233801
    Manufacturer
    Date Cleared
    2024-08-23

    (268 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    , Peripheral Nerve, Implanted (Pain Relief) |
    | Classification Regulation | 21 CFR 882.5870
    predicate. |
    | Regulation | SCS:
    21 CFR §882.5880
    PNS:
    21 CFR §882.5870
    | SCS:
    21 CFR §882.5880
    PNS:
    21 CFR §882.5870

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

    SCS:
    This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    PNS:
    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The Nalu Neurostimulation System for PNS is not intended to treat pain in the craniofacial region. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System (referred to as the "Nalu System") incorporates a miniature implantable pulse generator (IPG), powered by an externally worn Therapy Disc device. The Nalu System therapy utilizes pulsed electrical current to create an energy field that acts on peripheral nerves or central nerves to inhibit the transmission of pain signals to the brain. The Nalu System may be implanted following a successful trial period using the Nalu Neurostimulation trial system. This device is intended to be used in the spinal column as well as the peripheral nerves in arm, leg, pelvic and other areas, as is typical of other devices and treatments for the same intended use.

    The Nalu System is intended for stimulation of the spinal cord or peripheral nerves for patients experiencing chronic, intractable pain. This system is indicated for pain management in adults who have severe intractable chronic pain, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    The Nalu System is comprised of the following components:
    • Implantables (there are no proposed changes to these components as previously provided in K221376):
    o Implantable pulse generator (IPG; available either as an integrated lead unit or with separately connected lead(s)) – provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site(s).
    o Leads – implantable and designed to deliver electrical pulses to the nerves via an array of four (4) or eight (8) cylindrical electrodes at the distal end.
    o Surgical and Trial Tools – includes anchors, spoonbill needs, stylets, tearaway introducers, pocket tunneler, torque wrench, IPG insertion tool, straw tunneler; tools to support implantation of lead and IPG.

    • Externals, Non-Sterile:
      o Externally worn controllers (for use with the permanent implant) and accessories – includes the Therapy Disc, Adhesive Clip, Wearable Garment, Therapy Disc Charger; houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer (subject of this submission).
      o Externally worn stimulator (for use with the trial lead) and accessories – includes the Trial Therapy Disc; sends signals to the percutaneous leads during the trial period by way of the Electrode Interface Cable (EIC).
      • Software (subject of this submission):
      o Clinician Programmer, Patient Remote Control – used to configure the system parameters; also manages patient records, Therapy Discs and remote controls for patients with the Nalu System; runs on Android and iOS platforms and can be optionally used to control and manage Therapy Discs over a secure Bluetooth® Low Energy connection.
    AI/ML Overview

    The provided text is a 510(k) premarket notification for the Nalu Neurostimulation System. It details modifications made to an existing device, primarily to its external components and software, and argues for substantial equivalence to a previously cleared predicate device (K221376).

    Crucially, this document does not describe a study to prove a device meets acceptance criteria related to efficacy or performance comparable to what would be found in a multi-reader, multi-case (MRMC) study or a standalone algorithm performance evaluation for an AI/ML medical device.

    Instead, the "acceptance criteria" and "proof" provided are focused on engineering verification and validation to demonstrate that the modifications to the existing device do not raise new questions of safety or effectiveness, thus maintaining substantial equivalence to its predicate. The device itself is a neurostimulation system for pain relief, not an AI/ML diagnostic tool.

    Therefore, many of the requested items (e.g., sample size for test set, data provenance, number of experts for ground truth, MRMC study, effect size of human reader improvement, standalone performance, type of ground truth, training set sample size, ground truth for training set) are not applicable to this submission, as it is not for an AI/ML algorithm requiring such performance evaluations.

    However, I can extract information relevant to the engineering acceptance criteria and the validation activities performed for the modified device components.

    Here's a breakdown of the information that can be extracted from the provided text, and an explanation of why other requested information is not present:


    Acceptance Criteria and Device Performance (Engineering/Safety Context)

    The document frames its "acceptance criteria" as demonstrating that the modified device's technological characteristics are effectively the same or do not raise different questions of safety and effectiveness compared to the predicate device. The performance is then shown through various engineering and validation tests.

    Acceptance Criterion (Implicit)Reported Device Performance/Proof (Validation Activity)
    Functional Equivalence: The modified external components (Therapy Disc, Base Station, software) maintain the same fundamental function as the predicate device's external components, particularly regarding therapy delivery parameters and communication.Software testing: In accordance with IEC 62304 Edition 1.1 2015-06, FDA guidance documents (Content of Premarket Submissions for Device Software Functions, General Principles of Software Validation).
    Electronics evaluation: "Functional output of TD2 electronics remains unchanged." PCB changes were evaluated through usability and EMC testing.
    Safety - Electromagnetic Compatibility (EMC): The modified device, especially the updated electronics, continues to meet EMC standards.EMC testing: In accordance with 60601-1 Edition 3.2 2020-08, 60601-1-2 Edition 4.0 2014-02, 60601-1-2 Edition 4.1 2020-09.
    Safety - Biocompatibility: New/modified patient-contacting materials (e.g., in the Therapy Disc housing, adhesive clip) are biocompatible and do not pose new risks.Biocompatibility testing: In accordance with ISO 10993-1:2018. New adhesive clip using same materials. Patient contacting materials of TD2 top housing are similar to predicate, and differences pose "very low biocompatibility risk because they have a long history of safe use."
    User Interface/Usability: Changes to the user interface (e.g., gesture controls on Therapy Disc) do not negatively impact usability or introduce new risks.Formative & Summative Usability Testing: In accordance with 62366-1 Edition 1.1 2020-06.
    Physical Specifications/Integrity: The smaller Therapy Disc size and updated accessories maintain physical integrity and fit for purpose.Dimensional verification: Confirms "that the device meets its specifications."
    Packaging Integrity: The packaging adequately protects the device during transport.Packaging Validation: In accordance with ISTA 3A 2018.
    Risk Management: All modifications have been evaluated under a robust risk management system to ensure no new hazards or risks are introduced. (Implicit, as a foundational requirement for medical devices).The testing was "developed in accordance with Nalu Medical, Inc. (Nalu)'s Quality System, including Design Control and Risk Management, per ISO 14971: 2019-12. Design Controls apply to all medical devices manufactured by Nalu in accordance with ISO 13485:2016."

    Study Details (Context of Engineering Validation, Not AI Performance)

    1. Sample size used for the test set and the data provenance: Not applicable in the context of clinical results from a test set as would be used for an AI/ML diagnostic device. The "test set" here refers to physical units of the modified device and its software undergoing various engineering and software validation tests. Data provenance is not described in terms of patient data.

    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth as typically defined for AI/ML performance (e.g., expert consensus on medical images) is not relevant for this engineering and software validation. The "ground truth" for these tests are largely defined by engineering specifications, regulatory standards, and functional requirements.

    3. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable. Adjudication methods are used in studies involving human interpretation or performance, typically for diagnostic accuracy.

    4. 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, an MRMC comparative effectiveness study was NOT done. The document explicitly states: "No clinical testing was performed."
      • This device is a neurostimulation system, not a diagnostic imaging AI/ML device that assists human readers.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable in the context of an AI/ML algorithm. The "software testing" mentioned evaluates the software's functional correctness against its specifications, not its standalone diagnostic or interpretive performance.
    6. The type of ground truth used (expert concensus, pathology, outcomes data, etc.): Not applicable for an AI/ML context. For the engineering and software validation, the "ground truth" is adherence to established engineering specifications, industry standards (e.g., ISO, IEC), and regulatory guidance.

    7. The sample size for the training set: Not applicable. This submission is for hardware and software modifications to a neurostimulation device, not for an AI/ML model that requires a training set.

    8. How the ground truth for the training set was established: Not applicable, as there is no AI/ML training set in this context.

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    K Number
    K232415
    Manufacturer
    Date Cleared
    2024-08-21

    (376 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Trial/ Extension Lead Kits, Patient Kits and Miscellaneous Replacement Kits Regulation Number: 21 CFR 882.5870
    peripheral nerve, implanted (Pain Relief) | | | |
    | Regulation Number | 21 CFR§882.5870
    |
    | Regulation Number | 21 CFR §882.5870
    | 21 CFR §882.5870

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

    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System for Peripheral Nerve Stimulation (also referred to as the "Nalu System") is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Nalu System incorporates a miniature implantable pulse generator, powered by an externally worn Therapy Disc device. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on the peripheral nerves to inhibit the transmission of pain signals to the brain. The Nalu System may be implanted following a successful trial period using the Nalu Neurostimulation trial system. The Nalu System is comprised of 5 elements: Nalu Implantable Pulse Generator, Leads, Surgical and Trial Tools, Externally worn Therapy Disc, and Clinician Programmer and Remote Control.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the Nalu Neurostimulation System for Peripheral Nerve Stimulation. The submission aims to establish substantial equivalence to a previously cleared predicate device (K183579), primarily focusing on an update to the device's Magnetic Resonance (MR) Conditional Labeling to include full body scans.

    Based on the provided text, there is no acceptance criteria table or specific study performance data for a device meeting acceptance criteria in the traditional sense of an AI/ML model for diagnostic or predictive purposes. This document is a regulatory submission for a physical medical device (implantable neurostimulator) and its associated external components and software, not an AI/ML diagnostic software. The "performance" discussed here relates to the safety and functionality of the device itself, particularly its compatibility with MRI, rather than the accuracy of a diagnostic algorithm.

    Therefore, many of the requested elements (e.g., sample size for test set, data provenance, number of experts for ground truth, adjudication method, MRMC study, standalone performance, training set details) are not applicable to this type of medical device submission.

    However, I can extract the relevant information regarding the device's "performance" as presented in the context of this 510(k) submission, specifically concerning the MRI compatibility, as this is the primary change necessitating the resubmission.


    Summary of Acceptance Criteria and Device (MRI) Performance:

    Since this is not an AI/ML diagnostic device, the "acceptance criteria" are not framed in terms of metrics like accuracy, sensitivity, or specificity. Instead, they are related to established safety standards for medical devices, particularly regarding MRI compatibility. The "device performance" refers to the results of testing performed to ensure these safety standards are met.

    1. Table of Acceptance Criteria and Reported Device Performance (Focusing on MRI Compatibility):

    Acceptance Criteria CategorySpecific Criteria (Implicitly based on standards)Reported Device Performance / Assessment
    Magnetic Resonance (MR) Safety and Compatibility for Full Body ScansConformance to MR Conditional Labeling for full body scans.Testing included in this submission demonstrates the safety and compatibility of the Nalu System for PNS in the Magnetic Resonance (MR) Environment for full body.
    Magnetically Induced Displacement ForceMeet limits defined in ASTM F2052-15Testing performed to standard.
    Magnetically Induced TorqueMeet limits defined in ASTM F2213-17Testing performed to standard.
    MR Image ArtifactsMeet limits defined in ASTM F2119-2013Testing performed to standard.
    Safety of Active Implantable Medical Device in MRIConformance to ISO/TS 10974Testing performed to standard.
    General Device Safety and PerformanceConformance to ISO 14708 (Parts 1 & 3)Testing performed to standard.
    Design ControlsAdherence to 21 CFR 820.30Nalu follows these procedures.
    Risk ManagementAdherence to ISO 14971Nalu follows these procedures.
    Quality Management SystemAdherence to ISO 13485:2016Nalu follows these procedures.
    BiocompatibilityDemonstrated through testing.Testing performed.
    SterilizationDemonstrated through testing.Testing performed.
    Human Factors and UsabilityDemonstrated through testing.Testing performed.
    Functional SpecificationDevice meets user needs.Validation and performance testing demonstrate this.
    Substantial EquivalenceIdentical indications for use, performance, and technological characteristics to predicate.Stated as "identical" and "no differences that would impact safety or effectiveness." The only noted difference is the updated MR Conditional Labeling, which is supported by new testing.

    2. Sample Size Used for the Test Set and the Data Provenance:

    • Sample Size: The document does not specify the sample sizes used for the engineering tests (e.g., number of devices tested for MRI compatibility, displacement, torque, or artifacts). These are typically bench tests on physical units, not clinical data sets.
    • Data Provenance: Not applicable in the context of clinical data. The tests are laboratory-based, non-clinical performance and bench testing.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:

    • Not Applicable. This is not a study assessing the performance of a diagnostic algorithm where expert ground truth is established for medical images. The "ground truth" for this device's performance relies on engineering measurements and adherence to international and national standards (e.g., ISO, ASTM) for device safety and functionality.

    4. Adjudication Method for the Test Set:

    • Not Applicable. As there are no human readers or diagnostic interpretations involved in the "test set" (which consists of physical device tests), no adjudication method is necessary.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    • No. This type of study is typically done for diagnostic imaging devices or AI tools that assist human readers. This submission is for an implantable neurostimulation system, not a diagnostic imaging or AI assistance tool.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    • Not Applicable. There is no "algorithm only" performance being evaluated in this submission in the context of diagnostic AI. The device's functionality (e.g., electrical stimulation parameters) and safety (e.g., MRI compatibility) are evaluated.

    7. The Type of Ground Truth Used:

    • The "ground truth" for the device's safety and performance is established through adherence to recognized international and national consensus standards (e.g., ISO/TS 10974, ISO 14708, ASTM F2052-15, ASTM F2213-17, ASTM F2119-2013) and engineering verification and validation testing. It is not based on expert consensus on medical image interpretations or clinical outcomes data in the context of diagnostic accuracy.

    8. The Sample Size for the Training Set:

    • Not Applicable. This is not an AI/ML device that requires a training set of data.

    9. How the Ground Truth for the Training Set was Established:

    • Not Applicable. (See point 8).
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    K Number
    K233162
    Manufacturer
    Date Cleared
    2024-06-20

    (267 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    K233162

    Trade/Device Name: Freedom Peripheral Nerve Stimulator (PNS) System Regulation Number: 21 CFR 882.5870
    |
    | Regulation Number: | 21 CFR 882.5870

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

    The Freedom Peripheral Nerve Stimulator (PNS) System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The Freedom Trial Lead Kit is only to be used in conjunction with the Freedom Neurostimulator Kit. The trial devices are solely used for a trial stimulation period (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Freedom PNS System uses HF-EMC (High Frequency Electromagnetic Coupling) neurostimulation technology to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The Freedom PNS System is comprised of a two-component implantable neurostimulator, an externallyworn transmitter, and WaveCrest software used to set patient-specific stimulation programs. The system's mechanism of action relies on programmable pulsed electrical current to create an energy field that acts on the targeted peripheral nerve to inhibit the transmission of pain signals to the brain. The two-component neurostimulator, comprised of an electrode array and a separate receiver, are surgically connected and anchored within two separate incisions, including creation of a subcutaneous pocket. The stimulation program is adjusted as needed to provide pain relief for the patient. The purpose of this submission is to modify the indications for use for the existing system (K171366) to include craniofacial applications.

    The Freedom PNS System is a single-use, prescription-only system, to be implanted by an appropriate clinician, such as a neurosurgeon, interventional pain physicial surgeon or orthopedic surgeon.

    AI/ML Overview

    The provided text describes the acceptance criteria and the study conducted for the Freedom Peripheral Nerve Stimulator (PNS) System (K233162) to support the expansion of its indications for use to include craniofacial applications.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    CriterionAcceptance CriteriaReported Device Performance
    Primary Effectiveness EndpointA statistically significant proportion of patients in the active treatment group demonstrate significant pain relief (at least 50% reduction) at 3 months compared to baseline, and this is superior to the deactivated control device.The study showed that "continued treatment with the subject device is superior to the deactivated control device in the proportion of patients with significant (at least 50%) pain relief at 3 months compared to baseline and, thus, the primary effectiveness endpoint was met."
    Primary Safety EndpointThe proportion of patients with serious adverse events by 3 months is less than 30%.The treatment with the subject device was shown to be safe, "passing the safety hypothesis test by demonstrating the proportion of patients with serious adverse events by 3 months was less than 30%." Specifically, "None of the 60 subjects who had implanted devices (Treatment or Control groups) had serious adverse events."
    Secondary EndpointsNot explicitly stated in the provided text, but mentioned as having been met."The study met its primary effectiveness, primary safety, and secondary endpoints."

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: 60 patients were implanted with the Freedom® PNS system. Of these, 58 completed the 7-day confirmation visit. 56 of these 58 responders were randomized to either the Active (Treatment group) or Deactivated (Control group).
      • Treatment/Active group: 28 patients
      • Control/Deactivated group: 28 patients
    • Data Provenance: The study was a "multi-center randomized clinical trial." The country of origin is not specified in the provided text, but "clinical data" and "multi-center randomized clinical trial" imply prospective data collection in a clinical setting.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    The study described is a clinical trial assessing the effectiveness of a pain management device. The "ground truth" for effectiveness in this context is self-reported pain relief from the patients themselves, and safety is determined by the occurrence of serious adverse events. Therefore, there's no mention of a traditional expert panel establishing "ground truth" in the same way it would be for, say, image interpretation. The efficacy is based on patient outcomes as measured against the specified endpoints.

    4. Adjudication Method for the Test Set

    Not applicable in the context of this clinical trial for device effectiveness and safety endpoints. The assessment of pain relief and adverse events would typically follow pre-defined clinical protocols and criteria.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, an MRMC comparative effectiveness study was not done. This study is a randomized controlled trial comparing the device's effectiveness (active stimulation) against a control (deactivated device) in patients.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done

    Not applicable. The Freedom PNS System is a physical implanted medical device that requires human implantation and patient interaction (wearing an external transmitter) to function. Its "performance" is assessed through clinical outcomes in patients, not as a standalone algorithm.

    7. The Type of Ground Truth Used

    The ground truth for effectiveness was established by patient-reported pain relief (at least 50% reduction compared to baseline). The ground truth for safety was established by the occurrence of serious adverse events.

    8. The Sample Size for the Training Set

    Not applicable. This is a clinical trial for device approval/expanded indication, not an AI/ML algorithm development where data sets are typically split into training and test sets in that manner. The described study is the clinical evidence used to support the device's efficacy and safety for its intended use.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable, as there isn't a "training set" in the context of an AI/ML algorithm. The clinical data from the trial serves as the evidence for the device's performance.

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    K Number
    K221303
    Date Cleared
    2023-04-11

    (341 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    , California 95134

    Re: K221303

    Trade/Device Name: Neuspera Nuity System Regulation Number: 21 CFR 882.5870
    Product Code: GZF (Stimulator, peripheral nerve, implanted (Pain Relief) Regulation number: 21 CFR 882.5870
    |
    | Regulation number | 21 CFR §882.5870

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

    The Neuspera Nuity™ System (NNS) is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The Neuspera Nuity™ System (NNS) is also used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) implant.

    Device Description

    The Neuspera Nuity™ System is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The System consists of an implantable pulse generator (IPG), electrode array, surgical implant tools, wireless worn transmitter, clinician programmer, a patient controller, and undergarments. The implantable pulse generator is a miniature implanted neurostimulator, powered by an externally worn wireless transmitter device which contains a rechargeable battery.

    Same as the predicate, the Neuspera Nuity™ System utilizes pulsed electrical current to create an energy field that acts on the targeted nerve to inhibit the transmission of pain signals to the brain. The Neuspera Nuity™ System may also be used during the trial period before recommendation for permanent implant.

    The Neuspera Nuity™ System (NNS) is comprised of the following components: Neuspera Implanted Pulse Generator (IPG) Or Neuspera Implanted Microstimulator, Electrode Array, Surgical/Implant Tools, Externally Worn Wireless Transmitter, Clinician Programmer and Patient Controller.

    AI/ML Overview

    The provided text does not contain a study that proves the device meets specific acceptance criteria in terms of performance metrics like sensitivity, specificity, accuracy, or any other quantifiable measure. Instead, the document is an FDA 510(k) clearance letter and summary, primarily focusing on demonstrating substantial equivalence to a predicate device based on intended use, technological characteristics, and safety aspects.

    Therefore, many of the requested categories cannot be filled as they would relate to a clinical or performance study of the device's diagnostic or therapeutic effectiveness, which is not detailed in this document. The information provided is mainly related to bench testing, engineering comparisons, and biocompatibility.

    Here's an analysis of the requested information based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state acceptance criteria for performance metrics (e.g., pain reduction scores, successful stimulation rates) nor does it provide a clinical study to report on these. The closest information available is a comparison of technological characteristics to a predicate and reference device, implying that meeting or being comparable to these characteristics is a form of acceptance.

    Acceptance Criterion (Implicit)Reported Device Performance (from Tables 1, 2, 3)
    Intended UseSubject Device (Neuspera Nuity™ System): Stimulation of peripheral nerves for chronic, intractable pain. Also for trial stimulation (no longer than 30 days).
    Predicate Device (Neuspera Neurostimulation System K202781): Same.
    Reference Device (Nalu Neurostimulation System K183579): Same.
    Analysis: Same. Differences in wording do not affect safety and effectiveness of intended use.
    Product Code & ClassSubject Device: GZF, Class II
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Regulation NumberSubject Device: 21 CFR §882.5870
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Classification NameSubject Device: Implanted peripheral nerve stimulator for pain relief
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Prescription Use?Subject Device: Yes
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Implant SiteSubject Device: Adjacent to nerves peripheral to central nervous system, excluding craniofacial region.
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Environmental UseSubject Device: Hospital, Home
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Intended ClinicianSubject Device: Orthopedic, Neurosurgeon, Anesthesiologist
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Intended UserSubject Device: Physician, Layperson
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Mode of ActionSubject Device: RF wireless transmission of energy to charge implanted energy source with stimulation pulse generator to produce stimulation at stimulator electrodes.
    Predicate Device: Same
    Reference Device: RF wireless transmission of energy to produce stimulation at stimulator electrodes. (Note: Reference device description is slightly different from subject/predicate in that it omits "implanted energy source with stimulation pulse generator")
    Analysis: Same as K202781
    Software Level of ConcernSubject Device: Moderate
    Predicate Device: Moderate
    Reference Device: Moderate
    Analysis: Same
    Dimensions (IPG, Electrode Array)Subject Device: IPG: 2.33 mm diameter, electrode array 1.3 mm diameter, 4.5-5.2 cm total length. Subject devices consist of 2 lengths (30mm and 35mm electrode array lengths).
    Predicate Device: IPG: 2.33 mm diameter, electrode array 1.3 mm diameter, 5.1 cm total length. Predicate electrode array length is 34mm.
    Reference Device: Lead = 1.30 mm diameter, 40 or 60 cm length, IPG = 28 x 11 x 4.9 mm.
    Analysis: Differences in electrode array lengths are negligible as therapy output remains the same between subject and predicate devices.
    ConfigurationSubject Device: Implanted antenna receiver, energy storage capacitor, stimulation pulse generator coupled with electrode arrays.
    Predicate Device: Same.
    Reference Device: Embedded receiver, flexible circuit board.
    Analysis: Same as K202781
    Electrical ComponentsSubject Device: Embedded receiver, flexible circuit board with energy storage and stimulation pulse generator.
    Predicate Device: Same.
    Reference Device: Same.
    Analysis: Same
    Power DeliverySubject Device: Radio frequency transmission receiver.
    Predicate Device: Same.
    Reference Device: Coupled receiver radio frequency transmission.
    Analysis: Same as K202781
    Electrode MaterialSubject Device: Platinum-iridium 90:10
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Insulation Body MaterialSubject Device: Pellethane 2363-55D
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Electrode Array DiameterSubject Device: 1.30 mm
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Electrode Array LengthSubject Device: 21 mm (Measured Start of First to End of Last Electrode)
    Predicate Device: Same
    Reference Device: 52 mm
    Analysis: Same as K202781
    No. of Electrodes per arraySubject Device: 4
    Predicate Device: Same
    Reference Device: 8
    Analysis: Same as K202781
    Individual Electrode LengthSubject Device: 3 mm
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Electrode Surface AreaSubject Device: 12.25 mm²
    Predicate Device: Same
    Reference Device: 12.25 mm³ (likely a typo, should be mm²)
    Analysis: Same
    SterilizationSubject Device: Ethylene Oxide
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Pulse FrequencySubject Device: 2 to 1500 Hz
    Predicate Device: 4 to 130 Hz
    Reference Device: 2 to 1500 Hz
    Analysis: Neuspera Nuity pulse frequency range covers predicate device and is within range of reference device. Therefore, differences do not affect safety and effectiveness.
    Pulse WidthSubject Device: 15 to 960 µs
    Predicate Device: 105 to 960 µs
    Reference Device: 12 to 1000 µs
    Analysis: Neuspera Nuity pulse width range covers predicate device and is within range of reference device. Therefore, differences do not affect safety and effectiveness.
    Current/Voltage RegulatedSubject Device: Voltage or Current
    Predicate Device: Voltage
    Reference Device: Current
    Analysis: Adjustable between regulation mode of both predicate and reference devices. Therefore, differences do not affect safety and effectiveness.
    Output CurrentSubject Device: (300 Ohms) 0 to 5.73 mA*, (500 Ohms) 0 to 5.44 mA*, (800 Ohms) 0 to 5.20 mA*
    Predicate Device: Same
    Reference Device: (all) 0 to 10.2 mA
    Analysis: Same as K202781 (*measured with typical therapy pulse width of 240us)
    WaveformSubject Device: Charge balanced (delayed) biphasic asymmetrical
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Pulse ShapeSubject Device: Decaying Exponential
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Maximum Phase ChargeSubject Device: (300 Ohms) 2.88 µC/pulse**, (500 Ohms) 2.74 µC/pulse**, (800 Ohms) 2.43 µC/pulse**
    Predicate Device: Same
    Reference Device: (300 Ohms) 6.8 µC/pulse, (500 Ohms) 6.4 µC/pulse, (800 Ohms) 4.7 µC/pulse
    Analysis: Same as K202781 (**measured with maximum pulse width of 960us)
    Maximum Charge DensitySubject Device: (300 Ohm) 23.5 µC/cm2**, (500 Ohm) 22.4 µC/cm2**, (800 Ohm) 19.8 µC/cm2**
    Predicate Device: Same
    Reference Device: (300 Ohm) 53.1 µC/cm², (500 Ohm) 50.3 µC/cm², (800 Ohm) 15.9 µC/cm2***
    Analysis: Same as K202781
    Maximum Current DensitySubject Device: (300 Ohm) 46.8 mA/cm2*, (500 Ohm) 44.4 mA/cm2*, (800 Ohm) 42.4 mA/cm2*
    Predicate Device: Same
    Reference Device: (all) 26.5 mA/cm2***
    Analysis: Same as K202781
    Net ChargeSubject Device: 0 µC
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Pulse Delivery ModeSubject Device: Continuous
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Current Path OptionsSubject Device: Bipolar
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Program CycleSubject Device: Cycle through programs
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Pulse PatternSubject Device: Fine tuning of pulse patterns
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    Dosage TimeSubject Device: Cycling ON/OFF 1 second-1 day
    Predicate Device: Same
    Reference Device: Same
    Analysis: Same
    BiocompatibilitySubject Device: Complies with ISO 10993-1:2018 for long-term implant (>30 days) and limited duration tissue contact (
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    K Number
    K221376
    Manufacturer
    Date Cleared
    2022-06-10

    (29 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    |
    | Classification Regulation | 21 CFR 882.5870
    Number | 21 CFR 882.5880 (GZB)
    21 CFR 882.5870
    | 21 CFR 882.5880 (GZB)
    21 CFR 882.5870
    Regulation
    Number | 21 CFR 882.5880
    (GZB)
    21 CFR 882.5870
    | 21 CFR 882.5880
    (GZB)
    21 CFR 882.5870

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

    Spinal Cord Stimulation (SCS)

    This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Peripheral Nerve Stimulation (PNS)

    This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System has been cleared by the FDA for spinal cord stimulation (SCS; K203547) and peripheral nerve stimulation (PNS; K203547) to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral, bilateral nerve pain. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord or peripheral nerve to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system.

    The Nalu Neurostimulation System consists of five (5) components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site. The leads are implantable and designed to deliver electrical pulses to the nerves via an array of four (4) or eight (8) cylindrical electrodes at the distal end. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for Spinal Cord Stimulation (SCS) or Peripheral Nerve Stimulation (PNS) is performed via standard surgical tools and techniques, as described in (K203547).

    AI/ML Overview

    This looks like a 510(k) summary, which typically focuses on demonstrating substantial equivalence to a predicate device rather than presenting a standalone study with specific acceptance criteria and performance metrics for a novel AI device. The document mostly highlights the similarities between the subject device (K221376) and its predicate (K203547).

    Based on the provided text, there is no specific AI component or algorithm mentioned, nor are there acceptance criteria or a study described to demonstrate the performance of such a component. The device is a "Nalu Neurostimulation System" which appears to be a hardware device for spinal cord and peripheral nerve stimulation. The changes referenced are related to "Clinician Programmer" software differences for therapy configuration, rather than an AI/ML algorithm that interprets data or makes diagnostic decisions.

    Therefore, most of the questions you've asked about acceptance criteria, study details, ground truth, sample sizes, and involvement of experts/AI effectiveness are not applicable to this submission as it doesn't describe an AI/ML device in the context of the typical information provided if it were an AI/ML device.

    Here's an attempt to answer your questions based only on the provided text, highlighting where the information is absent because the device does not appear to be an AI/ML product as you seem to be assuming:


    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state acceptance criteria in the form of performance metrics (e.g., sensitivity, specificity, AUC) that would be expected for an AI device. Instead, it demonstrates an acceptance of "substantial equivalence" to a predicate device by showing that the technological characteristics and indications for use are the same, and that non-clinical testing confirms safety and performance within established limits.

    The tables (Table 1, Table 2, Table 3) provided in the document compare the technological characteristics and therapeutic parameters of the subject device (K221376) and its predicate device (K203547). The "reported device performance" in this context is that these characteristics are "Same as predicate" or that any differences "do not impact the safety and effectiveness of the device."

    Table of Acceptance Criteria and Reported Device Performance (as inferred from the document):

    Acceptance Criteria CategorySpecific Criteria (Implicitly Met by Predicate Equivalence)Reported Device Performance (Subject Device K221376)
    Product Code and ClassGZB and GZF, Class II (for SCS and PNS)Same as predicate (K203547)
    Regulation Number21 CFR 882.5880 (GZB), 21 CFR 882.5870 (GZF)Same as predicate (K203547)
    Classification NameImplanted spinal cord stimulator for pain relief / Implanted peripheral nerve stimulator for pain reliefSame as predicate (K203547)
    Trade NameNalu Neuromodulation SystemSame as predicate (K203547)
    ManufacturerNalu Medical, Inc.Same as predicate (K203547)
    Intended UseStimulation of spinal cord/peripheral nerves for chronic intractable painSame as predicate (K203547)
    Indications for UseFor chronic, intractable pain of the trunk and/or limbs (SCS); For severe intractable chronic pain of peripheral nerve origin (PNS)Same as predicate (K203547)
    Clinical ApplicationTreatment of chronic, intractable painSame as predicate (K203547)
    Prescription UseYesSame as predicate (K203547)
    Environmental UseHospital, HomeSame as predicate (K203547)
    Intended ClinicianOrthopedic, Neurosurgeon, AnesthesiologistSame as predicate (K203547)
    Intended UserPhysician, LaypersonSame as predicate (K203547)
    Implant Site, LeadsEpidural space (SCS) or peripheral nerve areas (PNS)Same as predicate (K203547)
    Principle of OperationStimulation of spinal cord/peripheral nerve to provide therapeutic reliefSame as predicate (K203547)
    Mode of ActionRF wireless transmission of energy to deliver stimulationSame as predicate (K203547)
    Software Level of ConcernModerateSame as predicate (K203547)
    Therapeutic Electrical Parameters (e.g., Pulse Frequency, Pulse Width, Current, Voltage, Waveform, Charge/Current Density, Net Charge, Power, Pulse Delivery Mode, etc.)Within specified ranges and identical to predicateSame as predicate (K203547)
    Clinician Programmer SoftwareSoftware to communicate to Trial Therapy or Therapy Disc; Manual control of current and optional model-based allocation; Safety parameters (charge per phase, charge density, current density) unchanged and within limits.Differences do not impact safety and effectiveness. New method is an option for faster programming, with patient feedback for effectiveness.
    Patient Remote Control SoftwareSoftware to pair with Trial Therapy or Therapy Disc; SW update to reflect Clinician Programmer changesNo impact on safety or effectiveness (implied by lack of further analysis).
    Externally Worn Devices FirmwareFirmware update to reflect Clinician Programmer and Remote Control changesNo impact on safety or effectiveness (implied by lack of further analysis).
    LabelingUpdated to support Clinical Programmer Current Steering optionsDifferences to labeling do not impact safety and effectiveness.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    Not applicable. The document states, "Nalu Medical determined that bench and non-clinical testing are sufficient to demonstrate that the Nalu Neurostimulation system is as safe and effective as the predicate device." No clinical data (which might involve a test set, sample size, or patient data provenance) was required or submitted for this 510(k) submission, as the device's substantial equivalence was established through non-clinical testing and comparison to the predicate.

    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)

    Not applicable. As no clinical study or test set for an AI/ML algorithm was conducted/submitted, there was no need for experts to establish ground truth. The device is a neurostimulation system, not an AI diagnostic or interpretive tool.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. No test set requiring adjudication was used.

    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 not an AI-assisted diagnostic or interpretive tool, and no MRMC study was performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This device is not an AI algorithm. Its functionality involves hardware for neurostimulation, with software controlling the programming and delivery of stimulation.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    Not applicable. Ground truth for an AI algorithm is not relevant here as the device is not an AI/ML product. The "ground truth" for this submission is implicitly the established safety and effectiveness of the predicate device, validated through non-clinical engineering and performance testing.

    8. The sample size for the training set

    Not applicable. No AI/ML model training was described or performed for this device.

    9. How the ground truth for the training set was established

    Not applicable. As no training set for an AI/ML model was used, no ground truth needed to be established for it.

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    K Number
    K211965
    Manufacturer
    Date Cleared
    2022-02-23

    (244 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    91355

    Re: K211965

    Trade/Device Name: StimRouter Neuromodulation System Regulation Number: 21 CFR 882.5870
    |
    | | Regulation Number: | 21 CFR §882.5870

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

    The StimRouter Neuromodulation System is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as an adjunct to other modes of therapy (e.g., medications). The StimRouter is not intended to treat pain in the craniofacial region.

    Device Description

    The StimRouter Neuromodulation System consists of two main parts - the implantable lead, and the external (to the body) accessories for the StimRouter include a clinician programmer with software (CPS), a disposable hydrogel electrode patch, an external pulse transmitter, an external pulse transmitter stimulation tester and a device used by the patient to wirelessly control the external pulse transmitter. The StimRouter Neuromodulation System is provided with three labeling documents: the Clinician's Guide, the Procedure Manual and the User's Guide. The complete StimRouter System consists of three kits: a Lead and Lead Introducer Kit, a Clinician Kit and User Kit. The Lead Kit contains the StimRouter implantable multielectrode lead with integrated receiver, used for peripheral nerve stimulation. The Lead receives an electrical signal transmitted transcutaneously by the external pulse transmitter which is mounted on an electrode patch on the skin and delivers that electrical signal down the lead's length to a target peripheral nerve. The Lead is supplied in Lead Loader that is used during intraoperative testing of the lead and to verify proper placement during implantation. The Lead and Lead Introducer Kit consists of two stimulation probes, two stimulation cables, and introducer set, a lead adapter, a Tunneling Needle, and a Tunneling Needle Stylet. The included tools and components allow for insertion of the StimRouter Lead and confirmation of optimal location of the stimulation electrode contacts of the StimRouter Lead. The Clinician Kit is used for the programming of the external pulse transmitter. The components of the Clinician Kit are a tablet PC with programming software that is capable of connecting to and configuring the external pulse transmitter. The User Kit contains the patient-use components of the StimRouter System. The components are the External Electric Field Conductor (E-EFC), an external pulse transmitter, with included charger and the StimRouter Electrode Carrying Case. After the E-EFC is programmed, the E-EFC can be connected to the StimRouter Electrode through which it can deliver stimulation transcutaneously to the implanted lead receiver.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the StimRouter Neuromodulation System, arguing for its substantial equivalence to a previously cleared predicate device (K200482). The submission primarily focuses on comparing the technological characteristics of the new device (modified StimRouter) with the predicate, rather than presenting a study with specific acceptance criteria and performance data for a standalone algorithmic device.

    Therefore, many of the requested details about acceptance criteria, specific device performance metrics, sample sizes for test/training sets, ground truth establishment, and multi-reader multi-case studies are not available in the provided document. The document describes a comparison study, not a standalone performance study as would be typical for an AI/ML device.

    Here's a breakdown of what can be extracted and what is missing:


    1. Table of Acceptance Criteria and Reported Device Performance

    This information is not provided in the document as specific numerical acceptance criteria and corresponding reported device performance for an algorithm's classification or prediction capabilities. The document describes a comparison of technical characteristics between the modified StimRouter and its predicate, rather than reporting performance against predefined acceptance criteria.

    The "Equivalency Assessment" column in the table on pages 5-6 indicates similarity to the predicate and states that differences do not affect safety and effectiveness of intended use. For example:

    • EWD Electrical Signal Transmitter: "Similar. The E-EFC circuitry is functionally equivalent to the EPT circuitry. The differences do not affect safety and effectiveness of intended use."
    • EWD Phase Duration: "The reduction in number of positive phase duration values (due to a simplified code base) does not affect safety and effectiveness of the intended use because minor adjustments can be made to other parameters to create therapeutic programs equivalent to those provided by the EPT."
    • EWD Max Compliance Voltage: The E-EFC's maximum compliance voltage increased to 130V from the predicate's 100V. The assessment states: "This difference in hardware does not affect safety and effectiveness of the intended use."

    2. Sample size used for the test set and the data provenance

    Not applicable/Not provided. This document does not describe a study involving a test set of data for evaluating an AI/ML algorithm's performance. The "performance testing" mentioned on page 15 refers to electrical compatibility, wireless coexistence, biocompatibility, shipping, storage, shelf life, functional verification, usability, and software verification/validation—these are not related to a data-driven performance evaluation with a test set in the context of AI.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable/Not provided. As there is no described test set or ground truth establishment in the context of an AI/ML algorithm's performance, this information is not present.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable/Not provided.

    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/Not provided. This submission is for a neuromodulation system, not an AI/ML diagnostic or assistive device that would involve human readers.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    Not applicable/Not provided. The device described is a physical neuromodulation system, not a standalone algorithm. The software components are for controlling the device (CPS, MAPP app) and are evaluated through software verification and validation, not standalone diagnostic performance.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    Not applicable/Not provided.

    8. The sample size for the training set

    Not applicable/Not provided. No AI/ML training is described.

    9. How the ground truth for the training set was established

    Not applicable/Not provided.


    Summary of the Study Performed (as described in the document):

    The "study" described in the 510(k) submission is a comparison of technological characteristics and performance testing to demonstrate substantial equivalence to a predicate device (StimRouter Neuromodulation System cleared in K200482).

    The core of the submission (pages 5-6) is a detailed table comparing the "Subject Device (Modified StimRouter)" to the "Predicate (StimRouter cleared in K200482)" across numerous technical attributes, including:

    • Manufacturer, 510(k) number, Intended use (all identical)
    • Implantable Lead and Lead Introducer Kit components (packaging, lead characteristics, introduction method, tools) - indicated as "No changes" or "Same"
    • User Kit accessories (External Electrical Field Conductor (E-EFC) vs. External Pulse Transmitter (EPT), MAPP Smartphone Application vs. Patient Programmer)
    • Clinician Kit accessories (Modified Clinician's Programming Software (CPS) vs. original CPS)

    The "Equivalency Assessment" column justifies why any differences (e.g., changes in electronics, wireless protocol, charging port, integrated controls, maximum compliance voltage, or phase duration values) do not affect the safety and effectiveness of the intended use, arguing that similar functionality is maintained or improved.

    Performance Testing Mentioned (page 15):

    The document lists "Performance Testing" categories that the StimRouter Neuromodulation System was qualified through:

    • Electrical compatibility and safety
    • Wireless coexistence
    • Biocompatibility Testing
    • Shipping and storage
    • Shelf life
    • Functional Verification
    • Usability
    • Software Verification and Validation Testing

    These tests are standard for medical devices and demonstrate the device's adherence to relevant standards and its functional capabilities, rather than an AI/ML algorithm's data-driven performance. The document concludes that based on these comparisons and performance tests, the modified StimRouter is substantially equivalent to its predicate and does not raise new safety or effectiveness concerns.

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    K Number
    K202781
    Date Cleared
    2021-08-27

    (339 days)

    Product Code
    Regulation Number
    882.5870
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    95134

    Re: K202781

    Trade/Device Name: Neuspera Neurostimulation System (NNS) Regulation Number: 21 CFR 882.5870
    System Common/Usual Name: Neuspera Neurostimulation System Product Code: GZF Requlation number: 21 CFR 882.5870
    | |
    | Regulation number | 21 CFR §882.5870

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

    The Neuspera Neurostimulation System (NNS) is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region.

    The Neuspera Neurostimulation System (NNS) is also used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) implant.

    Device Description

    The Neuspera Neurostimulation System is used for peripheral nerve stimulation to provide therapeutic relief for chronic, intractable pain of peripheral nerve origin. The System consists of an implantable pulse generator (IPG), electrode array, surgical implant tools, wireless worn transmitter, clinician programmer and a patient controller. The implantable pulse generator is a miniature implanted neurostimulator, powered by an externally worn wireless transmitter device which contains a rechargeable battery.

    AI/ML Overview

    The provided text is a 510(k) summary for the Neuspera Neurostimulation System (NNS). It details the device's indications for use, its components, and a comparison to predicate devices, focusing on technological characteristics. However, this document describes a neurostimulation system for pain management, NOT an AI/ML medical device for image analysis or diagnosis.

    Therefore, the information required to answer your prompt, which is specifically related to acceptance criteria and studies for AI/ML device performance (e.g., accuracy, sensitivity, specificity, expert ground truth, MRMC studies), is not present in this 510(k) summary. The summary focuses on hardware specifications, electrical properties, biocompatibility, and animal studies for an implantable medical device, and explicitly states "Clinical evaluation is not required".

    To directly address your request, if this were an AI/ML device submission, here's what the answer would look like (hypothetically, based on typical AI/ML medical device FDA submissions):

    Hypothetical Response (if this were an AI/ML device, assuming typical FDA AI/ML study requirements):

    This 510(k) summary does not appear to be for an AI/ML medical device that requires clinical performance studies based on human reader performance or algorithm-only metrics. The device, Neuspera Neurostimulation System (NNS), is an implanted peripheral nerve stimulator for pain relief. The provided documentation focuses on engineering specifications, biocompatibility, and non-clinical testing (functional, performance, MRI testing, animal studies) to demonstrate substantial equivalence to a predicate device.

    The summary explicitly states: "Clinical evaluation is not required for the Neuspera Neurostimulation System as the indications for use are equivalent to the legally marketed predicate device and referenced device. These types of devices, including versions of the legally marketed predicate device, have been on the market for many years with a proven safety and efficacy for the use of the device. Therefore, Neuspera determined that bench and non-clinical testing are sufficient to demonstrate that the Neuspera Neurostimulation System is as safe and effective as the predicate device."

    Therefore, the requested information regarding acceptance criteria, performance metrics (like sensitivity, specificity), data provenance, expert ground truth establishment, adjudication methods, MRMC studies, or standalone algorithm performance, which are typical for AI/ML diagnostic or prognostic devices, is not applicable or available in this specific 510(k) submission for the Neuspera Neurostimulation System.

    If this were an AI/ML device submission, the following sections would be populated (but cannot be from the provided text):

    1. Table of acceptance criteria and reported device performance:
      (Hypothetical example for an AI/ML device)
    MetricAcceptance CriteriaReported Device Performance
    Sensitivity≥ 90%92.5%
    Specificity≥ 80%85.1%
    AUC (ROC)≥ 0.900.93
    PPV≥ 75%78.2%
    NPV≥ 95%96.8%
    1. Sample size used for the test set and the data provenance:
      (Hypothetical example for an AI/ML device)

      • Test Set Sample Size: E.g., 500 cases (e.g., medical images).
      • Data Provenance: Retrospective, collected from multiple institutions across the United States, Europe, and Asia.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
      (Hypothetical example for an AI/ML device)

      • Number of Experts: E.g., 3 independent board-certified radiologists.
      • Qualifications: Each radiologist had a minimum of 10 years of experience specializing in (e.g., thoracic imaging) and were blinded to the device's output.
    3. Adjudication method for the test set:
      (Hypothetical example for an AI/ML device)

      • Adjudication Method: 2+1; if two initial readers disagreed, a third senior expert (adjudicator) reviewed the case to establish the final ground truth.
    4. If a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was done:
      (Hypothetical example for an AI/ML device)

      • MRMC Study: Yes, an MRMC study was conducted comparing human reader performance with and without AI assistance.
      • Effect Size: Human readers demonstrated a statistically significant improvement in diagnostic accuracy (e.g., 15% increase in AUC) when assisted by the AI device compared to unassisted reading. The sensitivity increased by X% and specificity by Y%.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
      (Hypothetical example for an AI/ML device)

      • Standalone Performance: Yes, standalone performance was evaluated on the test set. The algorithm achieved a sensitivity of 92.5% and a specificity of 85.1%.
    6. The type of ground truth used:
      (Hypothetical example for an AI/ML device)

      • Ground Truth Type: Expert consensus (from the expert radiologists) reviewed against relevant clinical outcomes data (e.g., biopsy results, surgical pathology, or patient follow-up data for disease progression/regression).
    7. The sample size for the training set:
      (Hypothetical example for an AI/ML device)

      • Training Set Sample Size: E.g., 10,000 cases.
    8. How the ground truth for the training set was established:
      (Hypothetical example for an AI/ML device)

      • Training Set Ground Truth: Established by a combination of clinical reports, a subset reviewed by a single board-certified radiologist, and confirmed with pathology results or long-term patient follow-up where available. Automated methods (e.g., natural language processing of reports) were also used for initial labeling, with a portion of cases undergoing expert review for quality control.
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    K Number
    K203547
    Manufacturer
    Date Cleared
    2021-03-25

    (111 days)

    Product Code
    Regulation Number
    882.5880
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    |
    | Classification Regulation | 21 CFR 882.5870
    |
    | Regulation
    number | 21 CFR 882.5880
    (GZB)
    21 CFR 882.5870
    | 21 CFR 882.5880
    (GZB)
    21 CFR 882.5870
    GZF) | 21 CFR 882.5880
    (GZB)
    21 CFR 882.5870

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

    For Spinal Cord Stimulation: This system is indicated as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach for chronic, intractable pain of the trunk and/or limbs, including unilateral or bilateral pain. The trial devices are solely used for trial stimulation (no longer than 30 days) to determine efficacy before recommendation for a permanent (long term) device.

    For Peripheral Nerve Stimulation: This system is indicated for pain management in adults who have severe intractable chronic pain of peripheral nerve origin, as the sole mitigating agent, or as an adjunct to other modes of therapy used in a multidisciplinary approach. The system is not intended to treat pain in the craniofacial region. The trial devices are solely used for trial stimulation (no longer than 30 day) to determine efficacy before recommendation for a permanent (long term) device.

    Device Description

    The Nalu Neurostimulation System has been cleared by the FDA for spinal cord stimulation, and peripheral nerve stimulation (K201618), to provide therapeutic relief for chronic, intractable pain of the trunk and/or limbs including unilateral, bilateral nerve pain. The Nalu Neurostimulation therapy utilizes pulsed electrical current to create an energy field that acts on nerves in the spinal cord or peripheral nerve to inhibit the transmission of pain signals to the brain. The Nalu System is implanted only following a successful trial period using the Nalu Neurostimulation trial system. The Nalu Neurostimulation System consists of several components. The implantable pulse generator (IPG) provides electrical stimulation pulses that are transmitted through the leads, to the desired location, either on the spinal cord or peripheral nerve site. The leads are implantable and designed to deliver electrical pulses to the nerves via an array of four or eight cylindrical electrodes at the distal end. The Trial Therapy Disc or the Therapy Disc houses the battery and electronics for RF power and controls the IPG for therapy delivery via the remote programmer. Implantation of the Nalu IPG and lead components for spinal cord stimulation (SCS) or peripheral nerve stimulation (PNS) is performed via standard surgical tools and techniques, as described in (K201618).

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a table of acceptance criteria or performance metrics in the way one might expect for a diagnostic or AI-based device's clinical performance. Instead, the submission describes the Nalu Neurostimulation System and its substantial equivalence to predicate devices, focusing on technical specifications and safety rather than a measurable clinical outcome in a performance study.

    The closest to "acceptance criteria" are the parameters defining the device's operational range, and the "reported device performance" is that these parameters are within acceptable limits compared to predicate devices, demonstrating substantial equivalence.

    Acceptance Criteria (Implied)Reported Device Performance
    Pulse Width RangeSubject Device: 12 to 2000 µs (Predicate: 12 to 1000 µs; Reference: 50 to 1000 µs) - Analysis: Available programmable pulse width will be capped to maintain Maximum Phase Charge and Maximum Charge Density within limits of Medtronic Xtrel reference device limit. No impact to safety and effectiveness.
    Maximum Phase Charge (300 Ohms)Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 18.0 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device.
    Maximum Phase Charge (500 Ohms)Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 14.2 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness.
    Maximum Phase Charge (800 Ohms)Subject Device: 18.0 µC/pulse (Predicate: 10.2 µC/pulse; Reference: 10.5 µC/pulse) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness.
    Maximum Charge Density (300 Ohm)Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 150.0 µC/cm²) - Analysis: Within maximum limit as set by Medtronic Xtrel reference device.
    Maximum Charge Density (500 Ohm)Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 118.3 µC/cm²) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness.
    Maximum Charge Density (800 Ohm)Subject Device: 146.94 µC/cm² (Predicate: 83.3 µC/cm²; Reference: 87.5 µC/cm²) - Analysis: Same as Medtronic Xtrel reference device at 300 Ohms. Maximum Phase Charge constant in current controlled system and enforced below maximum reference device value (at 300 Ohms). No impact to safety and effectiveness.
    Dosage Time RangeSubject Device: On spans 1 ms to 1000 ms, Off spans 1 ms to 2000 ms (Predicate: On spans 1 ms to 25 ms) - Analysis: This parameter has no impact on safety and effectiveness. Increasing the range allows the clinician to offer more flexibility to accommodate patient preferences.
    All other parameters (Frequency, Current/Voltage Regulated, Output Voltage/Current, Waveform, Pulse Shape, Maximum Current Density, Net Charge, Average Phase Power/Density, Pulse Delivery Mode, Current Path Options, Program Cycle, Pulse Pattern, Daily Therapy Time, Transmit Frequency)All "Same as predicate." or "Same as predicate/reference." indicating compliance with established safe and effective parameters.

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not describe a clinical performance study with a "test set" from real patient data in the context of an AI/diagnostic device. Instead, it refers to "testing" performed to support the safety and performance of the device. This testing appears to be primarily non-clinical (bench/laboratory) testing of electrical and software parameters.

    Therefore, there is no mention of a sample size for a test set of patient data, nor data provenance (country of origin, retrospective/prospective).

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    This information is not applicable and not provided. The study focuses on evaluating technical parameters against established medical device safety standards and comparison to predicate devices, not on a ground truth established by medical experts for diagnostic accuracy.

    4. Adjudication Method

    This information is not applicable and not provided, as the submission does not involve expert review or adjudication of clinical cases for diagnostic or performance accuracy.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

    No, an MRMC comparative effectiveness study was not done. This device is a neurostimulation system for pain relief, not a diagnostic imaging or AI-assisted diagnostic tool that would typically undergo MRMC studies to assess human reader improvement. The submission focuses on demonstrating substantial equivalence in technical characteristics and safety.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done

    This concept is not directly applicable. The "device" itself (Nalu Neurostimulation System) is a therapeutic electrical stimulator. The "software" changes described are modifications to its operational parameters. The performance testing referenced is likely to evaluate the hardware and software functionality as an integrated system, ensuring it operates within safe and effective limits. There isn't an "algorithm only" component in the sense of an AI interpreting inputs to provide diagnostic outputs.

    7. The type of ground truth used

    The "ground truth" for this submission appears to be regulatory and engineering standards, and the specifications and performance characteristics of legally marketed predicate and reference devices. The evaluation focuses on whether the subject device's technical specifications and functionality (particularly the updated software parameters) fall within the established safe and effective ranges of these comparable devices.

    8. The sample size for the training set

    This information is not applicable and not provided. The device is not an AI/ML model that would train on a dataset. The software changes are operational programming changes for the neurostimulator.

    9. How the ground truth for the training set was established

    This information is not applicable and not provided, as there is no "training set" for an AI/ML model.

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