MOBILECARE MONITOR, MODEL 2100

K090138 · Aframe Digital, Inc. · KMI · Apr 24, 2009 · General Hospital

Device Facts

• Record ID: K090138
• Device Name: MOBILECARE MONITOR, MODEL 2100
• Applicant: Aframe Digital, Inc.
• Product Code: KMI · General Hospital
• Decision Date: Apr 24, 2009
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 880.2400
• Device Class: Class 1

Intended Use

The MobileCare™ Monitor 2100 system includes a MyPHD™ personal help device that is intended to monitor residents in home and long-term care facilities including independent living, assisted living and rehabilitation settings. The monitor can be placed on the wrist using the Velcro strap and used like a watch by the resident. The other form of MyPHD offered has no wrist straps so it can be clipped to the waist or used in a bandage for attachment at other locations on the person as may be appropriate or preferred by the user or healthcare provider. The system provides an alert to designated caregivers or professional staff automatically at pre-set thresholds to indicate an impact has occurred. The system also includes an emergency (panic) button that can be pressed by the monitored individual to alert caregivers as needed. The users of the system include staff and residents. The product is intended to be used on a 24-hour basis. The system is not intended to provide automated treatment decisions, nor is it to be used as a substitute for professional healthcare judgment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate healthcare professional.

Device Story

MobileCare Monitor 2100 (MyPHD) is a wearable monitoring system for long-term care and home settings. Input: accelerometer data and manual panic button activation. Operation: device detects impacts via accelerometers; triggers alerts at pre-set thresholds; transmits data via 2.4 GHz Zigbee (IEEE 802.15.4) wireless mesh to a hub. Output: audible or silent (vibration) alerts to caregivers/staff via remote care management system. Usage: worn on wrist or clipped to waist/clothing by residents; monitored by professional staff or caregivers. Benefit: enables rapid staff response to potential falls or emergency requests. System does not provide automated diagnosis or treatment; requires professional oversight.

Clinical Evidence

Bench testing only. No clinical data provided. Safety demonstrated via FCC compliance (Title 47, Part 15, Subpart B and C). Performance validated through software validation testing.

Technological Characteristics

Materials: common plastics. Sensing: accelerometers, impact detectors, motion detectors, nurse call button. Connectivity: 2.4 GHz Zigbee v3.2 (IEEE 802.15.4) wireless mesh. Power: AC wall plug for hub, batteries for wearable. Form factor: wrist-worn or body-clipped. Software: proprietary, rule-based threshold alerting.

Indications for Use

Indicated for residents in home, independent living, assisted living, and rehabilitation settings who require monitoring for potential falls or need to request assistance. Intended for 24-hour use by residents and staff. No specific age or gender contraindications stated.

Regulatory Classification

Identification

A bed-patient monitor is a battery-powered device placed under a mattress and used to indicate by an alarm or other signal when a patient attempts to leave the bed.

Predicate Devices

• TABS Elite and Wireless TABs Bed and Chair Exit Monitor System (Stanley Security Solutions, Inc., Senior Technologies Div.)
• WanderCare T100 (Care Electronics, K925529)

Submission Summary (Full Text)

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# KOGO 138

### 510(k) Summary

APR 2.4 2009

2000 Lee Highway
Second Floor
Falls Church Virginia 22042

Phone [phone]
Fax [phone]

www.aframedigital.com

Traditional 510(k) Notification Purpose:

MobileCare Monitor™ is intended for monitoring residents in a long-term Device Type: care facility. The product is intended to be a monitoring and alerting system similar to many commercially available panic button systems. This product adds location information and an impact sensor that may indicate a fall. Per FDA Request for Information # C070224 (See Appendix A), this is considered a Patient Bed Monitor, a Class I device, classification code KMI.

December 17, 2008 Date:

- AFrame Digital, Inc. 510(k) Submitter: 8000 Lee Highway, 2nd Floor Falls Church, VA 22042 Owner/Operator#: 10028071 510(k) #: K090138
- 510(k) Contact: Sunil Saxena, MD Chief Medical Officer 8000 Lee Highway, 2nd Floor Falls Church, VA 22042 571-308-0147 (O) 703-852-7902 (F) [e-mail]
- Indications For Use: The MobileCareTM Monitor 2100 system includes a MyPHDTM personal help device that is intended to monitor residents in home and long-term care facilities including independent living, assisted living and rehabilitation settings. The monitor can be placed on the wrist using the Velcro strap and used like a watch by the resident. The other form of

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MyPHD offered has no wrist straps so it can be clipped to the waist or used in a bandage for attachment at other locations on the person as may be appropriate or preferred by the user or healthcare provider. The system provides an alert to designated caregivers or professional staff automatically at pre-set thresholds to indicate an impact has occurred. The system also includes an emergency (panic) button that can be pressed by the monitored individual to alert caregivers as needed. The users of the system include staff and residents. The product is intended to be used on a 24-hour basis. The system is not intended to provide automated treatment decisions, nor is it to be used as a substitute for professional healthcare judgment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate healthcare professional.

| Trade Name: | MobileCare™ Monitor |
|-----------------|-----------------------------------------------------------|
| Common Name: | MobileCare™ Monitor |
| Classification: | Monitor, Bed Patient, (21 CFR 880.2400, Product Code KMI) |
| Product Code: | KMI (21 CFR 880.2400) |
| FDA Docs: | Request for Information # C070224 (Appendix A) |
| Basis: | New Submission |

Design & Use of the Device: (Refer to Table 1 below)

| Question | YES | NO |
|---------------------------------------------------------------------------------------|-----|-----|
| Is the device intended for prescription use (21 CFR<br>801 Subpart D)? | | × |
| Is the device intended for over-the-counter use (21<br>CFR 807 Subpart C)? | × | |
| Does the device contain components derived from a<br>tissue or other biologic source? | | × |
| Is the device provided sterile? | | × |
| Is the device intended for single use? | | × |
| Is the device a reprocessed single use device? | | × |
| If yes, does this device type require reprocessed<br>validation data? | | N/A |
| Does the device contain a drug? | | × |
| Does the device contain a biologic? | | × |

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| Does the device use software? | X |
|---------------------------------------------------|---|
| Does the submission include clinical information? | X |
| Is the device implanted? | X |

#### Comparison to Predicate:

#### Substantially Equivalent Device

The AFrame Digital, Inc. MobileCare™ Monitor is substantially equivalent to the Stanley Security Solutions, Inc., Senior Technologies Div. TABS Elite and Wireless TABs Bed and Chair Exit Monitor System and the Care Electronics WanderCare T100.

#### Basis of Substantial Equivalence

Per FDA Request for Information # C070224 (See Appendix A), this is considered a Patient Bed Monitor, a Class I device, classification code KMI. The AFrame Digital MobileCare™ Monitor is similar to the primary predicate monitor device with respect to technical characteristics and performance in the following ways.

| General Technical<br>Characteristics | Stanley Security<br>Solutions, Inc. Senior<br>Technologies Div.<br>TABS Professional<br>monitors w/Wireless<br>TABS System (Reg.<br>1929691) | Care<br>Electronics,<br>Inc.<br>WanderCare<br>(K925529) | Proposed device<br>(MobileCare™ Monitor<br>myPHD™) |
|-----------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Attribute<br>Indications for use | TABS System is<br>designed to notify staff<br>that a patient is leaving<br>a bed, chair, room or<br>wheelchair, by<br>identifying which<br>monitor is alarming so<br>staff can go directly to<br>the resident in need of<br>assistance. | WanderCare<br>provides<br>monitoring of a<br>wanderer in<br>the home. The<br>system alerts<br>the caregiver<br>when the<br>wanderer goes<br>beyond a set<br>range and<br>provides<br>location<br>tracking<br>capability up<br>to one mile so<br>that the<br>wanderer can<br>be located and<br>returned. | The MobileCare™<br>Monitor System is<br>designed to notify<br>healthcare providers<br>and caregivers to<br>know when a patient<br>requests assistance or<br>experiences an impact<br>that may be due to a<br>fall, and their<br>location, so staff can<br>go directly to the<br>resident in need of<br>assistance. |
| Prescription | No | No | No |
| Intended population | Long Term Care,<br>Assisted Living<br>Residential,<br>Rehabilitation and<br>Home Settings with<br>patients at risk for falls<br>and in need of other<br>assistance | Wanderers<br>(wandering<br>individuals) in<br>the home or in<br>facilities. | Long Term Care,<br>Assisted Living<br>Residential,<br>Rehabilitation and<br>Home Settings with<br>patients at risk for<br>falls and in need of<br>other assistance |
| Intended Environment<br>of Use | Home, Clinic | Home, Clinic | Home, Clinic |
| Design | | | |
| Method of data<br>collection | Proprietary Software | Proprietary<br>Software | Proprietary Software |
| Communication method<br>with Care Mgmt and<br>Nurse Call System | Wireless | Wireless | Wireless |
| Types of sensors which<br>can be interfaced to<br>receiver hub | Pressure sensors in bed<br>and chair pads, door<br>monitors, magnetic<br>locks, smoke detectors,<br>door/window<br>transmitters, motion<br>detectors, nurse call<br>transmitters | Transmitter | Accelerometers,<br>impact detectors,<br>door monitors, motion<br>detectors, and nurse<br>call button |
| Connectivity | Wireless to hub | Wireless<br>Transmitter to<br>Receiver<br>Antenna | Wireless mesh to hub |
| Communication method<br>of hub with devices | 900 Mhz Spread<br>Spectrum | RF approx<br>200-500 MHz | 2.4 Ghz Zigbee v3.2<br>(IEEE 802.15.4) |
| Communications<br>protocol | Proprietary | Proprietary | Zigbee v3.2<br>(IEEE 802.15.4) |
| Wireless frequency | 900 Mhz Spread<br>Spectrum | RF approx<br>200-500 MHz | 2.402 to 2.480 GHz<br>(FHSS) ISM Band |
| Power Source | Wall plug for hub (a/c)<br>and 9V battery for<br>510(k) approved sensor<br>devices. | 9V battery for<br>transmitter | Wall plug for hub<br>(a/c) and batteries for<br>510(k) approved<br>sensor devices and<br>myPHDTM |
| Form Factor | Pressure Pad under bed<br>or chair | "Fanny Pack"<br>worn at the<br>waist with<br>transmitter<br>and 9V battery<br>assembly<br>inside. | Wrist watch or as a<br>small case for<br>attachment to<br>clothing at torso or<br>under a bandage. |
| Display | Low battery indicator on<br>unit. Flashing light<br>indicating source of call. | No display on<br>Fanny Pack.<br>LCD display on<br>Care | On myPHDTM watch<br>display in normal<br>mode or flashing<br>indicator if activated |
| | to Remote Nurse Call<br>System annunciator. | management<br>system for<br>caregiver. | and also on remote<br>care management<br>system |
| Alerts | Audible alarm at<br>bedside when sensor<br>activated | Alerts<br>wirelessly to<br>care<br>management<br>system for<br>caregiver. | Alert silently<br>(vibration) or audibly<br>to caregiver or nurse<br>at bedside or<br>remotely when sensor<br>activated |
| Alert reset | Manual and Automatic<br>when pressure is re-<br>applied (e.g. patient<br>returns to bed) | Manual or<br>Automatic<br>when person<br>returns to<br>area. | Manual or Automatic<br>upon caregiver<br>acknowledgement of<br>activation. |
| Materials | Common plastic<br>materials for human use | Common<br>plastic case for<br>human use. | Common plastic<br>materials for human<br>use |

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#### 1. Non Clinical substantial equivalence

- a. Safety The safety of the device is demonstrated conformance to the following standard:
FCC "Code of Federal Regulations" Title 47, Part 15, Subpart B, for receivers and Subpart C, Section 15.247 for Digital Modulation Intentional Radiators Operating within the band 2400-2483.5MHz

- A copy of the engineering test report demonstrating compliance with the above is contained in Appendix B of this submission
- b. Performance The performance of the device is demonstrated through the validation of the software. A summary report of this software validation is included as Appendix D of this submission.

#### 2. Conclusion:

The information in the Premarket Notification on safety and effectiveness supports a finding of substantial equivalence to devices already in commercial distribution. Equivalence is demonstrated through intended use, design and testing methods.

#### Similarities/Differences of the proposed device when compared to the predicate: 3.

The data within this submission demonstrates that there are no significant differences between the application device and the predicate, indicating that the application device is safe, effective and substantially equivalent for marketing in the U.S.

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#### DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter. Inside the circle is a stylized symbol that resembles an eagle or bird-like figure, composed of three curved lines. The symbol is positioned to the right of the text.

#### Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

APR 2 4 2009

Sunil Saxena, MD Chief Medical Officer AFrame Digital, Incorporated 8000 Lee Highway 2nd Floor Falls Church, Virginia 22042

Re: K090138

Trade/Device Name: MyPHD™ MobileCare™ Model 2100 Regulation Number: 21 CFR 880.2400 Regulation Name: Bed-Patient Monitor Regulatory Class: I Product Code: KMI Dated: March 26, 2009 Received: March 31, 2009

Dear Dr. Saxena:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements

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#### Page 2- Dr. Saxena

of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please contact the CDRH/Office of Surveillance and Biometrics/Division of Postmarket Surveillance at 240-276-3464. For more information regarding the reporting of adverse events, please go to http://www.fda.gov/cdrh/mdr/.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely vours,

Susan Runner, D.D.S., MA Acting Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## Indications for Use

510(k) Number (if known): K090138

Device Name: _ MyPHD MobileCare Monitor TM Model 2100

Indications For Use:

The MobileCare™ Monitor 2100 system includes a MyPHD™ personal help device that is intended to monitor residents in home and long-term care facilities including independent living, assisted living and rehabilitation settings. The monitor can be placed on the wrist using the Velcro strap and used like a watch by the resident. The other form of MyPHD offered has no wrist straps so it can be clipped to the waist or used in a bandage for attachment at other locations on the person as may be appropriate or preferred by the user or healthcare provider. The system provides an alert to designated caregivers or professional staff automatically at pre-set thresholds to indicate an impact has occurred. The system also includes an emergency (panic) button that can be pressed by the monitored individual to alert caregivers as needed. The users of the system include staff and residents. The product is intended to be used on a 24-hour basis. The system is not intended to provide automated treatment decisions, nor is it to be used as a substitute for professional healthcare judgment. All patient medical diagnosis and treatment are to be performed under direct supervision and oversight of an appropriate healthcare professional.

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

| Concurrence of CDRH, Office of Device Evaluation (ODE) | |
|--------------------------------------------------------|---------|
| (Division Sign-Off) | |
| Division of Anesthesiology, General Hospital | |
| Infection Control, Dental Devices | |
| | |
| 510(k) Number: | K090138 |