QNL · Medium-Term Adjunctive Predictive Cardiovascular Indicator

Cardiovascular · 21 CFR 870.2210 · Class 2

Overview

Identification

The adjunctive predictive cardiovascular indicator is a prescription device that uses software algorithms to analyze cardiovascular vital signs and predict future cardiovascular status or events. This device is intended for adjunctive use with other physical vital sign parameters and patient information and is not intended to independently direct therapy.

Classification Rationale

Class II (special controls). The special controls for this device are:

Special Controls

*Classification.* Class II (special controls). The special controls for this device are:(1) A software description and the results of verification and validation testing based on a comprehensive hazard analysis and risk assessment must be provided, including: (i) A full characterization of the software technical parameters, including algorithms; (ii) A description of the expected impact of all applicable sensor acquisition hardware characteristics and associated hardware specifications; (iii) A description of sensor data quality control measures; (iv) A description of all mitigations for user error or failure of any subsystem components (including signal detection, signal analysis, data display, and storage) on output accuracy; (v) A description of the expected time to patient status or clinical event for all expected outputs, accounting for differences in patient condition and environment; and (vi) The sensitivity, specificity, positive predictive value, and negative predictive value in both percentage and number form. (2) A scientific justification for the validity of the predictive cardiovascular indicator algorithm(s) must be provided. This justification must include verification of the algorithm calculations and validation using an independent data set. (3) A human factors and usability engineering assessment must be provided that evaluates the risk of misinterpretation of device output. (4) A clinical data assessment must be provided. This assessment must fulfill the following: (i) The assessment must include a summary of the clinical data used, including source, patient demographics, and any techniques used for annotating and separating the data. (ii) The clinical data must be representative of the intended use population for the device. Any selection criteria or sample limitations must be fully described and justified. (iii) The assessment must demonstrate output consistency using the expected range of data sources and data quality encountered in the intended use population and environment. (iv) The assessment must evaluate how the device output correlates with the predicted event or status. (5) Labeling must include: (i) A description of what the device measures and outputs to the user; (ii) Warnings identifying sensor acquisition factors that may impact measurement results; (iii) Guidance for interpretation of the measurements, including a statement that the output is adjunctive to other physical vital sign parameters and patient information; (iv) A specific time or a range of times before the predicted patient status or clinical event occurs, accounting for differences in patient condition and environment; (v) Key assumptions made during calculation of the output; (vi) The type(s) of sensor data used, including specification of compatible sensors for data acquisition; (vii) The expected performance of the device for all intended use populations and environments; and (viii) Relevant characteristics of the patients studied in the clinical validation (including age, gender, race or ethnicity, and patient condition) and a summary of validation results.

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Top Applicants

• Clew Medical , Ltd. — 2 clearances
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• Implicity, Inc. — 1 clearance