K183241 · Brainscope Company, Inc. · PIW · Feb 19, 2019 · Neurology
Device Facts
Record ID
K183241
Device Name
BrainScope TBI (Model: Ahead 400)
Applicant
Brainscope Company, Inc.
Product Code
PIW · Neurology
Decision Date
Feb 19, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 882.1450
Device Class
Class 2
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Structural brain injury likelihood
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Brain function index
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Cognitive performance
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Normative data collected from 707 healthy individuals
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Indications for Use
BrainScope TBI is a multi-modal, multi-parameter assessment indicated for use as an adjunct to standard clinical practice to aid in the evaluation of patients who have sustained a closed head injury within the past 72 hours (3 days), are between the ages of 18-85 years, have a Glasgow Coma Scale (GCS) score of 13-15 (including patients with concussion / mild traumatic brain injury (mTBI), and are being considered for a head CT. BrainScope TBI should not be used as a substitute for a CT scan. The BrainScope TBI Structural Injury Classification ("SIC") uses brain electrical activity to determine the likelihood of structural brain injury visible on head CT. Negative likely corresponds to those with no structural brain injury visible on head CT. Positive likely corresponds to those with a structural brain injury visible on head CT. Equivocal may correspond to structural brain injury visible on head CT or may indicate the need for further observation or evaluation. BrainScope TBI provides a measure of brain function Index, (BFI)) for the statistical evaluation of the human electroencephalogram (EEG), aiding in the evaluation of head injury as part of a multi-modal, multi-parameter assessment. The BrainScope TBI device is intended to record, measure, analyze, and display brain electrical activity utilizing the calculation of standard quantitative EEG (QEEG) parameters from frontal locations on a patient's forehead. The BrainScope TBI calculates and displays raw measures for the following standard QEEG measures: Absolute and Relative Power, Asymmetry, Coherence and Fractal Dimension. These raw measures are intended to be used for post hoc analysis of EEG signals for interpretation by a qualified user. BrainScope TBI also provides clinicians with quantitative measures of cognitive performance to aid in the assessment of an individual's level of cognitive function. These measures do not interact with any other device measures, and are stand alone. BrainScope TBI also stores and displays electronic of standardized clinical assessment tools that should be used in accordance with the assessment tools' general instructions. These tools do not interact with any other device measures, and are stand alone.
Device Story
Portable, non-invasive, point-of-care device for mTBI assessment. Inputs: frontal EEG signals via single-use Ag/AgCl electrode headset; cognitive performance test responses; standardized clinical assessment data. Operation: records/analyzes EEG to calculate QEEG parameters (Absolute/Relative Power, Asymmetry, Coherence, Fractal Dimension) and Structural Injury Classification (SIC) via proprietary algorithms; provides cognitive performance measures and Reliable Change Index (RCI). Used by clinicians in clinical settings to aid head CT decision-making. Output: SIC (Negative/Positive/Equivocal), BFI, raw QEEG measures, cognitive scores, and electronic clinical assessment forms. Benefits: provides objective adjunctive data to support clinical evaluation of head injury, potentially optimizing CT utilization.
Clinical Evidence
Bench testing only. Normative data collected from 707 healthy individuals (ages 13-85) to construct databases for cognitive tests. Device conforms to IEC 60601-1, IEC 60601-1-2 (Ed 4.0), IEC 60601-1-6, IEC 60601-2-26, ANSI/AAMI EC12, and ISO 10993 standards. No clinical performance data for the TBI indication was required beyond that established for the predicate.
Technological Characteristics
Portable device using Trimble T41 platform (Android OS). EEG sensing via single-use Ag/AgCl electrode array (International 10-20 system). Bandwidth: DC-300Hz (1kHz sample) and 0.67-43Hz (100Hz sample). Connectivity: USB 2.0, Wi-Fi, Cellular. Software: Kiosk mode application. Standards: IEC 60601-1, IEC 60601-1-2, IEC 60601-2-26, ANSI/AAMI EC12, ISO 10993, MIL-STD-810G.
Indications for Use
Indicated for patients aged 18-85 years who have sustained a closed head injury within the past 72 hours, present with a GCS score of 13-15 (including mTBI/concussion), and are being considered for a head CT scan.
Regulatory Classification
Identification
A brain injury adjunctive interpretive electroencephalograph assessment aid is a prescription device that uses a patient's electroencephalograph (EEG) to provide an interpretation of the structural condition of the patient's brain in the setting of trauma. A brain injury adjunctive interpretive EEG assessment aid is for use as an adjunct to standard clinical practice only as an assessment aid for a medical condition for which there exists other valid methods of diagnosis.
Special Controls
In combination with the general controls of the FD&C Act, the Ahead 100 is subject to the following special controls:
*Classification.* Class II (special controls). The special controls for this device are:(1) The technical parameters of the device, hardware and software, must be fully characterized and include the following information:
(i) Hardware specifications must be provided. Appropriate verification, validation, and hazard analysis must be performed.
(ii) Software, including any proprietary algorithm(s) used by the device to arrive at its interpretation of the patient's condition, must be described in detail in the software requirements specification (SRS) and software design specification (SDS). Appropriate software verification, validation, and hazard analysis must be performed.
(2) The device parts that contact the patient must be demonstrated to be biocompatible.
(3) The device must be designed and tested for electrical safety, electromagnetic compatibility (EMC), thermal, and mechanical safety.
(4) Clinical performance testing must demonstrate the accuracy, precision-repeatability and reproducibility, of determining the EEG-based interpretation, including any specified equivocal zones (cutoffs).
(5) Clinical performance testing must demonstrate the ability of the device to function as an assessment aid for the medical condition for which the device is indicated. Performance measures must demonstrate device performance characteristics per the intended use in the intended use environment. Performance measurements must include sensitivity, specificity, positive predictive value (PPV), and negative predictive value (NPV) with respect to the study prevalence per the device intended use.
(6) The device design must include safeguards to ensure appropriate clinical interpretation of the device output (
*e.g.,* use in appropriate patient population, or for appropriate clinical decision).(7) The labeling and training information must include:
(i) A warning that the device is not to be used as a stand-alone diagnostic.
(ii) A detailed summary of the clinical performance testing, including any adverse events and complications.
(iii) The intended use population and the intended use environment.
(iv) Any instructions technicians should convey to patients regarding the collection of EEG data.
(v) Information allowing clinicians to gauge clinical risk associated with integrating the EEG interpretive assessment aid into their diagnostic pathway.
(vi) Information allowing clinicians to understand how to integrate the device output into their diagnostic pathway when the device is unable to provide a classification or final result.
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February 19, 2019
Image /page/0/Picture/1 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
BrainScope Company Inc. Michael Singer CEO 4350 East West Hwy, Ste 1050 Bethesda. Maryland 20814
#### Re: K183241
Trade/Device Name: BrainScope TBI (Model: Ahead 400) Regulation Number: 21 CFR 882.1450 Regulation Name: Brain Injury Adjunctive Interpretive Electroencephalograph Assessment Aid Regulatory Class: Class II Product Code: PIW, PKO, OLU Dated: November 20, 2018 Received: November 21, 2018
Dear Michael Singer:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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 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 of medical device-related adverse events) (21 CFR 803) for
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Jay R. Gupta -S
For Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K183241
Device Name BrainScope TBI (Model: Ahead 400)
#### Indications for Use (Describe)
· BrainScope TBI is a multi-modal, multi-parameter assessment indicated for use as an adjunct to standard clinical practice to aid in the evaluation of patients who have sustained a closed head injury within the past 72 hours (3 days), are between the ages of 18-85 years, have a Glasgow Coma Scale (GCS) score of 13-15 (including patients with concussion / mild traumatic brain injury (mTBI), and are being considered for a head CT. BrainScope TBI should not be used as a substitute for a CT scan.
• The BrainScope TBI Structural Injury Classification ("SIC") uses brain electrical activity to determine the likelihood of structural brain injury visible on head CT. Negative likely corresponds to those with no structural brain injury visible on head CT. Positive likely corresponds to those with a structural brain injury visible on head CT. Equivocal may correspond to structural brain injury visible on head CT or may indicate the need for further observation or evaluation.
· BrainScope TBI provides a measure of brain function Index, (BFI)) for the statistical evaluation of the human electroencephalogram (EEG), aiding in the evaluation of head injury as part of a multi-modal, multi-parameter assessment.
· The BrainScope TBI device is intended to record, measure, analyze, and display brain electrical activity utilizing the calculation of standard quantitative EEG (QEEG) parameters from frontal locations on a patient's forehead. The BrainScope TBI calculates and displays raw measures for the following standard QEEG measures: Absolute and Relative Power, Asymmetry, Coherence and Fractal Dimension. These raw measures are intended to be used for post hoc analysis of EEG signals for interpretation by a qualified user.
· BrainScope TBI also provides clinicians with quantitative measures of cognitive performance to aid in the assessment of an individual's level of cognitive function. These measures do not interact with any other device measures, and are stand alone.
· BrainScope TBI also stores and displays electronic of standardized clinical assessment tools that should be used in accordance with the assessment tools' general instructions. These tools do not interact with any other device measures, and are stand alone.
Type of Use (Select one or both, as applicable)
| <span style="font-size:12px">☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="font-size:12px">☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
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Image /page/3/Picture/0 description: The image shows the logo for BrainScope. The logo is in blue and features the word "BrainScope" in a stylized font. There are two horizontal lines under the word. The registered trademark symbol is to the right of the word.
4330 East-West Highway.Suite 1000.Bethesda.Maryland.20814
www.brainscope.com
phone 240.752.7680
# 510(k) SUMMARY1
| Submitter: | BrainScope® Company, Inc.<br>4330 East West Highway Suite #1000<br>Bethesda, MD 20814<br>Phone: (240) 752-7680<br>Fax: (240) 752-7679<br>www.brainscope.com |
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| Contact: | Michael E. Singer, Ph.D.<br>Chief Executive Officer<br>BrainScope Company, Inc.<br>Phone: (240) 752-7677<br>Fax: (240) 752-7679<br>Email: michael.singer@brainscope.com |
| Prepared By: | Sabyasachi Roy, Ph.D.<br>Director Regulatory Affairs, Quality Assurance<br>&<br>Compliance |
| Device Proprietary Name: | BrainScope TBI (Model: Ahead 400) |
| Device Common Name: | Brain Injury Adjunctive Interpretive<br>Electroencephalograph Assessment Aid |
| Device Classification Name: | Brain Injury Adjunctive Interpretive<br>Electroencephalograph Assessment Aid |
| Classification Regulation: | 21 CFR § 882.1450 |
| Panel: | Neurology |
| Product Codes: | PIW, PKQ, OLU |
| Predicate Devices: | BrainScope One (K181179)<br>ANAM Test System: Military Battery (K150154) |
<sup>1</sup> Prepared in accordance with 21 CFR § 807.87(h) and 21 CFR § 807.92(c). BrainScope TBI 510(k) Summary
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Image /page/4/Picture/0 description: The image shows the logo for BrainScope. The logo is in blue and features the word "BrainScope" in a stylized font. There are two horizontal lines, one above and one below the word. The "O" in scope has a brainwave graphic in the middle of it.
## Device Description:
BrainScope TBI is a portable, non-invasive, non-radiation emitting, point of care device intended to provide results and measures to support clinical assessments and aid in the diagnosis of mild traumatic brain injury (mTBI). It also contains configurable, selectable computerized cognitive performance tests and digitized standard clinical assessment intended to provide a multi-modal panel of measures to support the clinical assessment of concussion / mTBI. BrainScope TBI provides healthcare professionals with a set of validated and clinically accepted library of concussion / mTBI assessments.
## Indications for Use:2
The BrainScope TBI's Indications for Use are as follows:
- . BrainScope TBI is a multi-modal, multi-parameter assessment indicated for use as an adjunct to standard clinical practice to aid in the evaluation of patients who have sustained a closed head injury within the past 72 hours (3 days), are between the ages of 18-85 years, have a Glasgow Coma Scale (GCS) score of 13-15 (including patients with concussion / mild traumatic brain injury (mTBI)), and are being considered for a head CT. BrainScope TBI should not be used as a substitute for a CT scan.
- The BrainScope TBI Structural Injury Classification ("SIC") uses brain electrical . activity to determine the likelihood of structural brain injury visible on head CT. Negative likely corresponds to those with no structural brain injury visible on head CT. Positive likely corresponds to those with a structural brain injury visible on head CT. Equivocal may correspond to structural brain injury visible on head CT or may indicate the need for further observation or evaluation.
- BrainScope TBI provides a measure of brain function (EEG Brain Function Index, . (BFI)) for the statistical evaluation of the human electroencephalogram (EEG), aiding in the evaluation of head injury as part of a multi-modal, multi-parameter assessment.
- . The BrainScope TBI device is intended to record, measure, analyze, and display brain electrical activity utilizing the calculation of standard quantitative EEG (QEEG) parameters from frontal locations on a patient's forehead. The BrainScope TBI calculates and displays raw measures for the following standard QEEG measures: Absolute and Relative Power, Asymmetry, Coherence and Fractal Dimension. These raw measures are intended to be used for post hoc analysis of EEG signals for interpretation by a qualified user.
- BrainScope TBI also provides clinicians with quantitative measures of cognitive . performance to aid in the assessment of an individual's level of cognitive function.
<sup>2</sup> The differences between the BrainScope TBI and its predicate (BrainScope One) do not alter the intended use of the device nor do they affect the safety and effectiveness of the predicate. The subject and predicate device have the same overall intended use.
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Image /page/5/Picture/0 description: The image shows the BrainScope logo in blue. The word "Brain" is written in a bold, sans-serif font with a horizontal line above and below it. The word "Scope" is written in a similar font, but with a wavy line in the middle of the "O" and a horizontal line below it. There is a registered trademark symbol to the right of the word "Scope".
These measures do not interact with any other device measures, and are stand alone.
- · BrainScope TBI also stores and displays electronic versions of standardized clinical assessment tools that should be used in accordance with the assessment tools' general instructions. These tools do not interact with any other device measures, and are stand alone.
| Proposed Device:<br>BrainScope TBI<br>(K183241) | Primary Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System -<br>Military Battery<br>(K150154) | Comments |
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| BrainScope TBI is a<br>multi-modal, multi-<br>parameter assessment<br>indicated for use as an<br>adjunct to standard<br>clinical practice to aid<br>in the evaluation of<br>patients who have<br>sustained a closed<br>head injury within the<br>past 72 hours (3 days),<br>are between the ages<br>of 18-85 years, have a<br>Glasgow Coma Scale<br>(GCS) score of 13-15<br>(including patients with<br>concussion / mild<br>traumatic brain injury<br>(mTBI)), and are being<br>considered for a head<br>CT. BrainScope TBI<br>should not be used as<br>a substitute for a CT<br>scan. | BrainScope One is<br>indicated for use as an<br>adjunct to standard<br>clinical practice to aid<br>in the evaluation of<br>patients who are being<br>considered for a head<br>CT, who sustained a<br>closed head injury<br>within 72 hours,<br>present with a Glasgow<br>Coma Scale score<br>(GCS) of 13-15<br>(including concussion /<br>mild Traumatic Brain<br>Injury (mTBI)), and are<br>between the ages of<br>18-85 years.<br>BrainScope One<br>should not be used as<br>a substitute for a CT<br>scan. | N/A | Equivalent. As<br>cleared under<br>510(k) K181785. |
| The BrainScope TBI<br>device is intended to<br>record, measure,<br>analyze, and display<br>brain electrical activity<br>utilizing the calculation<br>of standard quantitative<br>EEG (QEEG)<br>parameters from frontal<br>locations on a patient's<br>forehead. The<br>BrainScope TBI | The BrainScope One<br>device is intended to<br>record, measure,<br>analyze, and display<br>brain electrical activity<br>utilizing the calculation<br>of standard quantitative<br>EEG (QEEG)<br>parameters from frontal<br>locations on a patient's<br>forehead. The<br>BrainScope One | N/A | Same as primary<br>predicate. |
| Proposed Device:<br>BrainScope TBI<br>(K183241) | Primary Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System –<br>Military Battery<br>(K150154) | Comments |
| calculates and displays<br>raw measures for the<br>following standard<br>QEEG measures:<br>Absolute and Relative<br>Power, Asymmetry,<br>Coherence and Fractal<br>Dimension. These raw<br>measures are intended<br>to be used for post hoc<br>analysis of EEG<br>signals for<br>interpretation by a<br>qualified user. | calculates and displays<br>raw measures for the<br>following standard<br>QEEG measures:<br>Absolute and Relative<br>Power, Asymmetry,<br>Coherence and Fractal<br>Dimension. These raw<br>measures are intended<br>to be used for post hoc<br>analysis of EEG<br>signals for<br>interpretation by a<br>qualified user. | | |
| The BrainScope TBI<br>Structural Injury<br>Classification (“SIC”)<br>uses brain electrical<br>activity to determine<br>the likelihood of<br>structural brain injury<br>visible on head CT.<br>Negative likely<br>corresponds to those<br>with no structural brain<br>injury visible on head<br>CT. Positive likely<br>corresponds to those<br>with a structural brain<br>injury visible on head<br>CT. Equivocal may<br>correspond to<br>structural brain injury<br>visible on head CT or<br>may indicate the need<br>for further observation<br>or evaluation. | A negative BrainScope<br>One Structural Injury<br>Classification using<br>brain electrical activity<br>in patients who<br>sustained a closed<br>head injury within 72<br>hours, likely<br>corresponds to those<br>with no structural brain<br>injury visible on head<br>CT. | N/A | Equivalent. As<br>cleared under<br>510(k) K181785. |
| | A positive BrainScope<br>One Structural Injury<br>Classification using<br>brain electrical activity<br>in patients who<br>sustained a closed<br>head injury within 72<br>hours, likely<br>corresponds to those<br>with a structural brain<br>injury visible on head<br>CT. | N/A | Equivalent. As<br>cleared under<br>510(k) K181785. |
| | An equivocal<br>BrainScope One<br>Structural Injury<br>Classification using<br>brain electrical activity<br>in patients who<br>sustained a closed<br>head injury within 72<br>hours, likely | N/A | Equivalent. As<br>cleared under<br>510(k) K181785. |
| Proposed Device:<br>BrainScope TBI<br>(K183241) | Primary Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System –<br>Military Battery<br>(K150154) | Comments |
| | hours, may correspond<br>to structural brain injury<br>visible on head CT or<br>may indicate the need<br>for further observation<br>or evaluation. | | |
| BrainScope TBI<br>provides a measure of<br>brain function (EEG<br>Brain Function Index,<br>(BFI)) for the statistical<br>evaluation of the<br>human<br>electroencephalogram<br>(EEG), aiding in the<br>evaluation of head<br>injury as part of a multi-<br>modal, multi-parameter<br>assessment. | The BrainScope One<br>provides a measure of<br>brain function (EEG<br>Brain Function Index,<br>(BFI)) for the statistical<br>evaluation of the<br>human<br>electroencephalogram<br>(EEG). | N/A | Equivalent. As<br>cleared under<br>510(k) K181785. |
| BrainScope TBI also<br>provides clinicians with<br>quantitative measures<br>of cognitive<br>performance to aid in<br>the assessment of an<br>individual's level of<br>cognitive function.<br>These measures do<br>not interact with any<br>other device measures,<br>and are stand alone. | The BrainScope One<br>also provides clinicians<br>with quantitative<br>measures of cognitive<br>performance to aid in<br>the assessment of an<br>individual's level of<br>cognitive function.<br>These measures do<br>not interact with any<br>other device measures,<br>and are stand alone. | The ANAM Test<br>System: Military<br>Battery provides<br>clinicians with<br>objective<br>measurements of<br>cognitive<br>performance in<br>military populations<br>ages 18 to 65 years,<br>to aid in the<br>assessment of an<br>individual's level of<br>cognitive<br>functioning. The<br>ANAM Test System<br>should only be used<br>as an adjunctive tool<br>for evaluating<br>cognitive function. | Same as primary<br>predicate<br>(BrainScope One)<br>and equivalent to<br>secondary<br>predicate (ANAM<br>Test System –<br>Military Battery).<br>BrainScope TBI<br>extends age range<br>from 18-85 years<br>in predicate<br>(BrainScope One)<br>to 13 – 85 years.<br>Additional<br>performance data<br>including norming<br>study supported<br>the extended age<br>range. |
| BrainScope TBI also<br>stores and displays<br>electronic versions of<br>standardized clinical<br>assessment tools that<br>should be used in | The BrainScope One<br>also stores and<br>displays electronic<br>versions of<br>standardized clinical<br>assessment tools that | N/A | Equivalent.<br>Expanding the<br>availability of<br>clinical<br>assessment tools<br>does not affect the |
| Proposed Device:<br>BrainScope TBI<br>(K183241) | Primary Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System –<br>Military Battery<br>(K150154) | Comments |
| accordance with the<br>assessment tools'<br>general instructions.<br>These tools do not<br>interact with any other<br>device measures, and<br>are stand alone. | should be used in<br>accordance with the<br>assessment tools'<br>general instructions.<br>These tools do not<br>interact with any other<br>device measures, and<br>are stand alone. | | safety and<br>effectiveness of<br>the device.<br>Expanding<br>functionality<br>increases the<br>utility of the device<br>and better meets<br>user needs. |
#### Table 1: Indications for Use Comparison to Predicate devices
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Image /page/6/Picture/0 description: The image shows the BrainScope logo. The logo is in blue and features the word "BrainScope" in a stylized font. There are horizontal lines above and below the word "BrainScope". The "o" in "Scope" is stylized with a brainwave pattern. There is a registered trademark symbol to the right of the word "Scope".
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Image /page/7/Picture/0 description: The image shows the logo for BrainScope. The logo is in blue and features the word "BrainScope" in a stylized font. There are lines above and below the word, and the "O" in "Scope" is replaced with a brainwave graphic. A registered trademark symbol is located to the right of the word.
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Image /page/8/Picture/0 description: The image shows the logo for BrainScope. The logo is in blue and features the word "BrainScope" in a stylized font. There are lines above and below the word, and the "O" in "Scope" is replaced with a brainwave graphic. A registered trademark symbol is located to the right of the word.
# Comparison of Technological Characteristics with the Predicate Device:
The BrainScope TBI has similar technological characteristics as the legally marketed predicate devices. The BrainScope TBI includes the following modifications when compared to the primary predicate (BrainScope One):
- . Three additional computerized Cognitive Performance tests for a total of five. All five computerized Coqnitive Performance tests are intended for use on patients 13 - 85 years of age.
- . The addition of PECARN – Pediatric Head Injury Predication Rule to the library of Standard Clinical Assessments already included in BrainScope One.
- Expanded device connectivity to include an Over the Air (OTA) software upgrade . capability made possible using a Wi-Fi or Cellular connection.
All EEG based algorithms in both devices are limited to the FDA authorized age range of 18 to 85 years (Adolescent subgroup and Adult age patients).
The minor technological differences between the BrainScope TBI and the predicates do not raise new questions of safety and effectiveness and performance data demonstrate that the BrainScope TBI is as safe and effective as the predicate.
The BrainScope TBI is substantially equivalent to the predicates the BrainScope One and ANAM Test System - Military Battery.
| Topic /<br>Area | Proposed<br>Device:<br>BrainScope TBI | Primary<br>Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System –<br>Military Battery<br>(K150154) | Comments |
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| Hardware | | | | |
| Platform | Trimble T41<br>mobile device,<br>Android OS | Trimble T41<br>mobile device,<br>Android OS | PC: Dell Latitude<br>E6440 Laptop | Same as primary<br>predicate. |
| Topic /<br>Area | Proposed<br>Device:<br>BrainScope TBI | Primary<br>Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System -<br>Military Battery<br>(K150154) | Comments |
| Processed<br>EEG<br>Bandwidth | 1kHz sampled<br>data with DC to<br>300Hz bandwidth<br>and 100Hz<br>sampled data<br>with 0.67Hz to<br>43Hz bandwidth | 1kHz sampled<br>data with DC to<br>300Hz bandwidth<br>and 100Hz<br>sampled data with<br>0.67Hz to 43Hz<br>bandwidth | N/A | Same as primary<br>predicate. |
| Common<br>Mode<br>Rejection<br>Ratio<br>(CMRR) | < -100 dB (or<br>better) | < -100 dB (or<br>better) | N/A | Same as primary<br>predicate. |
| System<br>Noise<br>Floor | < 0.4 µV in 0.67<br>Hz to 43Hz<br>bandwidth | < 0.4 µV in 0.3 Hz<br>to 43Hz bandwidth | N/A | Same as primary<br>predicate. |
| ADC<br>Resolution | 45 nV/bit | 45 nV/bit | N/A | Same as primary<br>predicate. |
| ADC<br>Sampling<br>Rate | 1000 Hz, down<br>sampled to 100<br>Hz for algorithm<br>processing | 1000 Hz, down<br>sampled to 100 Hz<br>for algorithm<br>processing | N/A | Same as primary<br>predicate. |
| Electrode<br>Placement<br>System | The International<br>10-20 System | The International<br>10-20 System | N/A | Same as primary<br>predicate. |
| Electrode<br>Positions<br>Utilized | Fp1, Fp2, Fpz,<br>AFz, F7, F8, A1,<br>A2 | Fp1, Fp2, Fpz,<br>Afz, F7, F8, A1,<br>A2 | N/A | Same as primary<br>predicate. |
| Electrode<br>Material | Single use<br>Ag/AgCl<br>electrode sensor<br>array headset<br>with solid gel | Single use<br>Ag/AgCl electrode<br>sensor array<br>headset with solid<br>gel | N/A | Same as primary<br>predicate. |
| Assessment and Software | | | | |
| Real Time<br>EEG<br>Display | Yes | Yes | N/A | Same as primary<br>predicate. |
| EEG<br>Based<br>Classificati | Three tier<br>classification with<br>results of | Three tier<br>classification with<br>results of | N/A | Same as primary<br>predicate. |
| Topic /<br>Area | Proposed<br>Device:<br>BrainScope TBI | Primary<br>Predicate:<br>BrainScope One<br>(K181179) | Secondary<br>Predicate: ANAM<br>Test System –<br>Military Battery<br>(K150154) | Comments |
| on<br>Algorithm<br>(Structural<br>Injury<br>Classification) | Negative,<br>Equivocal and<br>Positive outputs. | Negative,<br>Equivocal and<br>Positive outputs. |…
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.