K122340 · Prodigy Diabetes Care, LLC · NBW · Nov 26, 2013 · Clinical Chemistry
Device Facts
Record ID
K122340
Device Name
PRODIGY CHOICE
Applicant
Prodigy Diabetes Care, LLC
Product Code
NBW · Clinical Chemistry
Decision Date
Nov 26, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Prodigy Choice Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, palm, upper-arm, calf or thigh. The Prodigy Choice Blood Glucose Monitoring System is intended to be used by a single person and should not be shared. The Prodigy Choice Blood Glucose Monitoring System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The Prodigy Choice Blood Glucose Monitoring System should not be used for the diagnosis of or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady – state times (when glucose is not changing rapidly). The Prodigy Choice Test Strips are for use with the Prodigy Choice Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, palm, upper-arm, calf or thigh.
Device Story
Prodigy Choice Blood Glucose Monitoring System measures glucose in capillary whole blood via amperometric assay using glucose oxidase (Aspergillus sp.). User applies 0.7 μL blood sample to test strip; meter measures electrical current proportional to glucose concentration. Used at home by patients with diabetes for monitoring; not for insulin dosing or CGM calibration. Meter features auto-coding; requires user to verify code on strip vial matches meter display. Results displayed on screen; used by patients to track glucose levels. System includes meter, test strips, control solution, and lancing device. Designed for single-patient use; validated for cleaning/disinfection cycles.
Clinical Evidence
Clinical performance evaluated via lay-user study (n=151) and healthcare professional (HCP) study (n=100). Accuracy compared against YSI reference method across finger, palm, forearm, upper-arm, calf, and thigh sites. Results showed 95% of readings within ±15 mg/dL for concentrations <75 mg/dL and within ±20% for concentrations ≥75 mg/dL. Bench testing included precision (pooled %CV 2.5-5.2%), linearity (r=1.00), interference testing, hematocrit (20-60%), altitude, and temperature/humidity stability.
Technological Characteristics
Electrochemical biosensor; glucose oxidase enzyme (Aspergillus niger); quantitative measurement of capillary whole blood; battery-powered; handheld meter form factor; no voice capability.
Indications for Use
Indicated for people with diabetes mellitus for quantitative measurement of glucose in fresh capillary whole blood from fingertips, palm, forearm, upper-arm, calf, or thigh. For home self-testing as an aid to monitor diabetes control. Contraindicated for neonatal use, screening or diagnosis of diabetes, critically ill patients, patients in shock, dehydrated patients, or hyper-osmolar patients.
Regulatory Classification
Identification
A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Special Controls
*Classification.* Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.
Predicate Devices
Prodigy Voice BGMS (k073118)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k122340
B. Purpose for Submission:
New device
C. Measurand:
Capillary whole blood glucose from the finger, forearm, upper arm, palm, calf and thigh
D. Type of Test:
Quantitative Amperometric Assay (Glucose Oxidase)
E. Applicant:
Prodigy Diabetes Care, LLC
F. Proprietary and Established Names:
Prodigy Choice Blood Glucose Monitoring System
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| NBW - Glucose test system | Class II | 862.1345 | Clinical Chemistry (75) |
| CGA – Glucose Oxidase, Glucose | Class II | 862.1345 | Clinical Chemistry (75) |
H. Intended Use:
1. Intended use(s):
See indications for use below
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2. Indication(s) for use:
The Prodigy Choice Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, palm, upper-arm, calf or thigh. The Prodigy Choice Blood Glucose Monitoring System is intended to be used by a single person and should not be shared.
The Prodigy Choice Blood Glucose Monitoring System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The Prodigy Choice Blood Glucose Monitoring System should not be used for the diagnosis of or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady – state times (when glucose is not changing rapidly).
The Prodigy Choice Test Strips are for use with the Prodigy Choice Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, palm, upper-arm, calf or thigh.
3. Special conditions for use statement(s):
- For over-the-counter use
- Not for neonatal use
- Not for screening or diagnosis of diabetes mellitus
- Not for use on critically ill patients, patients in shock, dehydrated patients or hyper-osmolar patients
- Prodigy Choice Blood Glucose Meter is for single-patient use only
- Alternative site testing (AST) testing should only be done during steady-state times (when glucose is not changing rapidly).
- AST should not be used to calibrate continuous glucose monitors (CGMs).
- AST should not be used for insulin dose calculations.
The following warning appears in the test strip insert, meter kit box, and owner’s manual regarding the low performance in lay-user accuracy:
CAUTION
Blood Glucose Meter Accuracy is the most important criteria in determining glucose meter quality. The Prodigy Choice® Blood Glucose Monitoring System is less accurate than most other blood glucose meters sold today. The Prodigy Choice® meter does not provide reliable accuracy readings beyond the following margins of error:
For glucose concentrations < 75 mg/dL, 95% of the results shall be within ± 15 mg/dL.
For glucose concentrations > 75 mg/dL, 95% of the results shall be within ± 20%.
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DO NOT USE THE PRODIGY CHOICE® TO CALCULATE INSULIN DOSAGES.
DO NOT USE THE PRODIGY CHOICE® TO CALIBRATE CONTINUOUS GLUCOSE MONITORS
The following warning appears on the test strip box:
The Prodigy Choice® Blood Glucose Monitoring System is less accurate than most other blood glucose meters sold today.
DO NOT USE THE PRODIGY CHOICE® TO CALCULATE INSULIN DOSAGES.
DO NOT USE THE PRODIGY CHOICE® TO CALIBRATE CONTINUOUS GLUCOSE MONITORS.
4. Special instrument requirements:
Prodigy Choice Blood Glucose Meter
I. Device Description:
The Prodigy Choice Blood Glucose Monitoring System is marketed as a meter only with a carrying case, battery, Owner's Manual, Quick Reference Guide, Logbook, and Warranty Card. The Prodigy Choice Blood Glucose Monitoring System is also marketed as a meter kit with a carrying case, battery, Owner's Manual, Quick Reference Guide, Logbook, and Warranty Card, Prodigy Lancing Device, Prodigy Lancets, Prodigy Choice Test Strips, and Prodigy Control Solution (1 level).
Prodigy Choice Blood Glucose Monitoring System consists of the following:
Prodigy Choice Blood Glucose Meter
Prodigy Choice Test Strips (Calibration code embedded on strip) - Glucose oxidase (Aspergillus sp.)
Prodigy Control Solution - (2 levels: low 30-50 mg/dL and high 200-300 mg/dL): Previously cleared in k060467
J. Substantial Equivalence Information:
1. Predicate device name(s):
Prodigy Voice BGMS
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2. Predicate 510(k) number(s):
k073118
3. Comparison with predicate:
| | Candidate Device | Predicate (k073118) |
| --- | --- | --- |
| Type | Prodigy Choice Blood Glucose Monitoring System | Prodigy Voice Blood Glucose Monitoring System |
| Indications for Use/Intended Use | The Prodigy Choice Blood Glucose Monitoring System is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and the following alternative sites: the palm, the forearm, the upper-arm, the calf and the thigh. It is intended for use by people with diabetes mellitus at home as an aid in monitoring the effectiveness of diabetes control. It is not intended for the diagnosis of or screening for diabetes mellitus. The alternative site testing in this system can be used only during steady-state blood glucose conditions. | Same |
| Detection Method | Amperometry | Same |
| Sample Type | Capillary whole blood | Same |
| Sample Sites | Finger, palm, forearm, upper-arm, calf, thigh | Same |
| Sample Volume | 0.7 μL | Same |
| Measurement Range | 20-600 mg/dL | Same |
| Test Strip | User verifies code embedded on test strip and displayed on screen matches the test strip vial | Same |
| Speaking Function | No | Yes |
| Reaction Time | 7 sec | Same |
| Reagent Enzyme | Glucose Oxidase | Same |
| Day Average | 7, 14, 21, 28 | 7, 14, 21, 28, 60, 90 |
| Identification of Control Solution and Results | User manually selects control solution button | |
| Hematocrit Range (%) | 20 - 60% | Same |
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| Test Strip Stability (open-vial) | 90 days | Same |
| --- | --- | --- |
## K. Standard/Guidance Document Referenced (if applicable):
ISO 15197:2003: In Vitro Diagnostic Test Systems-Requirements for Blood Glucose Monitoring Systems for Self-Testing in Managing Diabetes
NCCLS EP9-A: Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline
NCCLS EP5-A: Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline
ISO 14971: Medical Devices – Application of risk management to medical devices
60601-1-2: Medical electrical equipment – Part 1-1: General requirements for basic safety and essential performance – Collateral standard: Electromagnetic compatibility – Requirements and tests.
## L. Test Principle:
The test is based on the measurement of electrical current generated by the reaction of capillary whole blood glucose with glucose oxidase of the test strip. The meter measures the strength of the current which is proportional to the concentration of glucose present and displays the corresponding blood glucose level.
## M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Repeatability (Within-run)
The sponsor performed within-run precision studies using venous whole blood samples adjusted to give the following five glucose concentrations (30 - 50, 51 - 110, 111 - 150, 151 - 250, and 251 - 400 mg/dL). Each glucose level was analyzed in replicates of 10, using three test strip lots, and 10 meters for a total of 30 tests per each glucose level for each meter. The results are summarized below:
| Lot 1 | Interval 1 | Interval 2 | Interval 3 | Interval 4 | Interval 5 |
| --- | --- | --- | --- | --- | --- |
| | 30-50 mg/dL | 51-110 mg/dL | 111-150 mg/dL | 151-250 mg/dL | 251-400 mg/dL |
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| YSI | 43.1 | 81.8 | 135 | 201 | 318 |
| --- | --- | --- | --- | --- | --- |
| Mean | 43.3 | 80.4 | 137.7 | 197.4 | 321.6 |
| SD | 2.1 | 2.5 | 3.3 | 4.8 | 9.4 |
| %CV | 5.1 | 3.1 | 2.4 | 2.4 | 2.9 |
| n | 100 | 100 | 100 | 100 | 100 |
| Lot 2 | Interval 1 | Interval 2 | Interval 3 | Interval 4 | Interval 5 |
| --- | --- | --- | --- | --- | --- |
| | 30-50 mg/dL | 51-110 mg/dL | 111-150 mg/dL | 151-250 mg/dL | 251-400 mg/dL |
| YSI | 43.1 | 81.8 | 135 | 201 | 318 |
| Mean | 43.2 | 81.1 | 137.7 | 197.6 | 323.4 |
| SD | 2.2 | 2.5 | 3.5 | 5.1 | 9.5 |
| %CV | 5.1 | 3.1 | 2.6 | 2.6 | 2.9 |
| n | 100 | 100 | 100 | 100 | 100 |
| Lot 3 | Interval 1 | Interval 2 | Interval 3 | Interval 4 | Interval 5 |
| --- | --- | --- | --- | --- | --- |
| | 30-50 mg/dL | 51-110 mg/dL | 111-150 mg/dL | 151-250 mg/dL | 251-400 mg/dL |
| YSI | 43.1 | 81.8 | 135 | 201 | 318 |
| Mean | 43.7 | 80.3 | 137.8 | 198.7 | 322.2 |
| SD | 2.3 | 2.4 | 3.4 | 5.1 | 9.4 |
| %CV | 5.4 | 2.9 | 2.5 | 2.6 | 2.9 |
| n | 100 | 100 | 100 | 100 | 100 |
The combined within-run precision data for all three lots is described in the table below:
| | Interval 1 | Interval 2 | Interval 3 | Interval 4 | Interval 5 |
| --- | --- | --- | --- | --- | --- |
| [Conc.] | 30-50 mg/dL | 51-110 mg/dL | 111-150 mg/dL | 151-250 mg/dL | 251-400 mg/dL |
| Grand Mean (mg/dL) | 43.4 | 80.6 | 138 | 198 | 322 |
| Pooled SD (mg/dL) | 2.3 | 2.5 | 3.4 | 5.0 | 9.4 |
| Pooled %CV | 5.2 | 3.1 | 2.5 | 2.5 | 2.9 |
| n | 300 | 300 | 300 | 300 | 300 |
Intermediate Precision (Between Run)
Between Run imprecision was evaluated by testing 3 levels of control solutions (analyzed separately) using 3 test strip lots. Lot 1: 10 replicates using 5 different meters for 10 days, Lots 2 and 3: 5 replicates using 5 different meters for 10 days.
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Each of the control solutions were tested on all 5 meters each day. The results are summarized below.
| Lot 1 | Low | Normal | High |
| --- | --- | --- | --- |
| Conc. | 30 - 50 | 96 - 144 | 200-300 |
| YSI | 40.7 | 120 | 261 |
| Mean | 40.0 | 119.1 | 259.8 |
| SD | 1.98 | 3.9 | 11.8 |
| %CV | 4.9 | 3.3 | 4.5 |
| n | 500 | 500 | 500 |
| Lot 2 | Low | Normal | High |
| --- | --- | --- | --- |
| Conc. | 30 - 50 | 96 - 144 | 200-300 |
| YSI | 40.7 | 120 | 261 |
| Mean | 40.0 | 119.2 | 259.8 |
| SD | 1.98 | 4.4 | 11.9 |
| %CV | 5.0 | 3.7 | 4.6 |
| n | 250 | 250 | 250 |
| Lot 3 | Low | Normal | High |
| --- | --- | --- | --- |
| Conc. | 30 - 50 | 96 - 144 | 200-300 |
| YSI | 40.7 | 120 | 261 |
| Mean | 40.1 | 119.0 | 259.5 |
| SD | 2.03 | 4.3 | 11.3 |
| %CV | 5.1 | 3.6 | 4.4 |
| n | 250 | 250 | 250 |
The combined intermediate precision data for all three lots is described in the table below:
| Control Level | 1 | 2 | 3 | n |
| --- | --- | --- | --- | --- |
| [Conc.] mg/dL | 30 - 50 | 96 - 144 | 200-300 | |
| Grand Mean (mg/dL) | 40 | 119 | 260 | 1000 |
| Pooled SD (mg/dL) | 2.0 | 4.1 | 11.4 | 1000 |
| Pooled %CV | 5.0 | 3.5 | 4.4 | 1000 |
b. Linearity/assay reportable range:
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Linearity was evaluated using ten meters, three test strip lots and 13 glucose venous blood samples ranging in glucose concentrations (as measured by YSI) of 15, 22, 50, 90, 149, 251, 300, 349, 403, 455, 500, 601, 620 mg/dL. Each level was measured in 10 replicates per lot, per level for a total of 390 samples. Pooled and per lot data is below.
| Lot | 1 | 2 | 3 |
| --- | --- | --- | --- |
| N | 130 | 130 | 130 |
| Slope | 0.98 | 1.00 | 0.99 |
| y-intercept (mg/dL) | 3.74 | 2.40 | 2.67 |
| Correlation coefficient | 1.00 | 1.00 | 1.00 |
| Pooled | |
| --- | --- |
| N | 390 |
| Slope | 0.99 |
| y-intercept (mg/dL) | 2.94 |
| Correlation coefficient | 1.00 |
The results of the study support the sponsor's claimed glucose measurement range of 20 - 600 mg/dL.
c. Traceability, Stability (21 CFR § 211.166), Expected values (controls, calibrators, or methods):
Traceability: The assay is traceable to NIST SRM#917b
Controls: Open and closed vial stability was established in k060467.
Test Strip Stability
Protocol, acceptance criteria and summary results of real-time open and closed-vial, stability studies were performed on three lots of test strips at 4, 25, and 40 °C; with 10 and 85% relative humidity). Protocol, acceptance criteria support shelf-life claim (24 months), open-vial claim (90 days) in temperatures of 39 to 104 °F (4 to 40 °C) and 10 - 85% RH.
d. Detection limit:
See section M.1.b (linearity)
The reportable range is 20 to 600 mg/dL based on linearity/reportable range studies above. The low and high detection limits for this device have been set at 20 and 600
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mg/dL. Readings below 20 mg/dL and above 600 mg/dL will indicate a “Lo” and “Hi” on the meter display, respectively.
e. Analytical specificity:
Interference
An interference study was performed to evaluate the effects of endogenous and exogenous substances on the glucose test results generated by the Prodigy Choice Blood Glucose Monitoring System. Venous blood samples were collected into Lithium heparin tubes. Three glucose levels were achieved (50-100, 200-275, and 400-500 mg/dL) by adding a dextrose solution to the blood pool. Potential interferents were aliquotted into samples. The control pool (without an interfering compound) and test pool were measured by YSI and then on five meters using three test strip lots for each glucose concentration. The results are summarized below to show the highest concentration without significant interference (defined by the sponsor as ±10% bias).
| Substance | Highest concentration without interference (mg/dL) |
| --- | --- |
| Acetaminophen | 15 |
| Ascorbic Acid | 5.0 |
| Bilirubin | 90 |
| Cholesterol | 500 |
| Creatinine | 30 |
| Dopamine | 10 |
| Galactose | 900 |
| Gentisic Acid | 10 |
| Glutathione | 53 |
| Hydroxyurea | 4.0 |
| Ibuprofen | 50 |
| L-dopa | 10 |
| Maltose | 900 |
| Methyldopa | 3.0 |
| Salicylate | 60 |
| Tolazamide | 100 |
| Tolbutamide | 70 |
| Triglycerides | 2000 |
| Uric Acid | 14 |
| Xylose | 100 |
f. Assay cut-off:
- Not applicable
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# 2. Comparison studies:
a. Method comparison with predicate device:
# System Accuracy
To assess system accuracy, results from the Prodigy Choice Blood Glucose Monitoring System were compared to a reference method, YSI. Finger, palm, forearm, upper-arm, calf, and thigh capillary samples were collected by healthcare professionals from 100 participants with unaltered glucose concentrations ranging from $53.4 - 394\mathrm{mg / dL}$ (according to reference) were tested using three test strip lots. To obtain blood glucose concentrations $< 50$ $\mathrm{mg / dL}$ and $>400~\mathrm{mg / dL}$ , samples were allowed to glycolize or were spiked to achieve the desired glucose concentration. Ten samples were altered (5 glycolyzed, 5 spiked). The results relative to YSI are summarized in the tables below:
Finger
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 4/14 (29%) | 8/14 (57%) | 14/14 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 29/86 (34%) | 49/86 (57%) | 67/86 (78%) | 85/86 (99%) |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (fingerstick) | | | |
| | | n | 100 |
| | | Slope | 0.98 |
| | | y-int. (mg/dL) | 1.49 |
| | | r² | 0.95 |
| | | Range (mg/dL) | 53 – 394 |
Palm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 4/14 (29%) | 11/14 (79%) | 14/14 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 21/86 (24%) | 48/86 (56%) | 67/86 (78%) | 82/86 (95%) |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (Palm) | | | |
| | | n | 100 |
| | | Slope | 0.98 |
| | | y-int. (mg/dL) | 2.70 |
| | | r² | 0.95 |
| | | Range (mg/dL) | 53 – 394 |
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Forearm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 2/14 (14%) | 9/14 (64%) | 14/14 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 24/86 (28%) | 52/86 (60%) | 76/86 (88%) | 83/86 (97%) |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (forearm) | | | |
| | | n | 100 |
| | | Slope | 1.00 |
| | | y-int. (mg/dL) | -0.28 |
| | | r² | 0.95 |
| | | Range (mg/dL) | 53 – 394 |
Upper arm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 5/14 (36%) | 9/14 (64%) | 14/14 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 26/86 (30%) | 50/86 (58%) | 71/86 (83%) | 84/86 (98%) |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (Upper arm) | | | |
| | | n | 100 |
| | | Slope | 0.98 |
| | | y-int. (mg/dL) | 1.05 |
| | | r² | 0.95 |
| | | Range (mg/dL) | 53 – 394 |
Calf
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 2/14 (14%) | 7/14 (50%) | 14/14 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 26/86 (30%) | 46/86 (53%) | 71/86 (83%) | 85/86 (99%) |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (Calf) | | | |
| | | n | 100 |
| | | Slope | 1.00 |
| | | y-int. (mg/dL) | 0.49 |
| | | r² | 0.95 |
| | | Range (mg/dL) | 53 – 394 |
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Thigh
| For glucose concentrations < 75 mg/dL | | | | |
| --- | --- | --- | --- | --- |
| within ± 5 mg/dL | | within ± 10 mg/dL | | within ± 15 mg/dL |
| 7/14 (50%) | | 10/14 (71%) | | 14/14 (100%) |
| For glucose concentrations ≥ 75 mg/dL | | | | |
| within ± 5 % | within ± 10 % | | within ± 15 % | |
| 21/86 (24%) | 49/86 (57%) | | 71/86 (83%) | |
| Accuracy of Prodigy Choice (HCP) compared to YSI using capillary whole blood (Thigh) | | | | |
| | | | n | 100 |
| | | | Slope | 0.98 |
| | | | y-int. (mg/dL) | 3.55 |
| | | | r² | 0.96 |
| | | | Range (mg/dL) | 53 – 394 |
b. Matrix comparison:
- Not applicable
3. Clinical studies:
a. Clinical Sensitivity:
- Not applicable
b. Clinical specificity:
- Not applicable
c. Other clinical supportive data (when a. and b. are not applicable):
User Performance Study
To assess the performance of the Prodigy Choice Blood Glucose Monitoring System in the hands of the lay-users the sponsor performed a study with 151 lay-user participants, who collected 151 each of finger, palm, forearm, upper-arm, calf, and thigh capillary samples using only English-written labeling materials with no other instructions or coaching. Results from 3 test strip lots and 300 meters were analyzed by comparing blood glucose results from the Prodigy Choice meter obtained by the lay-user against the YSI reference value. The glucose concentration of the samples ranged from 50.3 to 355 mg/dL as measured by YSI. The results are summarized below.
The data obtained in the lay user study were not as accurate as meters on the market. Therefore the sponsor added the following caution to the test strip insert, meter manual, and the meter kit box:
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# CAUTION
Blood Glucose Meter Accuracy is the most important criteria in determining glucose meter quality. The Prodigy Choice® Blood Glucose Monitoring System is less accurate than most other blood glucose meters sold today. The Prodigy Choice® meter does not provide reliable accuracy readings beyond the following margins of error:
For glucose concentrations < 75 mg/dL, 95% of the results shall be within ± 15 mg/dL.
For glucose concentrations > 75 mg/dL, 95% of the results shall be within ± 20%. DO NOT USE THE PRODIGY CHOICE® TO CALCULATE INSULIN DOSAGES.
DO NOT USE THE PRODIGY CHOICE® TO CALIBRATE CONTINUOUS GLUCOSE MONITORS
The following warning appears on the test strip box:
The Prodigy Choice® Blood Glucose Monitoring System is less accurate than most other blood glucose meters sold today.
DO NOT USE THE PRODIGY CHOICE® TO CALCULATE INSULIN DOSAGES.
DO NOT USE THE PRODIGY CHOICE® TO CALIBRATE CONTINUOUS GLUCOSE MONITORS.
Finger
| For glucose concentrations < 75 mg/dL | | | | |
| --- | --- | --- | --- | --- |
| within ± 5 mg/dL | | within ± 10 mg/dL | | within ± 15 mg/dL |
| 2/15 (13%) | | 11/15 (73%) | | 15/15 (100%) |
| For glucose concentrations ≥ 75 mg/dL | | | | |
| within ± 5 % | within ± 10 % | | within ± 15 % | |
| 45/136 (33%) | 70/136 (51%) | | 104/136 (76%) | |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (fingerstick) | | | | |
| | | | n | 151 |
| | | | Slope | 1.0238 |
| | | | y-int. (mg/dL) | -3.5685 |
| | | | r² | 0.9417 |
| | | | Range (mg/dL) | 50.3 - 355 |
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Palm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 4/15 (27%) | 14/15 (93%) | 15/15 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 31/136 (23%) | 64/136 (47%) | 98/136 (72%) | 132/136 (97%) |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (Palm) | | | |
| | | n | 151 |
| | | Slope | 0.9919 |
| | | y-int. (mg/dL) | -1.041 |
| | | r² | 0.9259 |
| | | Range (mg/dL) | 50.3 - 355 |
Forearm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 8/15 (53%) | 10/15 (67%) | 15/15 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 28/136 (21%) | 73/136 (54%) | 107/136 (79%) | 130/136 (96%) |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (forearm) | | | |
| | | n | 151 |
| | | Slope | 0.9994 |
| | | y-int. (mg/dL) | -2.8697 |
| | | r² | 0.9376 |
| | | Range (mg/dL) | 50.3 - 355 |
Upper Arm
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 5/15 (33%) | 11/15 (73%) | 15/15 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 51/136 (38%) | 94/136 (69%) | 123/136 (90%) | 134/136 (99%) |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (Upper arm) | | | |
| | | n | 151 |
| | | Slope | 0.9645 |
| | | y-int. (mg/dL) | -3.221 |
| | | r² | 0.9718 |
| | | Range (mg/dL) | 50.3 - 355 |
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Calf
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 3/15 (20%) | 9/15 (60%) | 15/15 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 61/136 (45%) | 104/136 (76%) | 128/136 (94%) | 136/136 (100%) |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (Calf) | | | |
| | | n | 151 |
| | | Slope | 0.97 |
| | | y-int. (mg/dL) | -3.085 |
| | | r² | 0.9734 |
| | | Range (mg/dL) | 50.3 - 355 |
Thigh
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL | |
| 5/15 (33%) | 10/15 (67%) | 15/15 (100%) | |
| For glucose concentrations ≥ 75 mg/dL | | | |
| within ± 5 % | within ± 10 % | within ± 15 % | within ± 20 % |
| 56/136 (41%) | 99/136 (73%) | 127/136 (93%) | 135/136 (99%) |
| Accuracy of Prodigy Choice (Lay-user) compared to YSI using capillary whole blood (Thigh) | | | |
| | | n | 151 |
| | | Slope | 1.0194 |
| | | y-int. (mg/dL) | -6.7856 |
| | | r² | 0.9674 |
| | | Range (mg/dL) | 50.3 - 355 |
# 4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
| Status | Range |
| --- | --- |
| Preprandial plasma glucose (before a meal) | 70-100 mg/dL |
| Postprandial plasma glucose (after a meal) | <140 mg/dL |
American Diabetes Association. Standards of medical care in diabetes - 2012. Diabetes Care. 2012;35(Supp 1):S11-S63
{15}
16
N. Instrument Name:
Prodigy Choice meter
O. System Descriptions:
1. Modes of Operation:
Each strip is single use and requires a sample volume of 0.7 µL.
Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?
Yes ______ or No ☐
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?
Yes ______ or No ☐.
2. Software
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ or No ______
3. Specimen Identification:
There is no sample identification function with this device. Samples are applied directly to the test strip as they are collected.
4. Specimen Sampling and Handling:
The glucose test is intended to be used with capillary whole blood from the finger, palm, forearm, upper-arm, calf and thigh only. The whole blood sample is applied directly to the test strip by capillary action.
5. Calibration:
The meter is an auto-coding meter. No coding is required by the user. The user is required to verify that the code displayed on the meter and read off the test strip accurately reflects the code on the test strip vial.
6. Quality Control:
Two levels of control glucose solution are available. One level is sold with the
{16}
meter as a kit. The user has to change the setting on the meter to control so that the result is not saved.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
1. Hematocrit Study: The effect of different hematocrit levels on the performance of the Prodigy Choice Blood Glucose System was evaluated using venous whole blood samples with hematocrit levels 15, 20, 30, 40, 60 and 65 %, and spiked or glycolyzed to achieve 6 glucose concentrations ranging from 50 to 500 mg/dL (30-50, 51-110, 111-150, 151-250, 251-400 mg/dL). Each sample was then tested 20 times using 10 Prodigy Choice meters and two lots of test strips. The meter values were compared with those obtained from average YSI analyzer values at the tested hematocrit level and normal hematocrit (40%). The percent biases relative to YSI were acceptable within the claimed hematocrit range of 20 to 60%.
2. Altitude study: Venous whole blood samples collected and adjusted to obtain 5 glucose concentrations of 30-50, 51-110, 111-150, 151-250, and 251-400 mg/dL were tested at 298, 2,920, 4,790, 6,234, 8,563, and 11,161 feet above sea level. The study included 3 meters and 3 test strip lots. Results were compared to YSI values. The results demonstrate acceptable bias and indicate acceptable performance to the claimed altitude of 11,161 ft. The sponsor has claimed an altitude of 10,742 feet in their labeling.
3. Temperature and Humidity studies: The sponsor performed temperature and humidity studies using venous blood samples with glucose concentrations of 30-50, 96-144, and 280-420 mg/dL to evaluate temperatures ranging from 10 to 40°C (50 to 104 °F) and relative humidity from 10% to 85%. Meter results were compared to YSI values. Four temperature and humidity combinations were tested including low temperature/low humidity, low temperature/high humidity, high temperature/low humidity, and high temperature/high humidity. No significant bias (relative to YSI) was observed with the temperature and humidity combinations tested. The results support a temperature claim of 10 to 40°C (50 to 104 °F) with relative humidity of 10 to 85%.
4. Sample Volume: The sponsor performed a study to verify the test strip minimum sample volume requirement (0.7 μL) and the test strip fill error requirement established for the Prodigy Choice Blood Glucose Monitoring System. Blood samples with glucose concentrations of 30-50, 51-110, 111-150, 151-250, and 251-400 mg/dL were tested at seven sample volumes (0.5, 0.6, 0.7, 0.8, 1.0, 1.2, 1.5 μL) and values obtained were compared to YSI values. Results support the claimed minimum sample volume of 0.7 μL.
5. Readability Evaluation: SMOG readability assessment was conducted and the results demonstrated that the User Manual and test strip package insert were written at the 8th grade level and below.
17
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6. Electromagnetic compatibility (EMC) testing was performed by Audix Technology Corporation., Taipei Hsien, Taiwan. Verification of Compliance certificates were provided.. The results are for the Prodigy Preferred Meter, model Prodigy-C which is identical to the Prodigy Choice. The only difference is the location of the strip connector touch pin on the test strip.
7. Infection Control Studies: The meter is intended for single-patient use only. The Dispatch Hospital Cleaner Disinfection Towel with Bleach (EPA registration #56392-8) was used to validate disinfection efficacy using the PMA approved (P030049) HBV antigen assay demonstrating the absence of HBV antigen on meter surface coupons.
8. Robustness: The sponsor demonstrated that there was no change in performance (compared to YSI) or in the external materials of the meter after 10,950 cleaning and disinfection cycles (one cycle includes one cleaning wipe plus one disinfecting wipe). Labeling was reviewed for adequate instructions for the validated cleaning and disinfection procedures.
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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Learn the FDA Browser
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.