VERIZON WIRELESS CONVERGED HEALTH MANAGEMENT DEVICE
Applicant
Cellco Partnership D/B/A Verizon Wireless
Product Code
DRG · Cardiovascular
Decision Date
Feb 14, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2910
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
The CHM Device is a remote monitoring software solution intended to collect and store biometric data from physiological measurement devices intended for use in the home. The CHM Device also allows for the automated transmission of the biometric data to a remote secure server via an existing mobile telecommunications and/or internet infrastructure. The stored biometric data is accessible by clinicians for analysis and intervention. Patients can also review the stored biometric data and receive educational and motivational content from clinicians. The CHM Device can be used as a standalone device or in conjunction with supported patient monitoring devices, such as a glucometer, weight scale, pulse oximeter, and blood pressure monitor. The CHM Device is not intended for use in surgical rooms, intensive care units, intermediate or step-down units or emergency vehicles. It is not interpretive, nor is it intended for diagnosis or as a replacement for the oversight of healthcare professionals. It does not provide real-time or emergency monitoring.
Device Story
Software platform for remote monitoring; collects/stores biometric data from home-use physiological measurement devices (glucometers, scales, pulse oximeters, BP monitors). Transmits data via mobile/internet infrastructure to secure remote server. Clinicians access data for analysis/intervention; patients view data and receive educational/motivational content. Used in home environment; operated by patients and clinicians. Not interpretive; does not provide diagnosis or real-time/emergency monitoring. Facilitates communication between patient and healthcare provider.
Clinical Evidence
Bench testing only. Software verification and validation activities, including regression and usability testing, were performed. Verification confirmed accurate data transfer from supported glucometers (Telcare and Genesis Health) to the CHM platform. All predetermined acceptance criteria were met.
Technological Characteristics
Software platform for data collection, storage, and display. Utilizes existing internet and mobile telecommunications infrastructure for automated data transmission to a remote secure server. Supports integration with external patient monitoring devices. Provides clinician-to-patient messaging and tasking functionality.
Indications for Use
Indicated for home-based remote monitoring of biometric data collected from physiological measurement devices. Intended for patients requiring data transmission to clinicians for review and intervention. Not for use in surgical, ICU, step-down, or emergency settings. Not for diagnostic use or real-time/emergency monitoring.
Regulatory Classification
Identification
A radiofrequency physiological signal transmitter and receiver is a device used to condition a physiological signal so that it can be transmitted via radiofrequency from one location to another, e.g., a central monitoring station. The received signal is reconditioned by the device into its original format so that it can be displayed.
Predicate Devices
Verizon Wireless Converged Health Management Device (K122458)
Ideal Life Inc., Weight Scale (Class I, 510(k) Exempt)
Ideal Life Inc. Communication Gateway Ideal Life Pod ILP (K080538)
Telecare Inc., Blood Glucose Monitoring System (K110571)
Genesis Health Technologies, Blood Glucose Monitoring System (K121224)
Submission Summary (Full Text)
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# FEB 1 4 2014
K134004 Page 1 of 3
#### 510(k) SUMMARY
### Verizon Wireless Converged Health Management Device
Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared
Verizon Wireless One Verizon Way Basking Ridge, NJ 07920 Phone: 202-515-2454 Facsimile: 202-289-6781
Contact Person: Lolita Forbes, Assistant General Counsel - Mobile Health
December 27, 2013 Date Prepared:
#### Name of Device and Name/Address of Sponsor
Verizon Wireless Converged Health Management Device
Verizon Wireless One Verizon Way Basking Ridge, NJ 07920
#### Common or Usual Name: Telemedicine System
Classification Name: Radiofrequency Physiological Signal Transmitter and Receiver
#### Predicate Devices:
The Verizon Wireless Converged Health Management Device is a modification to K122458 Verizon Wireless Converged Health Management Device.
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K134004 Page 2 of 3
#### Intended Use
The CHM Device is a remote monitoring software solution intended to collect and store biometric data from physiological measurement devices intended for use in the home. The CHM Device also allows for the automated transmission of the biometric data to a remote secure server via an existing mobile telecommunications and/or internet infrastructure.
The stored biometric data is accessible by clinicians for analysis and intervention. Patients can also review the stored biometric data and receive educational and motivational content from clinicians.
The CHM Device can be used as a standalone device or in conjunction with supported patient monitoring devices, such as a glucometer, weight scale, pulse oximeter, and blood pressure monitor.
The CHM Device is not intended for use in surgical rooms, intensive care units, intermediate or step-down units or emergency vehicles. It is not interpretive, nor is it intended for diagnosis or as a replacement for the oversight of healthcare professionals. It does not provide real-time or emergency monitoring.
#### Technological Characteristics
The CHM is a software platform for the collection and display of biometric data, primarily from externally supported patient monitoring devices, both to the patient and to the clinician. The CHM Device may also be used as a standalone device. The CHM Device uses existing Internet and telecommunications architecture (cell phones and computers) for the automated transmission of medical data to a remote secure server from where it can be viewed remotely by clinicians and patients for the purposes of storage and basic analysis. The CHM Device also provides educational and motivationalities allowing the clinician to send tasks, recommendations, surveys, and educational and motivational messages to patients.
The Verizon Wireless Converged Health Management Device may be used in conjunction with the following externally supported patient monitoring devices:
- . Ideal Life Inc., Blood Pressure Cuff (K060504)
- � Ideal Life Inc., Glucose Monitor Model GMM0001 (K080283)
- . Ideal Life Inc. SpO2 Pulse Oximeter (K070371)
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## K134004 Page 3 of 3
- Ideal Life Inc., Weight Scale (Class I, 510(k) Exempt) .
- Ideal Life Inc. Communication Gateway Ideal Life Pod ILP (K080538) .
- . Telecare Inc., Blood Glucose Monitoring System (K110571)
- . Genesis Health Technologies, Blood Glucose Monitoring System (K121224)
### Performance Data
As part of its software verification and validation activities, regression and usability testing was performed to ensure that the changes to the software have not introduced new faults and that a change to one part of the software does not affect other parts of the software. Additional verification and verification activities were performed to ensure that the biometric data was transferred accurately from the Telcare and Genesis Health glucometers server infrastructure into the CHM platform. All verification and validation activities, as required by the risk analysis, were performed and the results demonstrated that the predetermined acceptance criteria were met.
### Substantial Equivalence
The Verizon Wireless Converged Health Management Device has the same intended Use and indications for use and its predicate, Verizon Wireless Converged Health Management Device (K122458). It also has identical technological characteristics as the predicate device. Software verification and validation testing demonstrate that the Verizon Wireless Converged Health Management Device performs as intended and that the differences between the Verizon Wireless Converged Health Management Device and its predicate do not raise new questions of safety or effectivenesss.
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three lines representing its wings, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged in a circular pattern around the eagle. The text is in all caps and appears to be in a sans-serif font. The logo is black and white.
#### Public Health Service
Food and Drug Administration 10903 New Hamoshire Avenue Document Control Center - WO66-G609 Silver Spring, MI) 20993-002
February 14, 2014
Cellco Partnership D/b/a Verizon Wireless Ms. Lolita Forbes Assistance General Counsel One Verizon Way Basking Ridge, NJ 07920 US
Re: K134004
> Trade/Device Name: Verizon Wireless Converged Health Management Device Regulation Number: 21 CFR 870.2910 Regulation Name: Radiofrequency Physiological Signal Transmitter and Receiver Regulatory Class: Class II (two) Product Code: DRG Dated: December 27, 2013 Received: December 27, 2013
Dear Ms. Lolita Forbes:
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. 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
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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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. 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 go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htmfor the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (800) 638 2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Owen-Paris-S
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
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K134004 Page 1 of 1
#### Indications for Use Statement
510(k) Number (if known):
Device Name: Verizon Wireless Converged Health Management System
Indications for Use:
The CHM Device is a remote monitoring software solution intended to collect and store biometric data from physiological measurement devices intended for use in the home. The CHM Device also allows for the automated transmission of the biometric data to a remote secure server via an existing mobile telecommunications and/or internet infrastructure.
The stored biometric data is accessible by clinicians for analysis and intervention. Patients can also review the stored biometric data and receive educational and motivational content from clinicians.
The CHM Device can be used as a standalone device or in conjunction with supported patient monitoring devices, such as a glucometer, weight scale, pulse oximeter, and blood pressure monitor.
The CHM Device is not intended for use in surgical rooms, intensive care units, intermediate or step-down units or emergency vehicles. It is not interpretive, nor is it intended for diagnosis or as a replacement for the oversight of healthcare professionals. It does not provide real-time or emergency monitoring.
Prescription Use _____________________________________________________________________________________________________________________________________________________________ (Per 21 C.F.R. 801 Subpart D) AND/OR
Over-The-Counter Use_ (Per 21 C.F.R. 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Page _1_ of _1_
Digitally signed by
Owen Faris -S
Date: 2014.02.14
11:51:21-05'00'
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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.
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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
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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.