Software as a Medical Device, Pediatric, 3rd-Party Reviewed
Indications for Use
AWARE™ is intended for use in the data collection, presentation, management and storage of patient information, and is used in conjunction with independent patient bedside devices and Hospital Information Systems connected via a network. This device is indicated for use by health care providers when providing patient care in an ICU and Emergency Department healthcare setting. AWARE is indicated for use in the clinical care of hospitalized adult and pediatric patient (newborn, infant, child, and adolescent) with or at risk of critical illness. AWARE is not an Electronic Medical Record (EMR) application and AWARE use is not intended to replace electronic data management systems utilized by healthcare institutions such as an EMR, LIMS (Laboratory Information Management System), PACS (Picture Archive Communication), patient medical device monitoring and alarm systems. AWARE is not a medical Alarm System and AWARE use is not intended to replace medical Alarm Systems (including monitors) within a healthcare institution. AWARE provides no auditory alerts nor does it provide monitoring and alerting of life threatening situations such as a ventilator disconnection, asystolia, or arrhythmia. AWARE provides a visual ICU-based status of events reported from the institutions' source systems to aid in the clinical care decision process.
Device Story
AWARE is stand-alone software for ICU/ED clinicians; aggregates patient data from existing hospital information systems and bedside devices via network; organizes data into systemic organ-based packages; provides visual status of events to aid clinical decision-making; does not perform EMR functions, patient admission/discharge, or research analytics; does not provide auditory alarms or monitor life-threatening conditions; serves as a decision support tool to reduce information overload; clinicians use interface to view bundled patient information; benefits include improved efficiency and informed decision-making.
Clinical Evidence
No clinical data. Bench testing only, including system-level, performance, and safety testing based on hazard analysis. Usability was supported by cited literature evaluating user interfaces in critical care settings.
Technological Characteristics
Software-based clinical decision support; utilizes Microsoft SQL, existing IT infrastructure, and rules engine technology; networked connectivity to hospital source systems; complies with ISO 14971 (risk management), IEC 62304 (software lifecycle), and IEC 60601-1-8 (alarm systems).
Indications for Use
Indicated for hospitalized adult and pediatric patients (newborn, infant, child, adolescent) with or at risk of critical illness in ICU and Emergency Department settings.
Regulatory Classification
Identification
A cardiac monitor (including cardiotachometer and rate alarm) is a device used to measure the heart rate from an analog signal produced by an electrocardiograph, vectorcardiograph, or blood pressure monitor. This device may sound an alarm when the heart rate falls outside preset upper and lower limits.
Predicate Devices
MetaVision Graphical Patient Information System, iMDsoft, Ltd. (K012349)
Intellivue Clinical Information Portfolio (ICIP), Philips Medical Systems (K100272)
Submission Summary (Full Text)
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three stripes forming its body and wings. The eagle faces right and appears to be in flight. Encircling the eagle is the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 2, 2015
Ambient Clinical Analytics % Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1394 25th Street, NW Buffalo, Minnesota 55313
K143372 Re: Trade/Device Name: Aware Regulation Number: 21 CFR 870.2300 Regulation Name: Cardiac Monitor (Including Cardiotachometer and Rate Alarm) Regulatory Class: Class II Product Code: MWI Dated: January 19, 2015 Received: January 20, 2015
Dear Mark Job,
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 comply
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Page 2 - Mark Job
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/McdicalDcvices/ResourcesforYou/Industry/default.htm. 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 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 Industry and Consumer Education 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,
Mitchell Stein
forBram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K143372
Device Name AWARETM
### Indications for Use (Describe)
A WARE™ is intended for use in the data collection, management and storage of patient information, and is used in conjunction with independent patient bedside devices and Hospital Information Systems connected via a network. This device is indicated for use by health care providing patient care in an ICU and Emergency Department healthcare setting.
A WARE is indicated for use in the clinical care of hospitalized adult and pediatric patient (newborn, infant, child, and adolescent) with or at risk of critical illness.
A WARE is not an Electronic Medical Record (EMR) application and AWARE use is not intended to replace electronic data management systems utilized by healthcare institutions such as an EMR, LIMS (Laboratory Information Management System), PACS (Picture Archive Communication), patient medical device monitoring and alarm systems.
A WARE is not a medical Alarm System and AWARE use is not intended to replace medical Alarm Systems (including monitors) within a healthcare institution. AWARE provides no auditory alerts nor does it provide monitoring and alerting of life threatening situations such as a ventilator disconnection, asystolia, or arthythmia. AWARE provides a visual ICUbased status of events reported from the institutions' source systems to aid in the clinical care decision process.
| Type of Use (Select one or both, as applicable) | | |
|-------------------------------------------------|---------------------------------------------|--|
| > Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) | |
| CONTINUE ON A SEPARATE PAGE IF NEEDED. | | |
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Image /page/3/Picture/0 description: The image shows a logo for a company called "Ambient Clinical Analytics". The logo features a large letter "A" with a circle around it, followed by the word "AMBIENT" in bold, uppercase letters. Below the word "AMBIENT", the words "CLINICAL ANALYTICS" are written in smaller, uppercase letters.
K143372
# 510(k) Summary AWARE™ 1.0
## 1. Date Prepared: 2015-03-24
## 2. Owner:
Allen Berning Ambient Clinical Analytics 221 1st Avenue SW Rochester, MN 55902 United States Phone: 952-240-6775 Email: info@ambientclinical.com
### 3. Contact person:
Amy Fowler DuVal & Associates, P.A. 825 Nicollet Mall, Suite 1820 Minneapolis, MN 55402 United States Phone: 612-338-7170, ext. 4 Email: fowler@duvalfdalaw.com
- 4. Trade name: AWARETM Version 1.0
Common/Usual Name is: Clinical Decision Support Software
Classification Name: Cardiac monitor (including cardiotachometer and rate alarm) Monitor, Physiological, Patient (Without Arrhythmia Detection or Alarms)
Product code: MWI
- 5. Predicate devices:
a. MetaVision Graphical Patient Information System, iMDsoft, Ltd. Cleared for marketing as K012349 on January 29th, 2002, Product Code MWI.
b. Intellivue Clinical Information Portfolio (ICIP), Philips Medical Systems. Cleared for marketing as K100272 on April 14th, 2010, Product Codes DXJ, NSX.
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Image /page/4/Picture/0 description: The image shows the logo for Ambient Clinical Analytics. The logo features a large letter A with a circle around it, followed by the word "AMBIENT" in bold, uppercase letters. Below "AMBIENT" are the words "CLINICAL ANALYTICS" in a smaller font size.
- 6. Device Description:
AWARE ™ is a stand-alone software product used by professional care providers in ICU and Emergency Department healthcare settings for the presentation, collection, management and storage of patient information. The AWARE application was created based on healthcare provider requirements to provide patient data through the use of an interface with built-in tools, practice surveillance, and decision support. The philosophy behind the system is the following:
- Identify and present relevant information from an institution's currently deployed patient . information systems
- Bundle related data into discrete systemic organ based packages to facilitate efficient informed ● decision making in a healthcare setting.
- Automatically collect and display critical patient data ●
- 7. Intended Use/Indications for Use:
AWARE™ is intended for use in the data collection, presentation, management and storage of patient information, and is used in conjunction with independent patient bedside devices and Hospital Information Systems connected via a network. This device is indicated for use by health care providers when providing patient care in an ICU and Emergency Department healthcare setting.
AWARE is indicated for use in the clinical care of hospitalized adult and pediatric patient (newborn, infant, child, and adolescent) with or at risk of critical illness.
AWARE is not an Electronic Medical Record (EMR) application and AWARE use is not intended to replace electronic data management systems utilized by healthcare institutions such as an EMR, LIMS (Laboratory Information Management System), PACS (Picture Archive Communication), patient medical device monitoring and alarm systems.
AWARE is not a medical Alarm System and AWARE use is not intended to replace medical Alarm Systems (including monitors) within a healthcare institution. AWARE provides no auditory alerts nor does it provide monitoring and alerting of life threatening situations such as a ventilator disconnection, asystolia, or arrhythmia. AWARE provides a visual ICU-based status of events reported from the institutions' source systems to aid in the clinical care decision process.
- 8. Summary of Technological Characteristics of AWARE™ compared to predicate devices:
The technological characteristics of AWARE™ and the predicate devices are the same. All devices use Microsoft SQL, existing IT infrastructure, and rules engine technology. All employ software and computers to interact with a healthcare institution's source electronic data systems via a network to collect, display, manage and store patient data. The way the system is used for generating patient records, computation of drug and fluid dosage and research tasks is determined by the health care providers, in terms of their environment and requirements.
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Image /page/5/Picture/0 description: The image shows the logo for Ambient Ecological Analytics. The logo features a large letter 'A' with a partial circle around it, followed by the word 'AMBIENT' in bold, uppercase letters. Below 'AMBIENT' is the phrase 'ECOLOGICAL ANALYTICS' in a smaller, less bold font.
The predicate application is resident on a workstation that provides for data input and patient data display to health care professionals. Typically, the predicate system comprises several workstations connected via a network system to one or more servers. Data is stored and managed by servers. The predicate system network can communicate with a number of remotely located patient care units.
The predicate applications "look and feel" is similar to Electronic Medical Records presentation of data, AWARE™ has a user interface designed from clinician requirements and that provide physiological systemic organ based views. The predications perform patient admit and discharge functions and associated data input screens for billing, AWARE™ doesn't perform patient admit and discharge functions. The iMD system provides Research analytics and reporting, A WARE™ does not support Research analytics and reporting. The predicate Graphical Patient Information Systems supports 15 languages, AWARETM supports English.
## 9. Non-clinical Performance:
Testing involved system level tests, performance tests and safety testing based on hazard analysis. Cybersecurity issues have been addressed. In addition to the verification and validation testing activities executed by Ambient Clinical Analytics to establish the performance and functionality of A WARE™ and the predicate devices, several standards were utilized:
| 14971 | Medical Devices – Applications Of Risk Management To Medical Devices |
|-----------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 62304 | Medical Device Software - Software Life Cycle Processes |
| 60601-1-8 | Medical Electrical Equipment - Part 1-8: General Requirements For Basic<br>Safety and Essential Performance – Collateral Standard: General<br>Requirements, Tests and Guidance For Alarm Systems In Medical Electrical<br>Equipment And Medical Electrical Systems |
Usability testing was independently conducted and published:
Pickering BW, Herasevich V, Ahmed A, Gajic O. Novel Representation of Clinical Information in the ICU: Developing User Interfaces which Reduce Information Overload. Appl Clin Inform. 2010:1(2):116-31.doi:10.4338/ACI-2009-12-CR-0027. PMID: 23616831
Ahmed A, Chandra S, Herasevich V, Gajic O, Pickering BW. The effect of two different electronic health record user interfaces on intensive care provider task load, errors of cognition, and performance. Crit Care Med. 2011;39(7):1626-34. doi:10.1097/CCM.0b013e31821858a0. PMID: 21478739
JM Litell, TW Suther, CJ Ridgeway, IC Tiong, BW Pickering, V. Herasevich Representation of Organ System Domains in a Novel Critical Care EMR Interface: Implications for Effective Partnership Between Clinicians and Design Professionals. AMIA 2012 proceedings.
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Image /page/6/Picture/0 description: The image shows the logo for Ambient Clinical Analytics. The logo features a stylized letter "A" with a partial circle around it, followed by the words "AMBIENT" in bold, uppercase letters. Below "AMBIENT" is the phrase "CLINICAL ANALYTICS" in smaller, uppercase letters.
Marc D, Pickering B, Harder K, Herasevich V. Interpretation of graphical icons in a critical care EMR interface. AMIA 2013 proceedings.
Marc D, Thongprayoon C, et al. Two interfaces cognitive load efficiency user sat Comparing Accuracy, Efficiency, and User satisfaction of Two EMR. AMIA 2014 proceedings.
- 10. Clinical Performance:
Not applicable.
- 11. Conclusions from Non-clinical Performance Testing:
The AWARE™ 510(k) package and results on non-clinical testing demonstrate AWARE™ is substantially equivalent to the predicate devices, the iMDsoft MetaVision Graphical Patient Information System and the Philips Intellivue Clinical Information Portfolio.
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Part 1 — Search, results, and everyday workflows 16 min
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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.
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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.