Xpert Xpress Flu, Xpert Nasopharyngeal Sample Collection Kit, Xpert Nasal Sample Collection Kit, GeneXpert Dx Systems (GX-I, GX-II, GX-IV, GX-XVI), GeneXpert Infinity-48S System and GeneXpert Infinity-80 System
Applicant
Cepheid
Product Code
OCC · Microbiology
Decision Date
Aug 15, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.3980
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K181289 · Aug 15, 2018
Xpert Xpress Flu, Xpert Nasopharyngeal Sample Collection Kit, Xpert Nasal Sample Collection Kit, GeneXpert Dx Systems (GX-I, GX-II, GX-IV, GX-XVI), GeneXpert Infinity-48S System and GeneXpert Infinity-80 System
Cepheid
Consecutively collected, frozen clinical specimens from previous influenza seasons
Frozen clinical specimens were used to supplement the prospective clinical study population to ensure sufficient sample size for performance evaluation during periods of low influenza prevalence.
Xpert Xpress Flu Assay Clinical Comparison Study; Multi-center clinical study (prospective and retrospective components); Follow-up/Duration: 2015-2016 and 2016-2017 influenza seasons; Study Period: 2015-2017
Individuals exhibiting signs and symptoms of respiratory infection; Sample Size: 2051 NP swab specimens (912 retrospective/frozen); 1598 NS specimens; Number of Sites: 11 institutions (NP swab); 14 institutions (NS)
FDA-cleared molecular comparator assay
Positive Percent Agreement (PPA) and Negative Percent Agreement (NPA)
Indications for Use
The Cepheid Xpert® Xpress Flu Assay, performed on the GeneXpert® Instrument Systems, is an automated, multiplex real-time, reverse transcriptase polymerase chain reaction (RT-PCR) assay intended for the in vitro qualitative detection and differentiation of influenza A and influenza B viral RNA. The Xpert Xpress Flu Assay uses nasopharyngeal (NP) swab and nasal swab (NS) specimens collected from patients with signs and symptoms of respiratory infection. The Xpert Xpress Flu Assay is intended as an aid in the diagnosis of influenza infections in conjunction with clinical and epidemiological risk factors. Negative results do not preclude influenza virus infection and should not be used as the sole basis for treatment or other patient management decisions. Performance characteristics for influenza A were established during the 2015-2016 influenza season for NP swab specimens and the 2016-2017 influenza season for NS specimens. When other novel influenza A viruses are emerging, performance characteristics may vary. If infection with a novel influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent influenza viruses and sent to state or local health departments for testing. Viral culture should not be attempted in these cases unless a BSL 3+ facility is available to receive and culture specimens.
Device Story
Xpert Xpress Flu Assay is an automated, in vitro diagnostic test for qualitative detection/differentiation of influenza A and B viral RNA. Input: nasopharyngeal or nasal swab specimens collected in viral transport medium. Operation: specimen transferred to GeneXpert cartridge; GeneXpert Instrument System performs automated sample processing and real-time RT-PCR. Output: qualitative test results generated in ~30 minutes. Used in clinical laboratory settings; operated by laboratory personnel. Results aid clinicians in diagnosing influenza infections alongside clinical/epidemiological risk factors. Benefits: rapid, automated diagnosis to inform patient management decisions.
Clinical Evidence
Clinical study evaluated performance at 11-14 U.S. institutions using 2051 NP swabs and 1598 NS specimens. Combined NP swab PPA/NPA: 98.1%/98.8% (Flu A), 100%/99.1% (Flu B). NS specimen PPA/NPA: 98.9%/97.6% (Flu A), 98.4%/99.3% (Flu B). Comparator: FDA-cleared molecular assay. Study included fresh and frozen specimens.
Technological Characteristics
Multiplex real-time RT-PCR; targets influenza A (M, PB2, PA genes) and influenza B (M, NS1, NS2 genes). Integrated sample prep via ultrasonic lysis and syringe-driven fluidics in single-use cartridges. I-CORE thermocycler. Software-based automated interpretation of fluorescent signals. Standalone/networked GeneXpert Dx or Infinity systems.
Indications for Use
Indicated for patients with signs and symptoms of respiratory infection to detect and differentiate influenza A and influenza B viral RNA from nasopharyngeal and nasal swab specimens. Intended as an aid in diagnosis in conjunction with clinical and epidemiological risk factors.
Regulatory Classification
Identification
A respiratory viral panel multiplex nucleic acid assay is a qualitative in vitro diagnostic device intended to simultaneously detect and identify multiple viral nucleic acids extracted from human respiratory specimens or viral culture. The detection and identification of a specific viral nucleic acid from individuals exhibiting signs and symptoms of respiratory infection aids in the diagnosis of respiratory viral infection when used in conjunction with other clinical and laboratory findings. The device is intended for detection and identification of a combination of the following viruses:(1) Influenza A and Influenza B; (2) Influenza A subtype H1 and Influenza A subtype H3; (3) Respiratory Syncytial Virus subtype A and Respiratory Syncytial Virus subtype B; (4) Parainfluenza 1, Parainfluenza 2, and Parainfluenza 3 virus; (5) Human Metapneumovirus; (6) Rhinovirus; and (7) Adenovirus.
Special Controls
*Classification.* Class II (special controls). The special controls are:(1) FDA's guidance document entitled “Class II Special Controls Guidance Document: Respiratory Viral Panel Multiplex Nucleic Acid Assay;”
(2) For a device that detects and identifies Human Metapneumovirus, FDA's guidance document entitled “Class II Special Controls Guidance Document: Testing for Human Metapneumovirus (hMPV) Using Nucleic Acid Assays;” and
(3) For a device that detects and differentiates Influenza A subtype H1 and subtype H3, FDA's guidance document entitled “Class II Special Controls Guidance Document: Testing for Detection and Differentiation of Influenza A Virus Subtypes Using Multiplex Nucleic Acid Assays.” See § 866.1(e) for the availability of these guidance documents.
Cepheid Xpert® Nasopharyngeal Sample Collection Kit for Viruses (K171552)
Cepheid Xpert® Nasal Sample Collection Kit for Viruses (K171552)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
A. 510(k) Number:
K181289
B. Purpose for Submission:
To obtain 510(k) clearance for the Xpert Xpress Flu Assay performed on the GeneXpert Instrument Systems implementing a new software version and an expanded Intended Use claim that includes nasal swab (NS) specimens as an additional cleared specimen type.
C. Measurand:
Conserved RNA sequences in the genes that encode the following proteins: influenza A matrix protein (M), influenza A polymerase basic protein 2 (PB2), influenza A polymerase acidic protein (PA), influenza B matrix protein (M), and influenza B non-structural proteins (NS1 and NS2).
D. Type of Test:
An automated, multiplex, real-time, reverse transcriptase polymerase chain reaction (RT-PCR) assay for the in vitro qualitative detection and differentiation of influenza A and influenza B viral RNA.
E. Applicant:
Cepheid
F. Proprietary and Established Names:
Xpert Xpress Flu
Xpert Xpress Flu Assay
G. Regulatory Information:
1. Regulation Section:
21CFR 866.3980 - Respiratory viral panel multiplex nucleic acid assay
2. Classification:
Class II
3. Product code:
OCC – Respiratory viral panel multiplex nucleic acid assay
OOI – Instrumentation for clinical multiplex test systems
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JSM - Culture media, non-propagating transport
# 4. Panel:
Microbiology (83)
# **H. Intended Use:**
# 1. Intended Use(s):
The Cepheid Xpert Xpress Flu Assay, performed on the GeneXpert Instrument Systems, is an automated, multiplex real-time, reverse transcriptase polymerase chain reaction (RT-PCR) assay intended for the *in vitro* qualitative detection and differentiation of influenza A and influenza B viral RNA. The Xpert Xpress Flu Assay uses nasopharyngeal (NP) swab and nasal swab (NS) specimens collected from patients with signs and symptoms of respiratory infection. The Xpert Xpress Flu Assay is intended as an aid in the diagnosis of influenza infections in conjunction with clinical and epidemiological risk factors.
Negative results do not preclude influenza virus infection and should not be used as the sole basis for treatment or other patient management decisions.
Performance characteristics for influenza A were established during the 2015-2016 influenza season for NP swab specimens and the 2016-2017 influenza season for NS specimens. When other novel influenza A viruses are emerging, performance characteristics may vary.
If infection with a novel influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent influenza viruses and sent to state or local health departments for testing. Viral culture should not be attempted in these cases unless a BSL 3+ facility is available to receive and culture specimens.
# Ancillary Nasopharyngeal Swab Specimen Collection Kit for Viruses:
The Xpert Nasopharyngeal Sample Collection Kit is designed to collect, preserve, and transport nasopharyngeal swab specimens and to preserve and transport nasal aspirate/wash specimens containing viruses from patients with signs and symptoms of respiratory infection prior to analysis with the Xpert Flu Assay or the Xpert Flu/RSV XC Assay. The Xpert Nasopharyngeal Sample Collection Kit is designed to collect, preserve, and transport nasopharyngeal swab specimens containing viruses from patients with signs and symptoms of respiratory infection prior to analysis with the Xpert Flu+RSV Xpress Assay, Xpert Xpress Flu/RSV Assay or the Xpert Xpress Flu Assay.
# Ancillary Nasal Swab Specimen Collection Kit for Viruses:
The Xpert Nasal Sample Collection Kit is designed to collect, preserve, and transport nasal swab specimens containing viruses from patients with signs and symptoms of respiratory infection prior to analysis with the Xpert Xpress Flu Assay.
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2. Indication(s) for Use:
Same as intended use
3. Special Conditions for Use Statement(s):
For prescription use only
4. Special Instrument Requirements:
GeneXpert Instrument Systems
- GeneXpert Dx Systems (GX-I, GX-II, GX-IV, GX-XVI)
- GeneXpert Infinity Systems (Infinity-48, Infinity-80, Infinity-48s)
# I. Device Description:
# Overview
The Xpert Xpress Flu Assay, performed on the GeneXpert Instrument (Dx and Infinity) Systems, is a rapid, multiplex nucleic acid amplification test for the qualitative detection and differentiation of influenza A and influenza B viral RNA from nasopharyngeal (NP) swab and nasal swab (NS) specimens.
To perform the Xpert Xpress Flu Assay, NP swab and NS specimens are collected from patients and placed into viral transport medium using the Xpert Xpress Nasopharyngeal Sample Collection Kit for Viruses. With a transfer pipette, eluted NP swab and NS specimens are loaded into the sample chamber of a single-use, self-contained Xpert Xpress Flu Assay cartridge. Each assay cartridge contains separate chambers for sample loading, sample processing and target amplification by real-time RT-PCR, and contains all the reagents necessary to carry out these processes. Because the cartridges are self-contained, and specimens never contact working parts of the instrument modules, cross-contamination between samples is minimized.
The assay cartridge containing the patient sample is inserted into the GeneXpert Instrument System, which performs fully automated and integrated sample preparation and real-time RT-PCR for the Xpert Xpress Flu Assay in approximately 30 minutes or less. The GeneXpert Instrument Systems, comprised of the GeneXpert Dx and GeneXpert Infinity Systems, have one to 80 randomly accessible modules that are each capable of performing separate sample preparation and real-time PCR and RT-PCR tests. Each module contains a syringe drive for dispensing fluids (i.e., the syringe drive activates the plunger that works in concert with the rotary valve in the cartridge to move fluids between chambers), an ultrasonic horn for lysing cells or spores, and a proprietary I-CORE thermocycler for performing real-time PCR and RT-PCR detection.
After completion of the test, the assay results are interpreted by the GeneXpert software
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from measured fluorescent signals and embedded calculation algorithms, and are shown in the “View Results” window in tabular and graphic formats.
# 1. Materials Provided
The Xpert Xpress Flu Assay (Cat # XPRSFLU-10) contains sufficient reagents to process 10 NP swab, NS specimens or quality control samples. The assay kit includes 10 individual cartridges with integrated reaction tubes that hold all the reagents necessary for sample lysis, RNA extraction, and nucleic acid amplification. Additionally, each kit includes a set of 12 transfer pipettes for loading samples into the assay cartridge and a CD containing the Assay Definition Files (ADFs) with instructions for importing ADFs into the GeneXpert software.
# 2. Materials Required but Not Provided
Validated Specimen Collection and Transport Kit:
- Cepheid Xpert Nasopharyngeal Sample Collection Kit for Viruses (Cat # SWAB/B-100) containing one individually wrapped, sterile nasopharyngeal flocked nylon swab and one Xpert Viral Transport Medium tube with three mL of Xpert Viral Transport Medium.
- Cepheid Xpert Nasal Sample Collection Kit for Viruses (Cat # SWAB/F-100) containing one individually wrapped, sterile nasal flocked nylon swab and one Xpert Viral Transport Medium tube with three mL of Xpert Viral Transport Medium.
GeneXpert Instrument System:
- GeneXpert Dx System (GX-I, GX-II, GX-IV, GX-XVI)
- GeneXpert Infinity System (Infinity-48, Infinity-48s, Infinity-80)
# 3. Materials Available but Not Provided
External Controls:
- Positive inactivated influenza A and B virus control from ZeptoMetrix (Cat # NATFLUAB-6C)
- Negative inactivated coxsackievirus control from ZeptoMetrix (Cat # NATCXVA9-6C)
# 4. Quality Control
The Xpert Xpress Flu Assay includes two internal controls: a sample processing control, and a probe check control.
Sample Processing Control:
The sample processing control (SPC) is a non-infectious armored RNA pseudovirus that ensures adequate processing of target viruses, monitors the presence of PCR inhibitors, and verifies the use of proper PCR conditions. The SPC should be POSITIVE in a sample that is
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negative for both influenza A and influenza B target analytes, and can be NEGATIVE or POSITIVE in a sample containing detectable levels of one or more of the target analytes.
Probe Check Control:
The probe check control (PCC) is present to control for sufficient reagent rehydration, PCR tube filling, probe integrity, and dye stability. All assay reagents must be present and intact for the PCC to pass the validated acceptance criteria. If any of the PCC conditions fail, the result is reported as an ERROR and the test must be repeated using a new assay cartridge.
# 5. Results Interpretation
POSITIVE or NEGATIVE test results for influenza A (Flu A) and influenza B (Flu B) viral RNA are automatically generated by the GeneXpert software and presented as text in the “View Results” window of the GeneXpert Instrument Systems following completion of the test. The GeneXpert software is equipped with embedded algorithms to determine the result of the test based on the calculated cycle threshold (Ct) values obtained for each of the RNA target-specific optical curves generated by fluorescent probes during the real-time PCR cycling process. Optical curves for each of the RNA targets are also displayed in the “View Results” window but do not require manual data interpretation or reviewing.
The Xpert Xpress Flu Assay uses two separate channels for the detection of influenza A viral RNA (Flu A 1 and Flu A 2). The primers and probes in the Flu A 1 channel have 100% homology to human influenza A strains. The primers and probes in the Flu A 2 channel have > 95% homology to avian influenza A strains and approximately 80% homology to human influenza A strains. Detection of influenza A strains in either the Flu A 1 or Flu A 2 channel is reported as Flu A POSITIVE.
The GeneXpert Instrument Systems software also reports if the test is INVALID, encounters an ERROR, or produces NO RESULT.
All possible test results for the Xpert Xpress Flu assay are shown in Table 1.
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Table 1: All Possible Final Test Results for the Xpert Xpress Flu Assay
| | RNA target | | | |
| --- | --- | --- | --- | --- |
| Result | Flu A 1 | Flu A 2 | Flu B | SPC |
| Flu A POSITIVE; Flu B NEGATIVE | POS | POS/NEG | NEG | POS/NEG |
| | POS/NEG | POS | | |
| Flu A POSITIVE; Flu B POSITIVE | POS | POS/NEG | POS | POS/NEG |
| | POS/NEG | POS | | |
| Flu A NEGATIVE; Flu B POSITIVE | NEG | NEG | POS | POS/NEG |
| Flu A NEGATIVE; Flu B NEGATIVE | NEG | NEG | NEG | POS |
| INVALID | NEG | NEG | NEG | NEG |
| ERROR | NO RESULT | NO RESULT | NO RESULT | NO RESULT |
| NO RESULT | NO RESULT | NO RESULT | NO RESULT | NO RESULT |
If any of the test results mentioned below occur, the test should be repeated using leftover specimen from the original transport medium tube and a new assay cartridge.
- INVALID: indicates that the control SPC failed. The sample was not properly processed, PCR was inhibited, or the sample was not properly collected.
- ERROR: could be a result of PCC failure, or that the maximum pressure limits were exceeded. PCR does not initiate when there is a PCC failure.
- NO RESULT: indicates that insufficient data were collected. For example, the operator stopped a test that was in progress or a power failure occurred.
- Co-infection with two or more viruses: the incidence of co-infection with influenza A and influenza B viruses is low. Specimens should undergo repeat testing if nucleic acids from more than one analyte are detected in a single specimen.
### J. Substantial Equivalence Information:
1. Predicate device name(s): Cepheid Xpert Flu/RSV XC
2. Predicate 510(k) number(s): K142045
3. Comparison with predicate:
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**Table 2. Differences between device and predicate**
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| | Cepheid Xpert Xpress Flu | Cepheid Xpert Flu/RSV XC K142045 |
| Assay Targets | Influenza A and Influenza B viral RNA | Influenza A, Influenza B, and RSV viral RNA |
| Specimen Types | Nasopharyngeal (NP) swab and nasal swab (NS) specimens | Nasal aspirate/wash (NA/W) specimens and Nasopharyngeal (NP) swab specimens |
| Assay Controls | Encapsulated (armored) RNA pseudovirus as a sample processing control. Available but not provided are inactivated virus controls for influenza A/B as external positive controls, and Coxsackie virus as an external negative control. | Encapsulated (armored) RNA pseudovirus as a sample processing control. Available but not provided are inactivated virus controls for influenza A/B and RSV as external positive controls, and Coxsackie virus as an external negative control. |
| Time to obtain test results | Approximately 30 minutes or less for sample preparation and RT-PCR | Approximately 60 minutes or less for sample preparation and RT-PCR |
| Combinatorial Assay Selections | Not applicable | Yes, user may select combined assay with all targets or a Flu only assay or a RSV only assay. |
**Table 3. Similarities between device and predicate**
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| | Cepheid Xpert Xpress Flu | Cepheid Xpert Flu/RSV XC K142045 |
| Regulation | 866.3980 | Same |
| Product Code | OCC, OOI | Same |
| Device Class | II | Same |
| Technology Principle of Operation | Multiplex real time RT-PCR | Same |
| Intended Use | The Cepheid Xpert Xpress Flu Assay, performed on the GeneXpert Instrument Systems, is an automated, | The Cepheid Xpert Flu/RSV XC Assay is an automated, multiplex real-time, reverse transcriptase polymerase chain reaction |
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| Similarities | | |
| --- | --- | --- |
| | Device | Predicate |
| Item | Cepheid Xpert Xpress Flu | Cepheid Xpert Flu/RSV XC K142045 |
| | multiplex real-time, reverse transcriptase polymerase chain reaction (RT-PCR) assay intended for the *in vitro* qualitative detection and differentiation of influenza A and influenza B viral RNA. The Xpert Xpress Flu Assay uses nasopharyngeal (NP) swab and nasal swab (NS) specimens collected from patients with signs and symptoms of respiratory infection. The Xpert Xpress Flu Assay is intended as an aid in the diagnosis of influenza infections in conjunction with clinical and epidemiological risk factors. Negative results do not preclude influenza virus infection and should not be used as the sole basis for treatment or other patient management decisions. Performance characteristics for influenza A were established during the 2015-2016 influenza season for NP swab specimens and the 2016-2017 influenza season for NS specimens. When other novel influenza A viruses are emerging, performance characteristics may vary. If infection with a novel influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent influenza viruses and sent to state or local health departments for testing. Viral culture should not be attempted in these | (RT-PCR) assay intended for the *in vitro* qualitative detection and differentiation of influenza A, influenza B, and respiratory syncytial virus (RSV) viral RNA. The Xpert Flu/RSV XC Assay uses nasopharyngeal swab and nasal aspirate/wash specimens collected from patients with signs and symptoms of respiratory infection. The Xpert Flu/RSV XC Assay is intended as an aid in the diagnosis of influenza and respiratory syncytial virus infections in conjunction with clinical and epidemiological risk factors. Negative results do not preclude influenza virus or respiratory syncytial virus infection and should not be used as the sole basis for treatment or other patient management decisions. Performance characteristics for influenza A were established during the 2013-2014 influenza season. When other novel influenza A viruses are emerging, performance characteristics may vary. If infection with a novel influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent influenza viruses and sent to state or local health department for testing. Viral culture should not be attempted in these cases unless a BSL 3+ facility is available to receive and culture specimens. |
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| Similarities | | |
| --- | --- | --- |
| | Device | Predicate |
| Item | Cepheid Xpert Xpress Flu | Cepheid Xpert Flu/RSV XC K142045 |
| | cases unless a BSL 3+ facility is available to receive and culture specimens. | |
| Indication for Use | Patients with signs and symptoms of respiratory infection in conjunction with clinical and epidemiological risk factors. | Same |
| Nucleic Acid Extraction | Yes | Same |
| Extraction Methods | Sample preparation integrated in GeneXpert Cartridge and GeneXpert Instrumentation System. | Same |
| Assay Results | Qualitative | Same |
| Instrument System | Cepheid GeneXpert Instrument Systems; same Cepheid I-core technology | Same |
| Primers and probes | Primers and probes to detect the presence of nucleic acid sequences of influenza A, influenza B, and RSV. Only results for influenza A and influenza B are reported. | Primers and probes to detect the presence of influenza A, influenza A subtype H7N9, influenza B, and RSV. Results for influenza A, influenza B and RSV analytes are reported. |
| Laboratory Users | Laboratory users in moderate complexity laboratory settings. | Same |
| Sample Preparation | Self-contained and automated after mixed specimen is added to cartridge. All other reagents are contained in the cartridge. | Same |
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| Similarities | | |
| --- | --- | --- |
| | Device | Predicate |
| Item | Cepheid Xpert Xpress Flu | Cepheid Xpert Flu/RSV XC K142045 |
| Primers and probes for influenza A, influenza B | Primers and probes to detect the presence of nucleic acid sequences of influenza A, influenza B, and RSV A/B. The Xpert Xpress Flu Assay contains primers and probes to detect additional RNA segments in order to protect the assay sensitivity and specificity from mutations in the influenza genome due to antigenic drifts and shifts. Only results for influenza A and influenza B are reported. | Primers and probes to detect the presence of nucleic acid sequences of influenza A, influenza B, and RSV A/B. The Xpert Flu+RSV Xpress Assay contains primers and probes to detect additional RNA segments in order to protect the assay sensitivity and specificity from mutations in the influenza genome due to antigenic drifts and shifts. Results for influenza A, influenza B and RSV analytes are reported. |
| Target Sequences | Influenza A: Matrix protein (M), basic polymerase (PB2), and acidic protein (PA) Influenza B: Matrix protein (M) and Non-structural proteins (NS1 and NS2) RSV A and RSV B: Nucleocapsid protein Only results for influenza A and influenza B are reported. | Influenza A: Matrix protein (M), basic polymerase (PB2), and acidic protein (PA) Influenza B: Matrix protein (M) and Non-structural proteins (NS1 and NS2) RSV A and RSV B: Nucleocapsid protein |
| Internal Controls | Sample processing control (SPC) and probe check control (PCC). | Same |
| Early Assay termination function | Yes | Yes |
### K. Standard/Guidance Document Referenced (if applicable):
1. The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]-Guidance for Industry and Food and Drug Administration Staff. Document issued on July 28, 2014.
2. Class II Special Controls Guidance Document: Instrumentation for Clinical Multiplex Test Systems-Guidance for Industry and Staff. Document issued on March 10, 2005.
3. Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices. Document issued on May 11, 2005.
4. EP17-A2: Protocols for Determination of Limit of Detection and Limits of Quantitation;
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Approved Guideline-Second Edition 2006.
5. Class II Special Controls Guidance Document: Testing for Detection and Differentiation of Influenza A Virus Subtypes Using Multiplex Nucleic Acid Assays. Document issued on October 9, 2009.
6. Class II Special Controls Guidance Document: Respiratory Viral Panel Multiplex Nucleic Acid Assay. Document issued October 9, 2009.
# L. Test Principle:
The Xpert Xpress Flu Assay performed on the GeneXpert Instrument platform utilizes automated real-time RT-PCR for unique gene-specific sequence amplification and 5' end cleavage of hybridized, fluorogenic target-specific probe for the detection of influenza A and influenza B viral RNA. Specific gene targets of the Xpert Xpress Flu Assay primers and probes include the matrix protein (M), basic polymerase protein 2 (PB2), and polymerase acidic protein (PA) of influenza A viruses and the matrix protein (M) and non-structural proteins (NS1 and NS2) of influenza B viruses. Additional assay primers generate amplicons for the SPC.
The GeneXpert Instrument Systems automates sample preparation, amplification and real-time detection of target-specific cDNA from clinical specimens. Each system utilizes a syringe pump drive to dispense fluids to and from the different cartridge chambers and ultrasonic lysis to release nucleic acids from both the target organisms and integrated SPC. During the amplification process, the I-CORE module contained within the GeneXpert Instrument systems heats and cools the reaction tube contents, and detects emitted fluorescence generated in the presence of target sequences. Embedded data analysis algorithms within the GeneXpert Instrument software generate test results based on the calculated cycle threshold (Ct) values obtained for each of the RNA target-specific optical curves generated by fluorescent probes during the real-time RT-PCR cycling process. The time to results is 30 minutes or less.
# M. Performance Characteristics:
# 1. Analytical performance
a. Precision/Reproducibility:
Precision
Not Applicable.
Reproducibility
A multi-center, blinded study using a five-member specimen panel consisting of negative samples, and simulated nasal matrix spiked with low positive samples containing influenza A or influenza B analyte at 1X the respective LoDs, and moderate positive samples containing influenza A or influenza B at 2-3X the respective LoDs. Testing was performed
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at three sites (one internal, two external), by two operators per site, on either the GeneXpert Dx system, the Infinity-48 system or the Infinity-80 system (each of the three sites used a different instrument). Each operator tested one panel in duplicate, two times per day over six, not necessarily consecutive days. Three lots of Xpert cartridges were used, with each lot representing approximately two days of testing.
Original testing was performed on the GeneXpert Dx Instrument System with system software version 4.6a or higher as part of K162456. Re-analysis of the original data was conducted for this submission using the Xpert Xpress Flu Assay ADF version 3 in order to determine reproducibility of the newly modified assay.
The expected results for each of the panel members are shown in Table 4 below. Overall percent agreement between the expected results and the re-analyzed reproducibility study results is presented in Table 5. Analysis of variance (CV) between sites, days, lots, and operators for each reproducibility panel member is presented in Table 6.
Re-analysis of K162456 reproducibility data resulted in no changes to the percent agreement for the negative, influenza A (Flu A) moderate positive, or influenza B (Flu B) low positive sample types. For influenza A low positive samples, the percent agreement decreased from 93.7% to 93.6% using ADF version 3. For influenza B moderate positive samples, the percent agreement increased from 99.3% to 100%.
Table 4. Reproducibility sample panel
| Panel Sample (Strain Name) | Expected Level | Expected Positivity Rate | Concentration (TCID_{50}/mL) |
| --- | --- | --- | --- |
| Negative | 0 | 0% | N/A |
| Flu A (A/Victoria/361/2011) | Low positive (1X LoD) | ~95% | 0.75 |
| Flu A (A/Victoria/361/2011) | Moderate positive (~2-3X LoD) | 100% | 1.5 |
| Flu B (B/Mass/2/2012) | Low positive (1X LOD) | ~95% | 0.2 |
| Flu B (B/Mass/2/2012) | Moderate positive (~2-3X LoD) | 100% | 0.4 |
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Table 5. Summary of Reproducibility Results - % Agreement-Re-analysis of K162456 Data Using Assay Definition File Version 3 (ADF v3)
| Sample ID | Site 1/Infinity-80 | | | Site 2/Dx | | | Site 3/Infinity-48 | | | % Total Agreement by Sample^{a} |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Op 1 | Op 2 | Site | Op 1 | Op 2 | Site | Op 1 | Op 2 | Site | |
| Negative | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (144/144) |
| Flu A Low Pos | 87% (20/23) | 95.8% (23/24) | 91.5% (43/47) | 95.7% (22/23) | 91.7% (22/24) | 93.6% (44/47) | 100% (23/23) | 91.3% (21/23) | 95.7% (44/46) | 93.6% (131/140)^{b} |
| Flu A Mod Pos | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (23/23) | 100% (23/23) | 100% (46/46) | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (142/142)^{b} |
| Flu B Low Pos | 95.8% (23/24) | 95.8% (23/24) | 95.8% (46/48) | 95.8% (23/24) | 95.8% (23/24) | 95.8% (46/48) | 95.8% (23/24) | 91.7% (22/24) | 93.8% (45/48) | 95.1% (137/144) |
| Flu B Mod Pos | 100% (23/23) | 100% (24/24) | 100% (47/47) | 100% (24/24) | 100% (24/24) | 100% (48/48) | 100% (24/24) | 100% (23/23) | 100% (47/47) | 100% (142/142)^{b} |
$^{a}$Agreement calculated based on expected result: Negative for Negative (targeted positivity: 0%); Positive for Low Pos (targeted positivity: 95%) and Mod Pos (targeted positivity: 100%) samples.
$^{b}$Eight samples were indeterminate [Flu A Low Pos (4); Flu A Mod Pos (2); Flu B Mod Pos (2)]
Table 6. Summary of Reproducibility Data-Re-analysis of K162456 Data Using Assay Definition File Version 3 (ADF v3)
| Sample | Assay Channel (Analyte) | N^{a} | Mean Ct | Between-Site | | Between-Lot | | Between-Day | | Between-Operator | | Within-Assay | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV (%) | SD | CV (%) | SD | CV (%) | SD | CV (%) | SD | CV (%) | SD | CV (%) |
| Negative | SPC | 144 | 32.3 | 0 | 0 | 0.7 | 2.1 | 0.1 | 0.4 | 0 | 0 | 0.6 | 1.9 | 0.9 | 2.8 |
| Flu A-Low Pos | FluA1 | 131 | 35.3 | 0 | 0 | 0.6 | 1.6 | 0 | 0 | 0 | 0 | 1.1 | 3.0 | 1.2 | 3.4 |
| Flu A-Mod Pos | FluA1 | 142 | 33.1 | 0 | 0 | 0.0 | 0.1 | 0.2 | 0.6 | 0 | 0 | 0.6 | 1.8 | 0.6 | 1.9 |
| Flu B-Low Pos | FluB | 137 | 34.6 | 0 | 0 | 0 | 0 | 0.5 | 1.3 | 0.4 | 1.2 | 1.3 | 3.9 | 1.5 | 4.2 |
| Flu B-Mod Pos | FluB | 142 | 32.3 | 0.1 | 0.3 | 0.3 | 0.8 | 0 | 0 | 0.3 | 0.8 | 0.8 | 2.4 | 0.9 | 2.7 |
$^{a}$Results with non-zero values out of 144
All negative samples produced a negative result (144/144).
All moderate positive samples produced a positive result [Flu A (142/142) and Flu B (142/142)].
The differences observed upon re-analysis of reproducibility data using the updated ADF v3 are minimal, and are summarized in Table 7 below. Based on these data, the ADF changes do not appear to impact the overall assay reproducibility.
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Table 7. Xpert Xpress Flu Assay Performance Comparison
| Sample Type | % Total Agreement by Sample | |
| --- | --- | --- |
| | Reference ADF | Candidate ADF |
| Negative | 100% (144/144) | 100% (144/144) |
| Flu A – Low Pos | 93.7% (134/143) | 93.6% (131/140)* |
| Flu A – Mod Pos | 100% (142/142) | 100% (142/142) |
| Flu B – Low Pos | 95.1% (137/144) | 95.1% (137/144) |
| Flu B – Mod Pos | 99.3% (143/144) | 100% (142/142)* |
*Fewer samples are reported for the re-analysis due to an increase in the number of invalid results when using Assay Definition File version 3.
Re-analysis of reproducibility data originally obtained during studies conducted for K171552, which used the Xpert Xpress Flu Assay on the GeneXpert Xpress System, was also performed and reported in this submission. Because the re-analysis resulted in no changes to the percent agreement for any of the sample types tested, data are not shown. Please refer to K171552 for results.
b. Linearity/assay reportable range:
Not Applicable.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability:
Not Applicable.
Calibrator
Not Applicable.
Controls
Please refer to submission K162456.
Stability:
Stability studies have been performed to support the following claims:
Sample Stability:
The following specimen stability claims are supported by study data from K162456:
- 15-30°C for up to 24 hours
- 2-8°C for up to seven days
Kit Stability:
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Additional study data to support stability claims at 16 months were provided in this submission.
- 2-28°C for up to 16 months.
Refer to K162456 and K171552 for all other stability information.
# Cartridge Hold Time:
The following stability claim for prepared samples waiting on the GeneXpert Xpress GX II or IV are supported by study data from K162456:
- Up to 4.5 hours at room temperature
# Carry-over:
A carry-over study was conducted to demonstrate that single-use, self-contained GeneXpert cartridges prevent carry-over contamination of negative samples if preceded by very high positive samples in the same GeneXpert module. The study consisted of a negative sample processed in the same GeneXpert module (GeneXpert Dx System; GX-IV instrument) immediately following a very high positive influenza A sample (A/Victoria/361/2011, 2x10⁷ TCID₅₀/mL) spiked into a simulated background matrix. The background matrix consisted of 2.5% (w/v) porcine mucin, 1% (v/v) human whole blood in 0.85% sodium chloride (NaCl) formulated in 1X PBS solution with 15% glycerol, which was then diluted in UTM to a final concentration of 16.7%.
The testing was repeated 20 times on two GeneXpert modules for a total of 41 runs resulting in 20 positive and 21 negative specimens for each virus type. All 20 positive samples were correctly reported as Flu A POSITIVE; Flu B NEGATIVE. All 21 negative samples were correctly reported as Flu A NEGATIVE; Flu B NEGATIVE. Therefore, under the conditions of the study, no evidence of specimen or amplicon carry-over contamination was observed in the GeneXpert Dx modules.
# d. Detection limit:
The following influenza strains were used in the Limit of Detection (LoD) study:
- Influenza A pandemic 2009 H1N1 strains
- A/California/7/2009 (H1N1)
- A/Florida/27/2011 (H1N1)
- Influenza A H3N2 strains
- A/Perth/16/2009 (H3N2)
- A/Victoria/361/2011 (H3N2)
- Influenza B strains
- B/Massachusetts/2/2012
- B/Wisconsin/01/2011
The LoD studies for the NP and NS specimens were originally conducted as part of submissions K162456 (using GeneXpert Instrument systems; NP samples) and
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K171552 (using GeneXpert Xpress systems; NS samples). These data were re-analyzed for this submission using a new Assay Definition File version 3 (ADF v3) and presented in Table 8. There was no change in LoD, using ADF v3, for any of the strains tested when compared to previous submissions K162456 and K171552.
Table 8. Confirmed LoD (TCID \( _{50} \) /mL) for Influenza A and Influenza B Strains - Re-analysis of K162456 (NP data) and K171552 (NS data) Using Assay Definition File Version 3(ADF v3)
| Sample Type | Influenza Strain | LOD (TCID50/mL) |
| --- | --- | --- |
| NP | Influenza A/California/7/2009 (H1N1) | 0.02 |
| NP | Influenza A/Florida/27/2011 (H1N1) | 0.04 |
| NP | Influenza A/Perth/16/2009 (H3N2) | 0.01 |
| NP | Influenza A/Victoria/361/2011 (H3N2) | 0.75 |
| NP | Influenza B/Massachusetts/2/2012 | 0.40 |
| NP | Influenza B/Wisconsin/01/2011 | 0.19 |
| NS | Influenza A/California/7/2009 (H1N1) | 0.02 |
| NS | Influenza A/Florida/27/2011 (H1N1) | 0.04 |
| NS | Influenza A/Perth/16/2009 (H3N2) | 0.01 |
| NS | Influenza A/Victoria/361/2011 (H3N2) | 0.21 |
| NS | Influenza B/Massachusetts/2/2012 | 0.07 |
| NS | Influenza B/Wisconsin/01/2011 | 0.17 |
e. Analytical specificity:
Interfering Substances
Please refer to submission K162456.
Analytical Reactivity (inclusivity)
Please refer to submission K162456.
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### Competitive Interference
Please refer to submission K162456.
### Cross-Reactivity
Please refer to submission K162456.
### *f. Assay cut-off:*
The Xpert Xpress Flu Assay detects Flu A and Flu B targets. The Assay has two channels (Flu A 1 and Flu A 2) to detect influenza A strains. The Assay has one channel (Flu B) to detect influenza B strains.
For each of the analytes (Flu A 1, Flu A 2, and Flu B) the valid cycle threshold (Ct) range to report a positive result is Ct 10.0 to 40.0. For the Sample Processing Control (SPC) the valid Ct range to report a positive result is Ct 26 to 40. The Ct cutoffs are included as automatic calculations in the ADF that is provided with the Xpert Xpress Flu Assay.
## 2. Comparison studies:
### *a. Method comparison with predicate device:*
Not Applicable.
### *b. Matrix comparison:*
An equivalency study for clinical and simulated nasal matrix was described in K162456.
An equivalence study for NP swab matrix, NS matrix and simulated matrix was described in K171552.
## 3. Clinical studies:
### *a. Clinical Sensitivity and Specificity:*
Performance of the Xpert Xpress Flu Assay was previously evaluated against FDA-cleared nucleic acid reference tests during two separate prospective clinical studies (K162456 and K171552). For the K162456 study, data was collected during the 2015-2016 influenza season and used to support clearance of the Xpert Xpress Assay on the GeneXpert Instrument systems (K162456) with nasopharyngeal (NP) swab specimens. For the K171552 study, data was collected during the 2016-2017 influenza season and used to support clearance of the Xpert Xpress Flu Assay on the GeneXpert Xpress Instrument Systems (K171552) with both NP and nasal swab (NS) specimens. Details for the two clinical studies can be found in the respective decision summaries.
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To determine the clinical performance of the newly modified Xpert Xpress Flu Assay (ADF v3) on the GeneXpert Instrument Systems, data from the previously conducted studies were re-analyzed using the new software version. Results from the reanalysis are summarized in the following tables.
Table 9. Number and Percent of NP Specimens by Age Range-from K162456 Study
| Age Group (years) | Number of Patients | % of Total | Flu A | | Flu B | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | Number of Positives | Positivity Rate | Number of Positives | Positivity Rate |
| ≤5 years | 360 | 17.6% | 25 | 7.0% | 17 | 4.7% |
| 6-21 years | 224 | 11.0% | 18 | 8.0% | 30 | 13.3% |
| 22-59 years | 729 | 35.5% | 52 | 7.1% | 26 | 3.6% |
| ≥60 years | 36 | 35.9% | 32 | 4.3% | 22 | 3.0% |
| Unknown | 1 | <0.1% | 0 | 0 | 0 | 0 |
| Total | 2051 | 100% | 127 | 6.2% | 95 | 4.6% |
Table 10. Xpert Xpress Flu Assay Performance with NP Swab Specimens-Re-analysis of K162456 Data Using Assay Definition File Version 3 (ADF v3)
| Specimen Type | Target | N | TP | FN | TN | FP | PPA (95% CI) | NPA (95% CI) |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Fresh, prospective | Flu A | 1139 | 35 | \( 2^a \) | 1095 | \( 7^b \) | 94.6% (82.3-98.5) | 99.4% (98.7-99.7) |
| | Flu B | 1139 | 42 | 0 | 1089 | \( 8^c \) | 100.0% (91.6-100.0) | 99.3% (98.6-99.6) |
| | | | | | | | | |
| Frozen, Consecutively Collected | Flu A | 912 | 68 | 0 | 827 | \( 17^d \) | 100.0% (94.7-100.0) | 98.0% (96.8-98.7) |
| | Flu B | 912 | 36 | 0 | 867 | \( 9^e \) | 100.0% (90.4-100.0) | 99.0% (98.1-99.5) |
| | | | | | | | | |
| Combined | Flu A | 2051 | 103 | \( 2^a \) | 1922 | \( 24^f \) | 98.1% (93.3-99.5) | 98.8% (98.2-99.2) |
| | Flu B | 2051 | 78 | 0 | 1956 | \( 17^g \) | 100.0% (95.3-100.0) | 99.1% (98.6-99.5) |
\( ^{a} \) . Testing results by sequencing: 2 of 2 were Flu A Negative.
\( ^{b} \) . Testing results by sequencing: 3 of 7 were Flu A Positive; 3 of 7 were Flu A Negative; 1 of 7 insufficient specimen for sequencing.
c. Testing results by sequencing: 6 of 8 were Flu B Positive; 1 of 8 were Flu B Negative; 1 of 8 insufficient specimen for sequencing.
\( ^{d} \) . Testing results by sequencing: 7 of 17 were Flu A Positive; 7 of 17 were Flu A Negative; 3 of 17 insufficient specimen for sequencing.
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c. Testing results by sequencing: 7 of 9 were Flu B Positive; 0 of 9 were Flu B Negative; 2 of 9 insufficient specimen for sequencing.
f. Testing results by sequencing: 10 of 24 were Flu A Positive; 10 of 24 were Flu A Negative; 4 of 24 insufficient specimen for sequencing.
g. Testing results by sequencing: 13 of 17 were Flu B Positive; 1 of 17 were Flu B Negative; 3 of 17 insufficient specimen for sequencing.
Implementation of ADF v3 resulted in a 0.1% increase in NPA for influenza A and influenza B for prospectively collected, fresh specimens when compared to the previous ADF version. In addition, there was a 0.8% increase in NPA for influenza A and influenza B for consecutively collected, frozen specimens when compared to the previous ADF version. Therefore, ADF v3 has minimal impact on assay performance using clinical NP swab specimens.
Table 11. Number and Percent of NS Specimens by Age Range-from K171552 Study
| Age Group (years) | Number of Patients | % of Total | Flu A | | Flu B | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | Number of Positives | Positivity Rate | Number of Positives | Positivity Rate |
| ≤5 years | 604 | 37.8% | 67 | 11.1% | 26 | 4.3% |
| 6-21 years | 273 | 17.1% | 65 | 23.8% | 26 | 9.5% |
| 22-59 years | 554 | 34.7% | 58 | 10.5% | 19 | 3.4% |
| ≥60 years | 167 | 10.5% | 30 | 18.0% | 3 | 1.8% |
| Total | 1598 | 100% | 220 | 14.0% | 74 | 4.6% |
Table 12. Xpert Xpress Flu Assay Performance with NS Specimens - Re-analysis of K171552 Data Using Assay Definition File Version 3 (ADF v3)
| Specimen Type | Target | N | TP | FN | TN | FP | PPA (95% CI) | NPA (95% CI) |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Fresh, prospective | Flu A | 1598 | 186 | \( 2^a \) | 1376 | \( 34^b \) | 98.9% (96.2-99.7) | 97.6% (96.6-98.3) |
| | Flu B | 1598 | 63 | \( 1^c \) | 1523 | \( 11^d \) | 98.4% (91.7-99.7) | 99.3% (98.7-99.6) |
a. Testing results by sequencing: 1 of 2 Flu A NEG; 1 of 2 Flu A POS.
b. Testing results by sequencing: 16 of 34 Flu A NEG; 11 of 34 Flu A POS; 7 of 34 inconclusive.
c. Testing results by sequencing: 1 of 1 inconclusive.
d. Testing results by sequencing: 5 of 11 Flu B POS; 6 of 11 inconclusive.
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Implementation of ADF v3 resulted in a 0.3% increase in NPA for influenza A and a 0.1% increase in NPA for influenza B when compared to the previous ADF version. Therefore, ADF v3 has minimal impact on assay performance using clinical NS specimens.
### 4. Clinical cut-off:
N/A
### 5. Expected values/Reference range:
Expected prevalence values for influenza A and influenza B infections were calculated using the data acquired during the NP and NS clinical studies conducted under K162456 and K171552, respectively. The number and percentage of cases positive for influenza A and influenza B, as reported in Table 13, were determined following re-analysis of the original study data with the Xpert Xpress Flu Assay ADF v3.
Table 13. Expected Values for Influenza A and Influenza B by Xpert Xpress Flu Assay (All swabs; NP and NS)
| Age Group (years) | Number of Patients | % of Total | Flu A | | Flu B | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | Number of Positives | Positivity Rate | Number of Positives | Positivity Rate |
| ≤5 years | 964 | 26.4% | 92 | 9.5% | 43 | 4.5% |
| 6-21 years | 498 | 13.6% | 83 | 16.7% | 56 | 11.2% |
| 22-59 years | 1283 | 35.2% | 110 | 8.6% | 45 | 3.5% |
| ≥60 years | 903 | 24.7% | 62 | 6.9% | 25 | 2.8% |
| Unknown | 1 | <0.1% | 0 | 0 | 0 | 0 |
| Total | 3649 | 100% | 347 | 9.5% | 169 | 4.6% |
## N. Instrument/System Description:
### 1. Instrument Name:
GeneXpert Dx Systems (GX-I, GX-II, GX-IV, GX-XVI) with GeneXpert Dx software version 4.7b or higher
GeneXpert Infinity-48 System with Xpertise software version 6.4b
GeneXpert Infinity-80 and Infinity-48s Systems with Xpertise software version 6.4b or higher
### 2. System Description:
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The GeneXpert Instrument System family (GeneXpert Dx and Infinity Systems) automates and integrates sample purification, nucleic acid amplification and detection of target sequences within compatible, assay-specific, single-use cartridges. The instrument systems each contain a computer and preloaded software for running tests and viewing the results.
# 3. Software:
FDA has reviewed applicant's Hazard Analysis and software development processes for this line of product types.
Yes ____ X ____ or No ____
# 4. Level of Concern
Moderate
# 5. Software Description
The GeneXpert Instrument Systems are provided with a computer, preloaded with software for running tests and viewing results. Each instrument (Dx and Infinity) contains random access, closed-system, computer-based software and embedded firmware which run dedicated microprocessor-controlled modules to integrate sample preparation, amplification, and real-time detection in a single system.
The GeneXpert Infinity modules contain extra robotic features for cartridge handling. The Xpertise software utilized by the Infinity Systems is the user interface and provides the ordering of tests as well as automates loading and unloading of cartridges into GeneXpert modules within the system. The Xpertise user interface builds upon the existing core software functionality for handling GeneXpert modules for cartridge fluidics control, temperature control, optics control, and data analysis by the addition of automation handling for the robotic arm.
# 6. Specimen Identification
Specimens are manually loaded into the Xpert Xpress Flu Assay cartridge by the user. The user can then either scan or type the sample and patient ID into the system. Prior to placing the cartridge into the GeneXpert Instrument System, the barcode on the Xpert Xpress Flu Assay cartridge is scanned. The information contained in the assay barcode is utilized by the software to run the appropriate assay definition file (ADF). If an assay is being run that does not already exist in the GeneXpert database, the user must import the ADF before starting the test.
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# 7. Calibration
Not required.
# 8. Quality Control
Please refer to Section I-4 of this document.
# **P. Other Supportive Instrument Performance Characteristics Data Not Covered In The “Performance Characteristics” Section above:**
Not Applicable
# **Q. Proposed Labeling:**
The labeling supports the finding of substantial equivalence for this device.
# **R. Conclusion:**
The information submitted 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.