Ascent Cardiorespiratory Diagnostic Software

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April 12, 2019 Medical Graphics Corporation % Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1394 25th Street, NW Buffalo, Minnesota 55313 Re: K181912 Trade/Device Name: Ascent Cardiorespiratory Diagnostic Software Regulation Number: 21 CFR 868.1890 Regulation Name: Predictive pulmonary-function value calculator Regulatory Class: Class II Product Code: BTY Dated: July 15, 2018 Received: July 17, 2018 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). 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Sincerely. for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ Image /page/2/Picture/0 description: The image shows the logo for MGC Diagnostics. The logo consists of a gray circle with three vertical lines inside, resembling a pause symbol. Below the symbol, the text "MGC DIAGNOSTICS" is displayed, with "MGC" in yellow and "DIAGNOSTICS" in gray, followed by the registered trademark symbol. MGC Diagnostics Corporation through its subsidiary Medical Graphics Corporation 350 Oak Grove Parkway St. Paul, Minnesota USA, 55127 -8599 ## 510(k) Summary April 11, 2019 ## Submitted by: MGC Diagnostics Corporation Through its subsidiary Medical Graphics Corporation 350 Oak Grove Parkway St. Paul, MN 55127-8599 USA 651-484-4874 ## Contact Person: Amy Fowler Regulatory Counsel for MGC Diagnostics Pathmaker FDA Law, P.L.L.C. 528 Hennepin Avenue, Suite 503 Minneapolis, MN 55403 Phone: (612) 356-9653 Email: fowler@pathmakerlaw.com Proprietary or Trade Name: Ascent™ Cardiorespiratory Diagnostic Software Common Name: Pulmonary Function Software ## Classification Names: Calculator, Predicted Values, Pulmonary Function, 21 CFR 868.1890, BTY Pulmonary Function Data Calculator, 21 CFR 868.1880, BZC Predicate Device: K122699, SentrySuite Product Line ## Intended Use: Ascent Cardiorespiratory Diagnostic Software is intended to be used for measurements, data collection and analysis of lung function (PFT) parameters, aiding in the diagnosis of related conditions. All the measurements are performed via a mouthpiece or a mask. The test can be viewed on-line {3}------------------------------------------------ with the help of a computer screen and can be printed after the test results can be saved for further referral or report generation purposes. For use of the Bronchial Challenge option, the medical director of the laboratory, physician, or person appropriately trained to treat acute bronchoconstriction, including appropriate use of resuscitation equipment, must be close enough to respond quickly to an emergency. The product can be utilized for patients from 4 years old and older as long as they can cooperate in the performance -- no special limit to patient's sex or height. Measurements will be performed under the direction of a physician in a hospital environment, physician's office or similar settings. #### Device Description: In conjunction with pulmonary diagnostic hardware, Ascent software, a Windows desktop application developed using Microsoft's NET Framework, is used to collect data pertaining to the patient's degree of obstruction, lung volumes, and diffusing capacity. It is also used to present the collected lung diagnostic information so that it can be checked for quality and interpreted by a qualified physician, usually a pulmonologist. The core purpose of the software is to facilitate pulmonary function testing in patients who may be suffering from pulmonary illnesses like Chronic Obstructive Pulmonary Disease and asthma. The software will interact with connected Medical Graphics Corporation diagnostic devices to perform the desired pulmonary function tests on the patient by a professional pulmonary function technologist. The application will display both actual and derived test variables to the user after a test is performed for purposes of data review. #### Pulmonary Function Tests Several pulmonary function tests are supported, including the following: - 1) Forced Vital Capacity (FVC) - 2) Slow Vital Capacity (SVC) - 3) Maximum Voluntary Ventilation (MVV) - 4) Plethysmography (Pleth) - 5) Functional Residual Capacity (FRC) Nitrogen Washout - ୧) Diffusing Capacity (DLCO), Single breath Real Time Diffusion and Single Breath Gas Chromatography - 7) Maximum Inspiratory/Expiratory Pressure (MIP/MEP) - Six Minute Walk (6MWT) 8) - 9) Challenge Testing (Bronchial Provocation (BRP)) #### Supported Devices The software is compatible with the following hardware devices, which have been independently cleared: | Device | FDA 510(k) Number | |------------------------------------------------------------|-------------------| | Platinum Elite™ Series Body Plethysmograph<br>(RTD and GC) | K943259 | | CPFS/D USB™ Spirometer | K861486 | #### User Information The software is intended to be used by trained professionals within the intended environments. The typical user of the software will be respiratory therapists and/or pulmonary function technologists to collect pulmonary diagnostic information from patients and to present the collected lung diagnostic information to a qualified physician, usually a pulmonologist, for diagnostic interpretation. Users of {4}------------------------------------------------ the software are expected to receive training on how to work with the software prior to using the software for diagnostic purposes. ## Hardware Interaction Ascent software is designed to interact with the Platinum Elite™ Series Body Plethysmograph (RTD and GC), and the CPFS/D USB™ Spirometer. These devices can be connected to the computer running the software via a USB port. Communication with the hardware can be managed by the application. The software can start or stop a patient test that is administered by the hardware device. The hardware device will input test results into the software where they can be managed and displayed to the user #### Intended Operational Environment The software is intended to be used in hospitals, clinics and other pulmonary function diagnostic environments. The software is intended to be installed as a desktop application on a Windows based personal computer. #### Summary of General Information Compared to Predicate Device: #### General Information Table | | Subject Device | Predicate Device | Comparison | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Device Name | Ascent Cardiorespiratory<br>Diagnostic Software | SentrySuite Product Line | N/A | | 510(k)<br>Number | TBD | K122699 | N/A | | Decision Date | TBD | Nov. 19. 2012 | N/A | | Manufacturer | Medical Graphics<br>Corporation | CareFusion | N/A | | Classification | Class II | Class II | Same | | Classification<br>Name | 1) Calculator, Predicted Values, Pulmonary Function; BTY<br><br>2) Pulmonary function data calculator; BZC | 1) Calculator, Predicted Values,<br>Pulmonary Function; BTY<br><br>2) Pulmonary function data Calculator; BZC<br><br>3) Diagnostic Spirometer; BZG<br><br>4) Volume plethysmograph; JEH | The subject device chooses a subset of the classifications used by the predicate device.<br><br>Because two classifications are the same, and there are no classifications that are used by the subject device that are not used by the predicate device, this is not an issue for substantial equivalence. | | Regulation | 868.1890<br>868.1880 | 868.1840<br>868.1890<br>868.1880<br>868.1760 | See above. | | Product Codes | BTY, BZG | BTY, BZG, BZC, JEH | See above. | | Prescription<br>Use? | Yes | Yes | Same | | Proposed Intended Use/<br>Indications for Use Statement for<br>Subject Device | Predicate Device Cleared<br>Intended Use/ Indications for<br>Use Statement (K122699) | Comparison | | | Ascent Cardiorespiratory<br>Diagnostic Software is intended to<br>be used for measurements, data<br>collection and analysis of lung<br>function (PFT) parameters, aiding<br>in the diagnosis of related<br>conditions. | The SentrySuite Product line is<br>intended to be used for<br>measurements, data collection<br>and<br>analysis of lung function (PFT)<br>parameters, aiding in the diagnosis<br>of related conditions. | Identical, except for predicate<br>device's use of nasal adapters and<br>subject device's more specific<br>supervision requirement. | | | All the measurements are<br>performed via a mouthpiece or a<br>mask. The results of the test can<br>be viewed on-line with the help of<br>a computer screen and can be<br>printed after the test. The test<br>results can be saved for further<br>referral or report generation<br>purposes. | All the measurements are<br>performed via a mouthpiece, a<br>mask or nasal adapters. The results<br>of the test can be viewed on-line<br>with the help of a computer screen<br>and can be printed after the test.<br>The test results can be saved for<br>further referral or report<br>generation purposes. | | | | For use of the Bronchial Challenge<br>option, the medical director of the<br>laboratory, physician, or person<br>appropriately trained to treat<br>acute bronchoconstriction,<br>including appropriate use of<br>resuscitation equipment, must be<br>close enough to respond quickly to<br>an emergency. | Use of the Option Bronchial<br>Challenge requires the supervision<br>of a physician familiar with<br>emergency medicine. | | | | The product can be utilized for<br>patients from 4 years on and older<br>as long as they can cooperate in<br>the performance -- no special limit<br>to patient's sex or height. | The products can be utilized for<br>patients from 4 years on and older<br>as long as they can cooperate in<br>the performance – no special limit<br>to patient's sex or height. | | | | Measurements will be performed<br>under the direction of a physician<br>in a hospital environment,<br>physician's office or similar<br>settings. | Measurements will be performed<br>under the direction of a physician<br>in a hospital environment,<br>physician's office or similar<br>settings. | | | | | Ascent<br>Cardiorespiratory<br>Diagnostic Software | Predicate Device Cleared<br>Technological Characteristics<br>(K122699) | Comparison | | Hardware | • Desktop or Notebook<br>Computer<br>• Trolley or Desk | • Desktop or Notebook<br>Computer<br>• Trolley or Stand with<br>Power Supply<br>• Pneumotach Handle<br>• Analyzer box (gas)<br>• APS Pro<br>• Nebulizer head<br>• Compressor | Similar (see<br>discussion) | | | • Measurement Devices<br>• CPFS/D USB™ Spirometer<br>• Platinum Elite™ Series Body<br>Plethysmograph (RTD and GC) | • Measurement Device<br>• MasterScreen Pneumo<br>• MasterScreen IOS<br>• MasterScreen PFT/ PFT Body | | | Performance<br>Specifications<br>(Measurement<br>Programs) | • Bronchial Test (Challenge Option) | • Bronchial Test<br>o Bronchospasmolysis<br>o Bronchoprovocation<br>o Pulsed Nebulization<br>o Continuous<br>Nebulization | Similar (see<br>discussion) | | | • Spirometry<br>• Incentive Spirometry<br>• Flow/ Volume<br>• MVV | • Spirometry<br>• Incentive Spirometry<br>• Flow/ Volume<br>• MVV<br>• R-Occlusion (Airway<br>Resistance)<br>• Impulse Oscillometry | | | | • FRC Nitrogen Washout<br>• Real Time Single Breath Diffusion<br>(0.3%CO, 0.3% CH4, 21% O2, Bal N2) | • FRC Helium Rebreathing<br>• Real Time Single Breath Diffusion<br>0.3%CO, 0.3% CH4, 21% O2, Bal N2)<br>• Intra Breath Diffusion | | | | • Diffusion Single Breath Gas<br>Chromatography (GC) (0.3% CO,<br>0.5% Ne, 21% O2, Bal N2) | • Diffusion Single Breath (0.3% CO,<br>9.5% He, Bal Ambient Air) | | | | • Body<br>Plethysmography | • Body<br>Plethysmography<br>• Respiratory Drive P0.1 | | | | • PI/PE Max (MIP/MEP) | • PI/ME Max (MIP/MEP) | | {5}------------------------------------------------ ## Summary of Intended Use of Device Compared to Predicate Device: ## Intended Use Table The tests run by Ascent are largely a subset of the tests run by the SentrySuite predicate device. In a few tests, the technology varies a bit. These similarities and differences are discussed below in both tabular and text form: {6}------------------------------------------------ ## Summary of Technological Characteristics of Device Compared to Predicate Device: ## Technological Characteristics Table The tests run by Ascent are largely a subset of the tests run by the SentrySuite predicate device. In a few tests, the technology varies a bit. These similarities and discussed below in both tabular and text form: {7}------------------------------------------------ #### TECHNOLOGICAL CHARACTERISTICS TABLE - DISCUSSION There are a few tests where there are minor differences between the subject device and predicate device: #### Bronchial Test Both Ascent and the predicate device can conduct and record data from a bronchial challenge test. However, Ascent does not interface with or control a nebulizer or dosimeter, unlike the predicate device. The pulmonary function response of a challenge agent is measured with Ascent after the clinical user provides the agent through a non-integrated nebulizer/ dosimeter. #### Lung Diffusion Tests Both Ascent and the predicate device measure diffusion capacity via Real Time Single Breath technique. Both Ascent and the predicate device also utilize a single breath diffusion measurement technique in which one average alveolar sample is collected for analysis. The subject device uses gas chromatography to measure CO and Ne while the predicate device uses separate gas analyzers for CO and He to obtain diffusing capacity. #### R-Occlusion Airway Resistance R-Occlusion (interrupter technique airway resistance) measures airways resistance by measuring airflow and mouth pressure at zero flow. R-Occlusion airway resistance technique is only available on the Predicate Device. #### FRC Nitrogen Washout vs FRC Helium Rebreathing The subject device determines FRC by using the multiple breath nitrogen washout technique where the FRC is determined by the volume of nitrogen washed out of the lungs during the test. The nitrogen is replaced as the patient breathes 100% oxygen during the test. The predicate device uses the helium rebreathing technique in which the FRC is determined by measuring the helium concentration after equilibration occurs. #### Respiratory Drive P0.1 (P100) Only the predicate device measures P0.1, the pressure measured at patient's mouth after a shutter or balloon has occluded the breathing pathway. This assesses the ventilatory response to an increased level of carbon dioxide (or decreased level of oxygen). The hardware components used with Ascent software are similar to those used with the predicate device. Like the predicate device, Ascent is designed to interface with hardware devices that perform spirometry, whole-body plethysmography, and other pulmonary function tests. The technological characteristics are largely the same, and where there are differences do not raise new questions of safety or effectiveness. {8}------------------------------------------------ ## Determination of Substantial Equivalence Based on Nonclinical Tests Ascent Cardiorespiratory Diagnostic Software was validated per medical device software standards and guidance. Testing results support that Ascent fulfills its intended use/indications for use and is substantially equivalent to the predicate device. ## Non-clinical Performance: Software validation testing involved system level tests, performance tests and safety testing based on hazard analysis. Physiologic performance validation testing was done with the subject software device and recommended hardware devices working together. Performance test parameters included FVC, MVV, FRC, SVC, DLCO, VA, and TGV. There were 38 test sessions, involving subjects from seven to sixtythree years old. In addition to the verification and validation testing activities executed by Medical Graphics Corporation to establish the performance and functionality of Ascent Cardiorespiratory Diagnostic Software and the predicate device, some standards were utilized: ISO 14971 Applications of Risk Management to Medical Devices IEC 62304:2006+AMD1:2015 Medical Device Software – Software Life Cycle Processes ## Determination of Substantial Equivalence Based on Clinical Tests: Not applicable. ## Comparison to Predicate Device and Conclusion: Ascent Cardiorespiratory Diagnostic Software is substantially equivalent to the predicate device, SentrySuite Product Line (K122699). The intended use for Ascent is substantially equivalent to the intended use/indications for use statement of SentrySuite Product Line, K122699. The technological characteristics of Ascent are almost identical to those of the predicate device. These characteristics of Ascent software have been validated through software validation procedures and the software performs as intended. MGC Diagnostics believes the predicate device confirms the subject device has the same intended use, the technological characteristics are largely the same, and where there are differences, the differences do not raise new questions of safety or effectiveness. {9}------------------------------------------------ # Please wait... If this message is not eventually replaced by the proper contents of the document, your PDF viewer may not be able to display this type of document. You can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by visiting http://www.adobe.com/go/reader_download. For more assistance with Adobe Reader visit http://www.adobe.com/go/acrreader. 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