K203677 · GE Medical Systems Ultrasound & Primary Care Diagnostics, LLC · LLZ · Jan 15, 2021 · Radiology
Device Facts
Record ID
K203677
Device Name
ViewPoint 6
Applicant
GE Medical Systems Ultrasound & Primary Care Diagnostics, LLC
Product Code
LLZ · Radiology
Decision Date
Jan 15, 2021
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.2050
Device Class
Class 2
Attributes
Software as a Medical Device
Indications for Use
ViewPoint 6 is intended to be used in medical practices and in clinical departments and serves the purposes of diagnostic interpretation of images, electronic documentation of examinations in the form of text and images, and generation of medical reports primarily for diagnostic ultrasound. ViewPoint 6 provides the user the ability to include images, drawings, and charts into medical reports. ViewPoint 6 is designed to accept, transfer, display, calculate, store, and process medical images and data, and enables the user to measure and annotate the images. The medical images, which ViewPoint 6 displays to the user, can be used for diagnostic purposes. ViewPoint 6 is intended for professional use only. ViewPoint 6 is not intended to be used as an automated diagnosis system. ViewPoint 6 is not intended to operate medical devices in surgery related procedures.
Device Story
ViewPoint 6 is an image archiving and reporting software for medical practices and clinical departments; used for diagnostic interpretation of images and data. Inputs include medical images and data; system enables user to measure, annotate, and document findings. Outputs include medical reports containing images, drawings, charts, and measurements. Used by clinicians in professional settings; supports single workstation or client-server network configurations. Software provides exam-specific reporting forms with standardized terminology; facilitates data management, storage, and retrieval. Healthcare providers use output to assist in diagnostic decision-making; device does not perform automated diagnosis. Benefits include standardized documentation and efficient reporting workflows.
Clinical Evidence
No clinical data. Substantial equivalence supported by non-clinical bench testing, including software verification and validation, performance testing, and adherence to recognized standards (IEC 62304, ISO 14971, IEC 62366-1).
Technological Characteristics
Software-based PACS for diagnostic ultrasound. Operates on Microsoft Windows. Supports DICOM (NEMA PS 3.1-3.20) for connectivity. Architecture supports single workstation or client-server deployment. Complies with IEC 62304 (software lifecycle), ISO 14971 (risk management), and IEC 62366-1 (usability).
Indications for Use
Indicated for professional use in medical practices and clinical departments for diagnostic interpretation of images, electronic documentation, and medical report generation, primarily for diagnostic ultrasound. Not for use as an automated diagnosis system or for operating medical devices in surgery.
Regulatory Classification
Identification
A medical image management and processing system is a device that provides one or more capabilities relating to the review and digital processing of medical images for the purposes of interpretation by a trained practitioner of disease detection, diagnosis, or patient management. The software components may provide advanced or complex image processing functions for image manipulation, enhancement, or quantification that are intended for use in the interpretation and analysis of medical images. Advanced image manipulation functions may include image segmentation, multimodality image registration, or 3D visualization. Complex quantitative functions may include semi-automated measurements or time-series measurements.
Special Controls
*Classification.* Class II (special controls; voluntary standards—Digital Imaging and Communications in Medicine (DICOM) Std., Joint Photographic Experts Group (JPEG) Std., Society of Motion Picture and Television Engineers (SMPTE) Test Pattern).
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Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services logo. The logo on the right is the FDA logo, which stands for U.S. Food & Drug Administration. The FDA logo is in blue.
GE Medical Systems Ultrasound & Primary Care Diagnostics, LLC % Tracey Ortiz Regulatory Affairs Director 9900 W. Innovation Drive WAUWATOSA WI 53226
Re: K203677
Trade/Device Name: ViewPoint 6 Regulation Number: 21 CFR 892.2050 Regulation Name: Picture archiving and communications system Regulatory Class: Class II Product Code: LLZ Dated: December 16, 2020 Received: December 17, 2020
Dear Tracey Ortiz:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmp/pmn.cfm identifies combination product submissions. 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 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 device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
January 15, 2021
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https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
For
Thalia T. Mills, Ph.D. Director Division of Radiological Health OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known)
#### K203677
Device Name ViewPoint 6
#### Indications for Use (Describe)
ViewPoint 6 is intended to be used in medical practices and in clinical departments and serves the purpostic interpretation of images, electronic documentations in the form of text and images, and generation of medical reports primarily for diagnostic ultrasound.
ViewPoint 6 provides the user the ability to include images, drawings, and charts into medical reports. ViewPoint 6 is designed to accept, transfer, display, calculate, store, and process medical images and data, and enables the user to measure and annotate the images, The medical images, which ViewPoint 6 displays to the used for diagnostic purposes.
ViewPoint 6 is intended for professional use only. ViewPoint 6 is not intended to be used as an automated diagnosis system. ViewPoint 6 is not intended to operate medical devices in surgery related procedures.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
X Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# GE Healthcare
510(k) Premarket Notification Submission
Image /page/3/Picture/2 description: The image shows the General Electric (GE) logo. The logo consists of the letters 'g' and 'e' intertwined in a stylized script, enclosed within a blue circle. The circle has decorative swirls or flourishes around its perimeter, giving it a classic and recognizable appearance.
### 510(k) Summary
K203677
In accordance with 21 CFR 807.92 the following summary of information is provided: Date: December 16, 2020
| Submitter: | GE Medical Systems Ultrasound and Primary Care Diagnostics |
|-----------------------|------------------------------------------------------------|
| 9900 Innovation Drive | |
| Wauwatosa, WI 53226 | |
- Primary Contact Person: Tracey Ortiz Regulatory Affairs Director GE Healthcare T:(262)470-1003
Secondary Contact Bryan Behn Regulatory Affairs Leader Person: GE Healthcare
| Trade Name: | ViewPoint 6 |
|-----------------------|------------------------------------------------------------------------------|
| Common/Usual Name: | PACS-Picture archiving and communications system |
| Classification Names: | Class II |
| Product Code: | LLZ, Picture archiving and communications system, 21 CFR<br>892.2050, 90-LLZ |
| Predicate Device: | ViewPoint 6 (K192917) |
| Product Code: | LLZ, Picture archiving and communications system, 21 CFR<br>892.2050, 90-LLZ |
| Reference Device: | EchoPAC Software Only (K200852) |
| Product Code: | LLZ, Picture archiving and communications system, 21 CFR<br>892.2050, 90-LLZ |
#### Device Description:
ViewPoint 6 is an image archiving and reporting software for medical practices and clinical radiological departments. It is used for diagnostic interpretation of images and other data. It provides different calculations and tools to allow for the assessment of the images and data.
ViewPoint 6 is for professional use only and enables quick diagnostic reporting with standardized terminology. It has an intuitive graphical user interface (GUI) and is based on Microsoft Windows® with defined hardware requirements for the user to install on their computer.
ViewPoint 6 provides exam type specific reporting forms for various medical care areas. Forms are composed of different sections with data entry fields. The documentation
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## GE Healthcare 510(k) Premarket Notification Submission
Image /page/4/Picture/1 description: The image shows the General Electric (GE) logo. The logo consists of the letters "GE" in a stylized script, enclosed within a blue circle. The circle has a swirling pattern around the letters, giving it a dynamic and recognizable appearance. The logo is simple, yet distinctive, and is widely recognized as the symbol of the General Electric company.
can include measurements, exam findings, images, and graphs. All data is saved in the ViewPoint 6 database and can be compiled to a professional report. Images and image sequences can be reviewed in the ViewPoint 6 display area based on user preference. ViewPoint 6 supports both a single workstation and a client - server setup. The number of user licenses determines how many workstations in the network have concurrent access to the database. Access can be limited to read - only functionality
### Intended Use/Indication for Use:
ViewPoint 6 is intended to be used in medical practices and in clinical departments and serves the purposes of diagnostic interpretation of images, electronic documentation of examinations in the form of text and images, and generation of medical reports primarily for diagnostic ultrasound.
ViewPoint 6 provides the user the ability to include images, drawings, and charts into medical reports. ViewPoint 6 is designed to accept, transfer, display, calculate, store, and process medical images and data, and enables the user to measure and annotate the images. The medical images, which ViewPoint 6 displays to the user, can be used for diagnostic purposes.
ViewPoint 6 is intended for professional use only. ViewPoint 6 is not intended to be used as an automated diagnosis system. ViewPoint 6 is not intended to operate medical devices in surgery related procedures.
#### Technology:
ViewPoint 6 employs the same fundamental scientific technology as its predicate device.
#### Determination of Substantial Equivalence:
#### Comparison to Predicate Devices
The proposed ViewPoint 6 system is substantially equivalent to the ViewPoint 6 (K192917) with regards to intended use, capabilities, technological characteristics, safety and effectiveness.
| Feature | Predicate Device<br>ViewPoint6 cleared<br>(K192917) | Proposed Device<br>ViewPoint 6 | Discussion of<br>Differences |
|------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|
| Intended use | Identical | Identical | n/a |
| Indications for Use | Identical | Identical | n/a |
| Contra-indications | Identical | Identical | n/a |
| Patient population | Identical | Identical | n/a |
| Environment of use | Identical | Identical | n/a |
| Human Factors | Identical | Identical | n/a |
| Design | Identical | Identical | n/a |
| Performance | Identical | Identical | n/a |
| Standards met | Identical | Identical | n/a |
| Compatibility with<br>other devices/<br>Connectivity | Added:<br>• Full Image Export CVUS - Send<br>Images for IACEL Accreditation<br>• Migrate patient and study data<br>from EchoPAC to ViewPoint 6<br>• Encapsulated PDF Document<br>Export<br>• Export to standard DICOM DIR | Similar function has been<br>cleared in reference<br>device EchoPAC<br>software only (K200852)<br>The difference has no<br>impact to ViewPoint 6<br>safety and effectiveness.<br>Other capabilities are<br>similar to predicate. | |
| Image Editing and<br>Management | Added:<br>• Export of anonymized<br>multi-frames available<br>• Message upon opening<br>several exams in EchoPAC<br>regarding DICOM SR data | Equivalent<br>The difference has<br>no impact to<br>ViewPoint 6 safety<br>and effectiveness. | |
| Report editing and<br>management | Added:<br>• User configured units of<br>measurements<br>• User Masks - New Control<br>Types<br>• Keep list item and field<br>visibility during update<br>• Additional Exam Locked<br>States<br>• For radio buttons, 'hide in<br>report' shall work individually<br>• Option to calculate and print<br>next appointment date<br>• Enhancements for<br>Echocardiography<br>• Extend OB/Gyn Reporting<br>Content<br>• Enhanced Fetal Anatomy and<br>Placenta Section<br>• Enhanced Reporting in<br>Multiple Pregnancies<br>• Vascular Enhancements | Equivalent<br>The difference has<br>no impact to<br>ViewPoint 6 safety<br>and effectiveness. | |
| Calculation | Identical | n/a | |
| Data Mining | Identical | n/a | |
| Coding for<br>Billing | Added:<br>• Unify and simplify medical<br>coding | Equivalent<br>The difference has no<br>impact to ViewPoint 6<br>safety and effectiveness. | |
| Data Privacy<br>and Security | Identical | n/a | |
| Scheduler | Identical | n/a | |
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# GE Healthcare 510(k) Premarket Notification Submission
Image /page/5/Picture/1 description: The image shows the General Electric (GE) logo. The logo consists of the letters 'GE' intertwined in a stylized script, enclosed within a blue circle. The circle has decorative swirls around the perimeter, giving it a classic and recognizable appearance.
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Image /page/6/Picture/22 description: The image shows the General Electric (GE) logo. The logo consists of the letters 'GE' in a stylized, cursive font, enclosed within a blue circle. The circle is surrounded by a swirling, wave-like pattern, also in blue. The logo is simple, clean, and easily recognizable.
510(k) Premarket Notification Submission
### Summary of Non-Clinical Tests:
ViewPoint 6 and its applications comply with voluntary standards:
- IEC 62366-1:2015 Medical devices-Application of usability engineering to medical devices
- IEC 62304:2006+A1:2015, Medical device software-Software life cycle process ●
- NEMA PS 3.1-3.20 (2016), Digital Imaging and Communications in Medicine ● (DICOM) Set. (Radiology)
- ISO 14971:2019 Medical Devices-Application of risk management to medical devices
- IEC 82304-1:2016, Health software-General requirements for product safety ●
The following quality assurance measures are applied to the development of the system:
- Risk Analysis
- Requirements Reviews ●
- Design Reviews ●
- o Testing on unit level (Module verification)
- Integration testing (System verification) 0
- o Performance testing (Verification & Validation)
- Safety testing (Verification)
## Summary of Clinical Tests:
The subject of this premarket submission, ViewPoint 6, did not require clinical studies to support substantial equivalence.
## Conclusion:
GE Healthcare considers the ViewPoint 6 to be as safe, as effective, and performance is substantially equivalent to the predicate device.
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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.