K221727 · Siemens Medical Solutions USA, Inc. · JAK · Jul 13, 2022 · Radiology
Device Facts
Record ID
K221727
Device Name
syngo.CT Extended Functionality
Applicant
Siemens Medical Solutions USA, Inc.
Product Code
JAK · Radiology
Decision Date
Jul 13, 2022
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.1750
Device Class
Class 2
Attributes
AI/ML, Software as a Medical Device
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Vascular structure segmentation
Deep learning algorithm
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Pulmonary opacity segmentation
AI algorithm
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Indications for Use
syngo.CT Extended Functionality is intended to provide advanced visualization tools to prepare and process medical images for diagnostic purpose. The software package is designed to support technicians and physicians in qualitative and quantitative measurements and in the analysis of clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners, and possibly other medical imaging modalities (e.g. MR scanners). An interface shall enable the connection between the syngo.CT Extended Functionality software package and the interconnected CT Scanner system. Resulting images created with the syngo.CT Extended Functionality software package can be used to assist trained technicians or physicians in diagnosis.
Device Story
Software bundle providing advanced visualization/measurement tools for medical images (CT/MR). Operates as extension to CT scanner systems; used by technicians/physicians for clinical evaluation. Features include: Average (pixel-by-pixel image averaging); Vessel (vascular evaluation/measurement); Interactive Spectral Imaging (dual-energy data representation); Oncology (nodule localization/evaluation); Trauma (layout sorting); Osteo (bone mineral density); Neuro DSA (bone removal); ROI HU Threshold (distribution analysis); Dual Energy (simultaneous evaluation); Endoscopic Viewing (fly-through); Pulmonary Density (opacity segmentation). Modifications in current version (SOMARIS/8 VB70) include deep learning-based bone removal for head/neck vessels, expanded ROI support for spectral/oncology tools, and new averaging functionality. Output assists clinicians in diagnosis and documentation via DICOM snapshots/series.
Clinical Evidence
Bench testing only. Verification and validation testing (integration and functional) performed to confirm software performance against specifications. No clinical data provided.
Technological Characteristics
Software-based image processing suite. Connectivity via DICOM (NEMA PS 3.1-3.20). Standards: IEC 62304 (software lifecycle), ISO 14971 (risk management), IEC 62366-1 (usability). Features rule-based processing and deep learning-based segmentation (bone removal).
Indications for Use
Indicated for use by trained technicians and physicians to perform qualitative and quantitative measurements and analysis of clinical data acquired/reconstructed by CT or other medical imaging modalities (e.g., MR) for diagnostic purposes.
Regulatory Classification
Identification
A computed tomography x-ray system is a diagnostic x-ray system intended to produce cross-sectional images of the body by computer reconstruction of x-ray transmission data from the same axial plane taken at different angles. This generic type of device may include signal analysis and display equipment, patient and equipment supports, component parts, and accessories.
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July 13, 2022
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Siemens Medical Solutions USA, Inc. % Monsuru Bello Regulatory Affairs Specialist 810 Innovation Drive KNOXVILLE TN 37932
## Re: K221727
Trade/Device Name: syngo.CT Extended Functionality Regulation Number: 21 CFR 892.1750 Regulation Name: Computed tomography x-ray system Regulatory Class: Class II Product Code: JAK Dated: June 13, 2022 Received: June 14, 2022
## Dear Monsuru Bello:
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/cfpmn/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
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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 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 mediation-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,
Laurel Burk, Ph.D. Assistant Director Diagnostic X-Ray Systems Team OHT 8B: Division of Radiological Imaging Devices and Electronic Products Office of Radiological Health Center for Devices and Radiological Health
Enclosure
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## Indications for Use
510(k) Number (if known) K221727
Device Name syngo.CT Extended Functionality
## Indications for Use (Describe)
syngo.CT Extended Functionality is intended to provide advanced visualization tools to prepare and process medical images for diagnostic purpose. The software package is designed to support technicians and physicians in qualitative and quantitative measurements and in the analysis of clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners, and possibly other medical imaging modalities (e.g. MR scanners). An interface shall enable the connection between the syngo. CT Extended Functionality software package and the interconnected CT Scanner system.
Resulting images created with the syngo.CT Extended Functionality software package can be used to assist trained technicians or physicians in diagnosis.
| Type of Use (Select <i>one</i> or <i>both</i> , as applicable) |
|----------------------------------------------------------------|
|----------------------------------------------------------------|
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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## 510(k) Summary
K221727
#### Identification of the Submitter l.
Importer/Distributor
Siemens Medical Solutions USA, Inc. 40 Liberty Boulevard Malvern, PA 19355 Establishment Registration Number 2240869
## Manufacturing Site
Siemens Healthcare GmbH Siemensstr 1 D-91301 Forchheim, Germany
Establishment Registration Number 3004977335
## Submitter Contact Person:
Submitter Contact Person: Monsuru K Bello Regulatory Affairs Specialist Siemens Medical Solutions, Inc. USA 810 Innovation Drive Knoxville, TN 37932 Phone: +1 (202) 856-6099 Email: Monsuru.bello@siemens-healthineers.com
## Alternate Contact:
Alaine Medio Regulatory Affairs Manager Siemens Medical Solutions, Inc. USA (MI) 810 Innovation Drive Knoxville, TN 37932 Phone: +1 (865) 206-0337 Email: alaine.medio@siemens-healthineers.com
#### II. Device Name and Classification
| Product Name: | syngo.CT Extended Functionality |
|-----------------------|----------------------------------|
| Propriety Trade Name: | syngo.CT Extended Functionality |
| Classification Name: | Computed Tomography X-ray System |
| Classification Panel: | Radiology |
| CFR Section: | 21 CFR §892.1750 |
| Device Class: | Class II |
| Product Code: | JAK |
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Image /page/4/Picture/1 description: The image shows the Siemens Healthineers logo. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the words is a graphic of orange dots in a pattern.
#### Predicate Devices III.
## Predicate Device
| Trade Name: | syngo.CT Extended Functionality |
|-----------------------|----------------------------------|
| 510(k) Number: | K214019 |
| Clearance Date: | 01/20/2022 |
| Classification Name: | Computed Tomography X-ray System |
| Classification Panel: | Radiology |
| CFR Section: | 21 CFR §892.1750 |
| Device Class: | Class II |
| Product Code: | JAK |
#### Device Description IV.
syngo.CT Extended Functionality is a software bundle that offers tools to support special clinical evaluations. The "tools" are represented by the so-called Extensions. syngo.CT Extended Functionality can be used to create advanced visualizations and measurements on clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners or other medical imaging modalities (e.g. MR scanners) by using the Extensions. Advanced visualizations and measurements are listed as follows. The subject device in the current software version SOMARIS/8 VB70 has been extended/modified as follows:
- Support of the extension "Average"
- Modifications to the extension "Vessel"
- Modifications to the extension "Interactive Spectral Imaging"
- Modifications to the extension "Oncology"
- "Trauma" Extension – No changes
- "Osteo" Extension - No changes
- "Neuro DSA" Extension – No changes
- "ROI HU Threshold" Extension – No changes
- . "Dual Energy" Extension – No changes
- "Endoscopic Viewing" Extension - No changes
- . "Pulmonary Density" Extension – No changes
- . "General" (Extension Independent Features) – No changes
#### Indications for Use V.
syngo.CT Extended Functionality is intended to provide advanced visualization tools to prepare and process medical images for diagnostic purpose. The software package is designed to support technicians and physicians in qualitative and quantitative measurements and in the analysis of clinical data that was acquired and reconstructed by Computed Tomography (CT) scanners, and possibly other medical imaging modalities (e.g. MR scanners).
An interface shall enable the connection between the syngo.CT Extended Functionality software package and the interconnected CT Scanner system.
Resulting images created with the syngo.CT Extended Functionality software package can be used to assist trained technicians or physicians in diagnosis.
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Image /page/5/Picture/1 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the words is a graphic of orange dots arranged in a circular pattern.
### Comparison of Technological Characteristics with the Predicate Device VI.
The differences and similarities between the above referenced predicate device are listed at a highlevel in the following table:
| Feature | Subject Device | Predicate Device |
|------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | syngo.CT Extended Functionality<br>(SOMARIS/8 VB70) | syngo.CT Extended Functionality<br>(SOMARIS/8 VB60) |
| 1. Average | The extension offers the possibility to<br>average on a pixel-by-pixel basis of two<br>different DICOM images. The "Average"<br>functionality can be used on individual<br>frames of the same series, or for frames<br>belonging to different series. The tool<br>saves a DICOM image as result series. This<br>extension does not introduce any new<br>clinical algorithms or features. | N/A |
| 2. Vessel Extension | The user can perform a vascular<br>evaluation supporting the following main<br>functionalities:<br>• Measuring vessels<br>• Creating DICOM snapshots or result<br>series for documenting findings<br>• Working on images that are acquired<br>with CT or MR scanner systems<br>constituting one or more volumes of<br>vascular structures<br>Modification:<br>Improved quality of the bone removal<br>algorithm for the head & neck region.<br>Segmentation of the bones use a deep<br>learning algorithm instead of a<br>traditional image processing. | The user can perform a vascular<br>evaluation supporting the following main<br>functionalities:<br>• Measuring vessels<br>• Creating DICOM snapshots or result<br>series for documenting findings<br>• Working on images that are acquired<br>with CT or MR scanner systems<br>constituting one or more volumes of<br>vascular structures |
| 3. Interactive Spectral<br>Imaging | Display different representations of Dual<br>Energy data.<br>Modifications:<br>Support of circular and elliptic ROIs. In<br>VB70 version the measurement tool<br>supports all others ROIs (ROI Circle (incl.<br>elliptic) / ROI Freehand / ROI Auto<br>Contour / ROI Polygonal). | Display different representations of Dual<br>Energy data. |
| 4. Oncology | The oncology extension offers tools for<br>localization and evaluation of nodules.<br>Modifications:<br>With SOMARIS/8 VB70, the spectral<br>information displayed for circular ROIs<br>was extended to arbitrarily shaped ROIs. | The oncology extension offers tools for<br>localization and evaluation of nodules. |
The remaining functions in syngo.CT Extended Functionality remain unchanged compared to the predicate version.
- Trauma- displays of sorted large number of reconstruction series into body region specific layouts.
- Osteo Extension - Evaluation of Bone Mineral Density (BMD) values (mg CA-HA/ml).
- Neuro DSA Extension - Selective bone removal from a CT angiography dataset
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# Healthinee
- ROI HU Threshold Extension Evaluation of HU Value distributions
- Dual Energy Extension – Simultaneous evaluation for low and high kV dual energy images
- Endoscopic Viewing Extension – Interactive fly through tubular structures that are filled by either low-intensity or high-intensity material
- . Pulmonary Density – Segmentation of opacity regions inside the lung using an Al algorithm.
The core modification of the subject device as compared to its predicate device (syngo.CT Extended Functionality (SOMARIS/8 VB60)) are the modifications shown in the table above.
### VII. Performance Data
The following performance data were provided in support of the substantial equivalence determination.
## Non-Clinical Testing
This submission contains performance tests (Non-clinical test reports) to demonstrate continued conformance with special controls for medical devices containing software. Non-clinical tests (integration and functional) were conducted for syngo.CT Extended Functionality during product development. These tests have been performed to test the ability of the included features of the subject device. The results of these tests demonstrate that the subject device performs as intended. The result of all conducted testing was found acceptable to support the claim of substantial equivalence.
## Risk Analysis
The risk analysis was completed, and risk control implemented to mitigate identified hazards. The testing results support that all the software specifications have met the acceptance criteria. Testing for verification and validation of the device was found acceptable to support the claims of substantial equivalence.
Siemens hereby certifies that syngo.CT Extended Functionality will meet the following voluntary standards covering electrical and mechanical safety listed below, prior to introduction into interstate commerce:
| Recognition<br>Number | Product<br>Area | Title of Standard | Date of<br>Recognition | Standards<br>Development<br>Organization |
|-----------------------|--------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|------------------------------------------|
| 12-300 | Radiology | Digital Imaging and Communications in<br>Medicine (DICOM) Set; PS 3.1 - 3.20 | 06/27/2016 | NEMA |
| 13-79 | Software | Medical Device Software –Software Life Cycle<br>Processes; 62304:2006 (1st Edition)/A1:2016 | 01/14/2019 | AAMI, ANSI, IEC |
| 5-125 | Software/<br>Informatics | Medical devices – Application of risk<br>management to medical devices; 14971 Third<br>Edition 2019-12 | 12/23/2019 | ISO |
| 5-129 | General I<br>(QS/RM) | Medical devices - Part 1: Application of<br>usability engineering to medical devices<br>IEC 62366-1:2016 | 07/06/2020 | ANSI, AAMI, IEC |
| 5-117 | General I<br>(QS/RM) | Medical devices - Symbols to be used with<br>medical device labels, labelling, and<br>information to be supplied - Part 1: General<br>requirements 15223-1:2016 | 8/21/2017 | ISO |
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Image /page/7/Picture/2 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is in teal, and the word "Healthineers" is in orange. To the right of the words is a graphic of orange dots arranged in a circular pattern.
## VIII. Conclusion
syngo.CT Extended Functionality has the same intended use and same indications for use as the predicate device. The technological characteristics such as image visualization, operating platform, and image measurement are the same as the predicate device.
For the subject device, syngo.CT Extended Functionality, Siemens used the same testing with the same workflows as used to clear the primary predicate device. Siemens considers syngo.CT Extended Functionality to be as safe, as effective, and with performance substantially equivalent to the commercially available predicate devices.
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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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.
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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.
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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.
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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.
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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.
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Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
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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.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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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.