Software as a Medical Device, Therapeutic, Pediatric
Indications for Use
The MiniMed Go app is indicated for people with diabetes or their caregivers. The indicated patient population varies based on the combination of connected CGM and injector. Simplera sensor only: Diabetes patients ages 18 years and older InPen smart insulin pen only: Diabetes patients ages 7 years and older, or younger patients under the supervision of an adult caregiver Simplera sensor and InPen smart insulin pen: Diabetes patients ages 18 years and older Instinct sensor and InPen smart insulin pen: Diabetes patients ages 7 years and older, or patients ages 2 to 6 years under the supervision of an adult caregiver The dose calculator of the MiniMed Go app is indicated for the management of diabetes by people with diabetes for calculating an insulin dose based on user entered data, most recent glucose value and active insulin. To calculate a recommended insulin dose, a healthcare professional must provide patient-specific therapy settings including glucose target, insulin-to-carbohydrate ratio, and insulin sensitivity parameters to be programmed into the software prior to use. For an insulin dose based on fixed or variable meal sizes, a healthcare professional must also provide patient-specific fixed doses or meal sizes to be programmed into the software prior to use. When connected to a CGM, the app supports display of Sensor Glucose (SG) values and trend arrows. When connected to the InPen smart insulin pen, the app supports automatic logging of insulin doses, tracking of active insulin, and a dose calculator. The app also supports alerts or reminders for low glucose, high glucose, and insulin doses.
Device Story
Software-only mobile application for diabetes management; connects via Bluetooth/NFC to compatible CGMs (Simplera, Instinct) and InPen smart insulin injector. Consolidates data visualization, insulin dose calculation, and event logging. Input: user-entered glucose/meal data, real-time CGM sensor glucose (SG) values, and insulin delivery logs from InPen. Operation: calculates insulin doses based on HCP-programmed therapy settings (glucose target, insulin-to-carbohydrate ratio, insulin sensitivity) and active insulin tracking to prevent stacking. Output: recommended insulin doses, SG trends, and alerts (high/low glucose, missed doses). Used in home environments by patients or caregivers. App serves as primary display/control interface; replaces standalone CGM apps. Benefits: unified platform for therapy management, improved user experience, and automated logging of insulin doses.
Clinical Evidence
No clinical data. Human factors validation studies conducted with 50 participants (17 Type 1 adults, 16 Type 2 adults, 17 pediatric) demonstrated that intended users can safely and effectively perform critical tasks without use-related errors.
Technological Characteristics
Software-only mobile application or COTS Samsung smartphone (App Manager) with Medtronic case. Connectivity: BLE, NFC, Wi-Fi. Software lifecycle per IEC 62304; usability per IEC 62366-1. Cybersecurity controls implemented for data handling. Major level of concern software.
Indications for Use
Indicated for people with diabetes or their caregivers. Population varies by device combination: Simplera sensor (18+); InPen (7+ or younger with caregiver); Simplera + InPen (18+); Instinct sensor + InPen (7+ or 2-6 with caregiver).
Regulatory Classification
Identification
A predictive pulmonary-function value calculator is a device used to calculate normal pulmonary-function values based on empirical equations.
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FDA
U.S. FOOD & DRUG
ADMINISTRATION
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
## I Background Information:
A 510(k) Number
K253512
B Applicant
Medtronic MiniMed
C Proprietary and Established Names
MiniMed Go App
D Regulatory Information
| Product Code(s) | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| NDC | Class II | 21 CFR 868.1890 – Predictive pulmonary-function value calculator | Clinical Chemistry |
## E Purpose for Submission:
New device
## II Intended Use/Indications for Use:
A Intended Use(s):
See Indications for Use below.
B Indication(s) for Use:
The MiniMed Go app is indicated for people with diabetes or their caregivers. The indicated patient population varies based on the combination of connected CGM and injector.
Simplera sensor only: Diabetes patients ages 18 years and older
InPen smart insulin pen only: Diabetes patients ages 7 years and older, or younger patients under the supervision of an adult caregiver
Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
www.fda.gov
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Simplera sensor and InPen smart insulin pen: Diabetes patients ages 18 years and older
Instinct sensor and InPen smart insulin pen: Diabetes patients ages 7 years and older, or patients ages 2 to 6 years under the supervision of an adult caregiver
The dose calculator of the MiniMed Go app is indicated for the management of diabetes by people with diabetes for calculating an insulin dose based on user entered data, most recent glucose value and active insulin.
To calculate a recommended insulin dose, a healthcare professional must provide patient-specific therapy settings including glucose target, insulin-to-carbohydrate ratio, and insulin sensitivity parameters to be programmed into the software prior to use.
For an insulin dose based on fixed or variable meal sizes, a healthcare professional must also provide patient-specific fixed doses or meal sizes to be programmed into the software prior to use.
When connected to a CGM, the app supports display of Sensor Glucose (SG) values and trend arrows. When connected to the InPen smart insulin pen, the app supports automatic logging of insulin doses, tracking of active insulin, and a dose calculator. The app also supports alerts or reminders for low glucose, high glucose, and insulin doses.
## C Special Conditions for Use Statement(s):
Rx - For Prescription Use Only.
- Follow the instructions and safety warnings in this user guide to receive alerts. Missing alerts from the app can result in undetected low and high glucose levels.
- Always use a BG meter reading to make treatment decisions if no sensor data are available or if symptoms do not match the SG value.
- Do not use the app if you have insufficient vision or hearing as you will need to verify alerts sent by the app.
- Do not use the app without understanding how the mobile device settings work. If any settings are changed, the app display and notification features may not work as intended, including not receiving SG alerts or status alerts.
- Make sure that your settings in the app are correct. Your healthcare professional should provide your therapy settings. Incorrect settings may result in incorrect recommendations which may result in hypoglycemia or hyperglycemia.
- Make sure Bluetooth is on, even if the mobile device is in airplane mode. If Bluetooth is off, the app will not send SG information or alerts.
- Do not force close the app. If the app is closed, the app will not send SG information or alerts.
- Check the app occasionally to make sure it is running. The mobile device may close the app automatically when another app is in use, such as a game. If the app is closed, the app will not send SG alerts.
- Always make sure to open the app after the mobile device restarts to ensure the app sends SG alerts.
- Turning off automatic updates on the mobile device may help to avoid unintentionally updating to an operating system that is not confirmed as compatible with the app.
K253512 - Page 2 of 7
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- When power saving settings are enabled, the mobile device may delay the alerts and notifications from the app.
- Alerts for the app will sound through headphones when headphones are connected. If headphones are connected but they are not being used, SG alerts may not be heard.
- Always allow notifications for the app. If notifications are turned off, the app will not send any alerts, including the Urgent Low Alert.
- If alerts and reminders are disabled on the mobile device, you will not receive them, including the Urgent Low Alert.
## III Device Description
The MiniMed Go App is a software-only mobile application intended to connect with compatible Continuous Glucose Monitors (CGMs) – including the Simplera Sensor (P160007/S047) and Instinct Sensor (K233537), and the InPen smart insulin injector (K242775). The App enables people with diabetes to manage their therapy through data visualization, insulin dose calculation, and event logging. The App can be installed on compatible mobile devices, enabling users to effectively manage their diabetes. The compatible devices include the user’s Android/iOS mobile phones or the App Manager, a compatible display device configured to host Medtronic MiniMed applications.
The App Manager is a compatible display device configured to host Medtronic MiniMed applications. It can be used as an alternative to installation of MiniMed Go App on the user’s personal compatible smartphone. The App Manager is a durable handheld medical device consisting of commercial off-the-shelf (COTS) Samsung smartphone hardware, with a Medtronic branded case, operating on the Android OS with MiniMed Go App pre-installed and configured for diabetes management use only. The App Manager is configured via a Mobile Device Management (MDM) service to lock down specified functionalities and to ensure that the App Manager is used solely as a medical device.
The App Manager is used in conjunction with the MiniMed Go App to facilitate communication with the InPen, Simplera sensor and Instinct sensor via COTS Samsung device’s BLE and NFC connectivity. Its Wi-Fi connectivity is used to upload data to CareLink Cloud.
The App functions as the primary display and control interface for the InPen and connected CGM systems, consolidating device management, data visualization, and alert functions within a single software platform. It replaces the standalone CGM applications and serves as the central interface through which users manage connected devices and receive CGM, InPen and other system notifications. This integration provides a unified platform that supports diabetes therapy management and improves the overall user experience through consolidated device interaction.
## IV Substantial Equivalence Information:
A Predicate Device Name(s):
InPen App
B Predicate 510(k) Number(s):
K242775
K253512 - Page 3 of 7
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C Comparison with Predicate(s):
| Device & Predicate Device(s): | K253512 | K242775 |
| --- | --- | --- |
| Device Trade Name | MiniMed Go App | InPen App |
| General Device Characteristic Similarities | | |
| Intended Use/Indications For Use | The MiniMed Go App is intended to manage diabetes by calculating insulin doses using user entered glucose value, logging the insulin doses administered by InPen and providing alerts and reminders. Additionally, the App is also intended to manage diabetes by directly connecting to compatible CGMs for display of SG values and trends and providing CGM related alerts and reminders. | Same |
| Prescription Use | Yes | Same |
| Environment of Use | Home | Same |
| Operating Systems | Android and iOS | Same |
| Communication with Insulin Pumps | No | Same |
| Control or Affect Insulin Delivery | No | Same |
| Insulin dose calculator | Allows users to calculate rapid-acting bolus doses using glucose level, anticipated meal intake (carb counting, fixed dose or meal estimation) and calculated active insulin to prevent insulin stacking. Active insulin display shows users how much rapid-acting insulin is remaining in their body from prior injections. | Same |
| General Device Characteristic Differences | | |
| Compatible Medical Devices | InPen Smart Insulin Injector Simplera Sensor | InPen Smart Insulin Injector |
K253512 - Page 4 of 7
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| | Instinct Sensor | |
| --- | --- | --- |
| Sensor Glucose (SG) Readings | Obtained directly from connected CGMs and displayed on the landing page and retrospective graph. | Obtained from the cloud and displayed on the landing page and retrospective graph |
| Connection to CareLink | Data from all compatible devices is shared with CareLink cloud services. | The InPen App is not directly connected to CareLink; however, SG values are sent from CareLink to the InPen Cloud and subsequently the InPen App. |
| Compatible Medical Devices | InPen Smart Insulin Injector Simplera Sensor Instinct Sensor | InPen Smart Insulin Injector |
| App Controller | In addition to installation on user’s compatible smart device, MiniMed Go App can also be used on a durable handheld medical device consisting of commercial off-the-shelf (COTS) Samsung smartphone hardware, with a Medtronic branded case, operating on the Android OS with MiniMed Go App pre-installed and configured for diabetes management use only. | InPen App can be installed on user’s compatible smart device. |
V Standards/Guidance Documents Referenced:
IEC 1162366-1 Edition 1.1 2020-06 CONSOLIDATED VERSION
Medical devices - Part 1: Application of usability engineering to medical devices
IEC 1162304 Edition 1.1 2015-06 CONSOLIDATED VERSION
Medical device software - Software life cycle processes
IEC 1182304-1 Edition 1.0 2016-10
Health software - Part 1: General requirements for product safety
ISO 1120417 First edition 2021-04 Corrected version 2021 -12
Medical devices - Information to be supplied by the manufacturer
ISO 1115223-1 Fourth edition 2021-07
Medical devices - Symbols to be used with information to be supplied by the manufacturer - Part 1: General requirements
K253512 - Page 5 of 7
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VI Performance Characteristics:
A. Non-Clinical Performance
Not applicable.
B. Clinical Studies:
Not applicable.
C. Other Supportive Device Performance Characteristics Data
Usability:
The sponsor provided comprehensive human factors engineering protocols and study results demonstrating that intended users can safely and effectively perform all critical tasks associated with the modified device features. The study participants were representative of the device's intended user population, including:
User Group 1: Adult Type 1 Diabetes (n=17)
- Age Range: 19-69 years (Average: 38.4 years)
- CGM Experience: 14 experienced, 3 naive
- Independence Level: 14 fully independent, 3 caregiver dyads
- Device Distribution: 8 iOS, 9 Android
User Group 2: Adult Type 2 Diabetes (n=16)
- Age Range: 36-80 years (Average: 59.6 years)
- CGM Experience: 14 experienced, 2 naive
- Independence Level: 11 fully independent, 5 caregiver dyads
- Device Distribution: 8 iOS, 8 Android
User Group 3: Pediatric Participants (n=17)
- Age Range: 4-17 years (Average: 11.7 years)
- CGM Experience: All 17 experienced, 0 naive
- Dependency Levels:
- 5 Fully dependent (require complete assistance)
- 9 Partially dependent (require some assistance)
- 2 Fully independent (manage tasks without assistance)
- Device Distribution: 9 iOS, 8 Android
The human factors validation studies adequately demonstrated that users could operate the device safely without use-related errors that could compromise patient safety or treatment effectiveness. The results support a determination of substantial equivalence to the predicate device regarding usability and user interface design.
Software:
The sponsor provided comprehensive software documentation in accordance with FDA's "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (May 11, 2005). The documentation was consistent with the requirements for
K253512 - Page 6 of 7
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software classified as having a major level of concern, reflecting the device's potential impact on patient safety through insulin dosing recommendations.
The software documentation package included appropriate:
- Software requirements and design specifications demonstrating traceability between intended use and software functionality
- Verification and validation protocols with evidence of comprehensive testing across anticipated use scenarios
- Risk analysis and mitigation strategies addressing potential software-related hazards and their clinical implications
- Cybersecurity considerations appropriate for the device's connectivity and data handling capabilities
The submitted software documentation was determined to be acceptable and sufficient to support the safety and effectiveness determination for this 510(k) submission.
## VII Proposed Labeling:
The labeling supports the finding of substantial equivalence for this device.
## VIII Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
K253512 - Page 7 of 7
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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
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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.