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Notal Vision Home Optical Coherence Tomography (OCT) System

Notal Vision Inc • Ophthalmic • 05/15/2024

De NovoIEC 62304 Class B§524B Cyber Device
FDA Summary PDF

Device Purpose

The Notal Vision Home OCT System (SCANLY) is a patient-operated spectral-domain optical coherence tomography device utilizing a cloud-based deep learning AI to monitor neovascular age-related macular degeneration. By enabling daily self-scans and quantifying retinal fluid biomarkers, it aims to inform timely ophthalmological interventions and improve management between clinic visits.

Summary

The Notal Vision Home OCT System (SCANLY) is a home-use spectral-domain optical coherence tomography (SD-OCT) device designed for patients with neovascular age-related macular degeneration (nAMD). Its primary purpose is to allow patients to self-administer daily retinal scans, facilitating continuous monitoring of their condition between regular clinic visits. The system employs a cloud-based artificial intelligence (AI) that analyzes these images, specifically segmenting and quantifying the volumes of subretinal and intraretinal fluid, which are critical biomarkers indicative of disease activity. The SCANLY system integrates a user-friendly OCT imager with a sophisticated deep-learning algorithm, which has been trained on thousands of retinal scans to accurately detect the presence and volume of fluid. Clinical trials, which included over 5,400 home scans, demonstrated high user compliance, with 97% of participants successfully producing high-quality images. Furthermore, the AI's analytical performance exhibited strong agreement with evaluations made by expert human graders, underscoring its reliability in monitoring retinal fluid and its potential to support earlier clinical intervention.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

Home OCTNeovascular AMDRetinal FluidArtificial IntelligenceSelf-monitoringSpectral-Domain OCTDeep LearningBiomarkersOphthalmologyTreatment Scheduling

Device Metadata

Submission Number
DEN230043
Company
Notal Vision Inc
Panel
Ophthalmic
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the AI algorithm differentiate between subretinal and intraretinal fluid, and what is the clinical significance of quantifying each type separately for nAMD management?; What are the long-term adherence rates for patients using the SCANLY home OCT system, and how does this compare to adherence with other home monitoring devices for chronic conditions?; How does the system's sensitivity and specificity for detecting changes in fluid volume compare to standard in-clinic OCT devices, particularly for subtle or early changes?; What is the learning curve for patients to consistently produce high-quality scans, and what training or support mechanisms are most effective?; How will the integration of AI-driven home monitoring data impact ophthalmologists' workflow and decision-making processes for nAMD treatment, particularly regarding treat-and-extend protocols?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via De Novo pathway; IEC 62304 Class B (software safety classification); Qualifies as a cyber device under §524B (post-Dec 2023, networked)

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score25/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment⚠ Not in summary - likely in full submission per §524B
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(deep learning, algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, remote)
✓ Detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Cybersecurity risk assessment not referenced in AI-generated device summary. FDA cybersecurity guidance (2023) expects this for cyber devices.

• Not detected in AI-generated device summary: SBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Notal Vision Home Optical Coherence Tomography (OCT) System - Notal Vision Inc | ESL FDA AI Device Intelligence