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d-Nav System

Hygieia, Inc • Anesthesiology • 02/04/2019

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The d-Nav System is a prescription software designed to optimize insulin management for adults with Type 2 diabetes by providing personalized insulin dose recommendations via a mobile application. Its methodology relies on an HCP-configured, algorithm-driven approach that analyzes blood glucose trends against target ranges, offering different treatment plans and leveraging local or cloud-based processing for dose calculations and instruction updates.

Summary

The d-Nav System is a prescription-only software device designed for adults with Type 2 diabetes to aid in optimizing insulin management. It consists of two main software elements: a Phone App for patients and a Website for Health Care Providers (HCPs). Patients use the Phone App on a mobile device to input blood glucose data (manually or automatically from a linked glucose meter via the cloud) and receive recommended insulin doses. HCPs, after training, use the d-Nav Website to configure the patient's Phone App, setting up physician-prescribed, patient-specific starting insulin dose instructions, including the treatment algorithm (treatment plan), insulin drug, and initial doses. The core of the system is the d-Nav Get-Dose Library, which calculates the next insulin dose; its "Recommend Dose" function is local on the phone, while the "Update Insulin Instruction" function can be local or cloud-based across four different operational models. The d-Nav System's methodology integrates HCP-prescribed starting parameters with automated dosing guidance. This guidance is based on comparing regularly measured blood glucose data trends against a device-specified target range, which is fixed based on the chosen treatment plan (basal, twice daily mixed, basal-bolus, or basal-bolus with carbohydrate counting). The dosing algorithm adjusts insulin doses based on these trends: decreases can be daily, while increases occur no more frequently than weekly. For dose decreases, it uses a single dose response, and for both increases and decreases, it can use an average response to similarly timed doses over a one-week period. The system includes safety checks, such as limits on dose adjustments (generally ≤ ±20%, with exceptions for basal-bolus plan increases up to <+30%) and halting titration if doses deviate significantly or exceed HCP-set thresholds. The architecture involves a mobile phone app (iOS/Android), a cloud-based d-Nav System Server (on AWS) housing databases and webservices, and options for local or cloud-based storage and processing of the Get-Dose Library functions.

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

Insulin ManagementType 2 DiabetesDose CalculationSoftware as a Medical Device (SaMD)Blood Glucose MonitoringTitration AlgorithmCloud ConnectivityMobile Health (mHealth)Prescription SoftwarePatient-Specific Dosing

Device Metadata

Submission Number
K181916
Company
Hygieia, Inc
Panel
Anesthesiology
Product Code
N/A
Data Type
EHR
Clinical Function
Intervention
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the d-Nav System's algorithm for weekly average response compare in glycemic control efficacy and patient adherence to systems using only single-dose response calculations for insulin adjustments in Type 2 diabetes patients?; What are the specific safety thresholds and deviation percentages that trigger a halt in titration, and how were these determined to ensure patient safety across different treatment plans?; In real-world usage, what is the typical latency for insulin instruction updates when the "Get-Dose Library Update Insulin Instruction" function is cloud-hosted, and how does intermittent cloud connectivity impact dose recommendation accuracy and timeliness?; What human factors were identified as most critical during usability testing for both the patient Phone App and the HCP Website, particularly regarding the setup of complex treatment plans like basal-bolus with carbohydrate counting?; Given that changes in insulin dose recommendations can be sent to the patient without immediate prescriber concurrence, what mechanisms or alerts are in place for HCPs to monitor and intervene if a patient's glucose trends or dose adjustments become concerning?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Authorized before §524B enforcement

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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 Score30/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableNo

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(algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud, server, hosted, remote, connectivity)
✓ 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(operational)
✓ 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, OBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

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

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d-Nav System - Hygieia, Inc | ESL FDA AI Device Intelligence