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SubtleMR

Subtle Medical, Inc. • Radiology • 09/16/2019

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

SubtleMR aims to improve diagnostic image quality of MRIs by employing a convolutional neural network-based algorithm to either reduce noise or increase sharpness in images from various anatomical regions. Its methodology involves processing DICOM MRI inputs as a Software as a Medical Device (SaMD) through fixed nonlinear filters, with its image enhancement capabilities scientifically validated through retrospective clinical data demonstrating significant improvements in signal-to-noise ratio and structural clarity.

Summary

SubtleMR is a Software as a Medical Device (SaMD) designed to enhance Magnetic Resonance Imaging (MRI) images acquired from 1.2 Tesla, 1.5 Tesla, or 3 Tesla scanners. The software utilizes a convolutional neural network (CNN)-based algorithm, which functions as a fixed nonlinear filter, to improve image quality by either reducing noise or increasing image sharpness. The specific algorithmic parameters vary depending on the selected enhancement, though the underlying network designs are similar. Users, typically radiologists in imaging centers, clinics, or hospitals, choose the desired enhancement (noise reduction or sharpness increase) via DICOM Series Description, command line arguments, or environment variables. SubtleMR processes standard DICOM MRI input files from the file system, produces enhanced DICOM images that co-exist with the originals, and has no direct user interface; enhanced images are viewed on existing Picture Archiving and Communication System (PACS) workstations. The software is indicated for reducing image noise in head, spine, neck, and knee MRI scans, and for increasing image sharpness specifically in non-contrast enhanced head MRI. SubtleMR's performance was validated through studies using retrospective clinical data. The noise reduction capability was confirmed by demonstrating an average improvement in signal-to-noise ratio (SNR) of 5% or more in selected regions of interest, while maintaining the visibility of small structures with an average change of 0.5 Likert scale points or less compared to original images. The sharpness increase function was validated by showing improved thickness of anatomical structures and sharpness of structure boundaries in at least 90% of the test datasets. These results confirmed the device's effectiveness in enhancing MRI image quality according to its specified functions.

AI Regulatory Concerns

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Keywords

SubtleMRMRI EnhancementConvolutional Neural NetworkImage Processing SoftwareNoise ReductionImage SharpnessDICOMSaMD (Software as a Medical Device)RadiologySignal-to-Noise Ratio (SNR)

Device Metadata

Submission Number
K191688
Company
Subtle Medical, Inc.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Generation
AI Subclass
image enhancement

Relevant Clinical Questions

  • Q1. How does the performance of the convolutional neural network in SubtleMR compare to other image enhancement algorithms in terms of computational efficiency and impact on diagnostic accuracy across different MRI sequences and anatomies?; What specific architectural details of the convolutional neural network are employed for noise reduction versus sharpness increase, and how were these architectures optimized during development?; Are there any known limitations or contraindications for using SubtleMR, such as specific MRI acquisition parameters, patient populations, or pathological conditions where its performance might be suboptimal or lead to artifacts?; How robust is the SubtleMR algorithm to variations in input image quality, MRI scanner vendor, or field strengths beyond the tested 1.2T, 1.5T, and 3T, and what is the expected performance under such varied conditions?; What was the detailed statistical distribution (e.g., range, standard deviation) of the signal-to-noise ratio improvement and Likert scale differences observed in the noise reduction performance test, beyond the reported average values?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (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 Score15/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan⚠ Not mentioned 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(deep learning, neural network, algorithm, dataset)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(network)
✓ 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(environment)
✓ 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.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• 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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SubtleMR - Subtle Medical, Inc. | ESL FDA AI Device Intelligence