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CLEWICU System (ClewICUServer and ClewICUnitor)

CLEW Medical Ltd. • Cardiovascular • 01/09/2021

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The CLEWICU System is an adjunctive clinical decision support tool that employs machine learning algorithms to analyze comprehensive ICU patient data, aiming to predict hemodynamic instability and identify low-risk patients. Its science relies on models trained and validated on retrospective clinical data to provide early, actionable insights for clinicians, thereby potentially improving patient management in critical care settings.

Summary

The CLEWICU System, comprising the ClewICUServer and ClewICUnitor, is a stand-alone analytical software product designed to provide clinicians with physiological insights into the likelihood of future hemodynamic instability in adult intensive care unit (ICU) patients, aged 18 years and over. It also aims to identify patients at low risk for clinical deterioration. The system utilizes machine learning models to process patient data imported from Electronic Health Records (EHR) and other medical devices. The ClewICUServer computes two key indicators: the CLEWHI index, representing the likelihood of hemodynamic instability requiring vasopressor or inotrope support, and the CLEWLR indication, signifying a patient is at low risk. The ClewICUnitor, a web-based interface, displays these indices, associated notifications, and overall unit status. It is intended as an adjunctive tool, meaning its predictions are for reference only and should not be the sole basis for therapeutic decisions. The system's technological characteristics involve receiving near-real-time patient health data (including vital signs, nursing assessments, flowsheet data, medications, and lab data), analyzing this data to generate predictions of future clinically significant cardiac events, and alerting healthcare providers when a patient’s risk reaches a pre-defined threshold. Performance was assessed through software verification and validation, risk analysis, cybersecurity review, and human factors testing with 15 intended users. A retrospective clinical validation was conducted using a dataset from WakeMed Health System, for which a tagging system was developed and validated against human physician readers to establish clinical truth. The Hemodynamic Instability (HI) model demonstrated a sensitivity of 60.6%, a Positive Predictive Value (PPV) of 22.3%, and a median lead-time for true positive alerts of 3.0 hours. The Low Risk (LR) model showed a specificity of 95.7% and a sensitivity of 21.4%.

AI Regulatory Concerns

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Keywords

CLEWICU SystemHemodynamic InstabilityPredictive AnalyticsMachine LearningIntensive Care Unit (ICU)Clinical Decision SupportCLEWHI IndexCLEWLR IndicationRetrospective Clinical ValidationPhysiological Insight

Device Metadata

Submission Number
K200717
Company
CLEW Medical Ltd.
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
predictive

Relevant Clinical Questions

  • Q1. How does the reported Positive Predictive Value of 22.3% for the Hemodynamic Instability model impact its clinical utility and the potential for alarm fatigue in a busy ICU setting?; What specific patient subgroups within the ICU (e.g., surgical, medical, trauma) were included in the WakeMed dataset, and was any variability in model performance observed across these subgroups?; Could the CLEWLR (Low Risk) model, with a sensitivity of 21.4%, be reliably used to de-escalate monitoring or intervention intensity, and what are the safety implications?; What methodology was used to validate the 'tagging system' against human physician readers, and what was the level of agreement achieved (e.g., Kappa statistic)?; Beyond the listed inputs (vital signs, nursing assessments, flowsheet data, medications, lab data), are there plans to incorporate other data sources, such as imaging or free-text notes, to enhance predictive accuracy?

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 Score45/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment✓ Detected 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(machine learning, algorithm, dataset, model performance)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(server)
✓ 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.

• 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, OBOM. These may be present in the full FDA submission.

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CLEWICU System (ClewICUServer and ClewICUnitor) - CLEW Medical Ltd. | ESL FDA AI Device Intelligence