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SubtleMR

Subtle Medical, Inc. • Radiology • 02/26/2021

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

SubtleMR is an image processing software that employs convolutional neural network algorithms to enhance MR images by reducing noise across a wide range of anatomical regions or increasing sharpness in head MRIs. The device aims to improve image quality for radiological assessment, with its efficacy demonstrated through performance tests showing quantitative SNR improvements and qualitative enhancements in image clarity and structural definition.

Summary

SubtleMR Version 2.0.0 is a Software as a Medical Device (SaMD) that utilizes a convolutional neural network-based algorithm to enhance the quality of Magnetic Resonance (MR) images. The software processes standard DICOM MR images acquired from 1.2 Tesla, 1.5 Tesla, or 3 Tesla scanners, offering functionalities for either image noise reduction or image sharpness enhancement. It operates as a fixed nonlinear filter without a direct user interface, with the choice of enhancement mode determined by the end-user (radiologists in imaging centers, clinics, or hospitals) via DICOM Series Description, command line, or environment variables. The output consists of enhanced images intended to improve diagnostic utility. The device's indications for use have been expanded to include noise reduction for additional anatomical regions: head, spine, neck, abdomen, pelvis, prostate, breast, and musculoskeletal MRI. Furthermore, its capability to increase image sharpness now applies to both contrast-enhanced and non-contrast-enhanced head MRIs. Performance testing, utilizing retrospective clinical data, demonstrated that SubtleMR met its acceptance criteria. For noise reduction, the signal-to-noise ratio (SNR) in selected regions of interest improved on average by ≥5%, while the visibility of small structures was maintained (average change ≤0.5 Likert scale points). For sharpness enhancement, the thickness of anatomic structures and the sharpness of structure boundaries were improved in at least 90% of the test datasets.

AI Regulatory Concerns

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Keywords

SubtleMRMRIimage enhancementconvolutional neural networknoise reductionimage sharpnessDICOMSoftware as a Medical Device (SaMD)radiologysignal-to-noise ratio

Device Metadata

Submission Number
K203182
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. What are the specific quantitative differences in signal-to-noise ratio improvement and sharpness enhancement when SubtleMR is applied to images from 1.2T, 1.5T, and 3T scanners respectively?; How does the performance of SubtleMR's noise reduction vary across the newly added anatomical locations (abdomen, pelvis, prostate, breast, musculoskeletal MRI) in terms of SNR improvement and preservation of diagnostic details?; Are there specific MRI sequences (e.g., T1-weighted, T2-weighted, FLAIR, DWI) where SubtleMR demonstrates superior or limited efficacy for noise reduction or sharpness enhancement?; What is the typical processing time for SubtleMR per series or study, and how might this integrate into high-volume clinical workflows?; Beyond the ≥5% average SNR improvement, what was the range and standard deviation of SNR improvement and the Likert scale change for visibility of small structures in the noise reduction performance tests?

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(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