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ZEUS System (Zio Watch)

iRhythm Technologies, Inc. • Cardiovascular • 07/19/2022

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The ZEUS System (Zio Watch) is a prescription-based software medical device intended to assist clinicians in managing Atrial Fibrillation by analyzing ECG and PPG data from the Zio Watch using distinct AI algorithms for ECG analysis (ECGDL) and PPG-based AF context (ACE). Its methodology involves AI-driven data processing, machine learning for pattern detection, and subsequent review by Certified Cardiographic Technicians to generate reports for clinical decision support.

Summary

The ZEUS System (Zio Watch) is a software as a medical device (SaMD) designed to aid clinicians in the management of Atrial Fibrillation (AF) in adult patients aged 22 years and older who are either diagnosed with or susceptible to developing the condition. Operating as part of the prescription-based Zio Watch Service, the system processes and analyzes electrocardiogram (ECG) and photoplethysmogram (PPG) data collected by the Zio Watch wearable device during ambulatory patient monitoring. Its purpose is to detect and report the presence of AF, providing clinicians with detailed ECG information and contextual data regarding AF episodes, thereby assisting in diagnosis, characterization, and management strategies for non-critical care patients. The system is not intended for use on critical care patients. The core functionality of the ZEUS System (Zio Watch) relies on two distinct artificial intelligence (AI) based algorithms that employ machine learning techniques. The ECG Deep Learned (ECGDL) algorithm analyzes ECG recordings to identify cardiac events such as beats, runs, rhythms, and heart rate. Concurrently, the AF Context Engine (ACE) processes continuously recorded PPG-based data to detect the presence of AF and characterize its occurrence over the monitoring period. Both algorithms were trained using extensive datasets of continuous cardiac recordings. The ACE algorithm underwent validation using multi-day PPG recordings from the Zio Watch compared against ECG-based reference data, while the ECGDL algorithm was validated using ECG data obtained from the Zio Watch. The system compiles these analyses into Zio Watch Transmission Reports, which are subsequently quality-reviewed by Certified Cardiographic Technicians (CCTs) before being made available to clinicians through a secure website.

AI Regulatory Concerns

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Keywords

Atrial Fibrillation (AF)ZEUS SystemZio WatchElectrocardiogram (ECG)Photoplethysmogram (PPG)Artificial Intelligence (AI)Machine LearningAF Context Engine (ACE)ECGDLAmbulatory Monitoring

Device Metadata

Submission Number
K213409
Company
iRhythm Technologies, Inc.
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection/diagnosis

Relevant Clinical Questions

  • Q1. How does the AF Context Engine (ACE) algorithm differentiate true Atrial Fibrillation from motion artifacts or other arrhythmias in continuous PPG data, especially during extended ambulatory use?; What are the specific performance metrics (e.g., sensitivity, specificity, positive predictive value, negative predictive value) of the ECGDL and ACE algorithms for AF detection as determined in their respective validation studies (ZWAF Database and Verily Prospective Study)?; How does the ZEUS System (Zio Watch) integrate the discrete ECG recordings with the continuous PPG-derived AF context to provide a unified and actionable report for clinicians, and what is the typical recommended monitoring duration for optimal AF detection?; What specific cybersecurity measures are implemented within the ZEUS System and the Zio Watch Service to ensure the integrity and privacy of patient data throughout its lifecycle, from collection by the Zio Watch to delivery of reports via the secure website?; Given that Certified Cardiographic Technicians (CCTs) review the AI-generated preliminary findings, what is the established protocol for resolving discrepancies between the AI's analysis and the CCT's interpretation, and how is inter-rater reliability among CCTs maintained?

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 Score50/100
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)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(remote)
✓ Detected
HBOMHardware Bill of Materials(sensor)
✓ 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, HBOM 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, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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ZEUS System (Zio Watch) - iRhythm Technologies, Inc. | ESL FDA AI Device Intelligence