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ART-PLAN

TheraPanacea • Radiology • 06/17/2022

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

ART-Plan is a medical image management and processing software that utilizes AI-driven deep learning algorithms for automated contouring of anatomical structures and generation of pseudo-CT images from multi-modal scans (CT, MR, PET). Its purpose is to enhance efficiency and standardization in radiotherapy treatment planning for cancer patients by providing tools for image visualization, registration, segmentation, and data export to treatment planning systems, with performance validated through extensive non-clinical testing.

Summary

ART-Plan version 1.10.0 is an advanced software application designed for cancer patients undergoing radiation treatment planning. It assists medical professionals by providing tools for 3D multi-modal medical image visualization, processing, and management, supporting DICOM 3.0 compliant datasets from CT, PET-CT, CBCT, 4D-CT, and MR imaging. Key functionalities include AI-driven automatic contouring of organs at risk (OARs) and healthy lymph nodes on both CT and MR images, as well as semi-automatic and manual segmentation tools. The software facilitates the registration (rigid and deformable) of anatomical and functional images, allowing for fused image displays to aid in comparison and delineation. A significant feature is its capability to generate, visualize, evaluate, and modify pseudo-CT images from MRI data, particularly for brain and male pelvis anatomies. The system comprises two main modules, SmartFuse for image registration and Annotate for contouring. ART-Plan v1.10.0 introduces improvements such as enhanced automatic segmentation across more anatomies (including female pelvis on CT, and various regions on MR), image registration for 4D-CT and CBCT, and cloud-based deployment. Its AI models for segmentation and pseudo-CT generation were trained on extensive, pseudo-anonymized real-world datasets, with performance validated against established clinical acceptance criteria (e.g., Dice Similarity Coefficient, gamma passing rates, qualitative evaluations) and compared favorably to predicate devices. The training data demographics were shown to be representative, and strategies were employed to mitigate biases from imaging hardware or patient anatomical diversity. Non-clinical testing confirmed the device's usability, safety, and effectiveness for its intended use in radiotherapy planning.

AI Regulatory Concerns

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Keywords

radiotherapy planningAI contouringimage registrationpseudo-CT generationDICOMmulti-modal imagingorgans at risk (OAR)segmentation softwaredeep learningmedical image processing

Device Metadata

Submission Number
K220813
Company
TheraPanacea
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Intervention
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the performance of the AI-based contouring for specific, challenging OARs (e.g., brachial plexus, individual cranial nerves) compare to expert manual delineation in terms of accuracy and time-saving, especially across different image qualities and pathologies?; What is the quantitative impact of using the generated pseudo-CT from MRI on dose calculation accuracy for different radiotherapy treatment modalities (e.g., VMAT, IMRT, SBRT) and across various anatomical sites beyond brain and male pelvis?; How robust is the deformable image registration algorithm when dealing with significant anatomical changes between imaging sessions, such as tumor shrinkage or post-surgical alterations, and what are the typical failure modes?; Given the training data dependencies (e.g., ViewRay 0.35T MR, Philips 1.5T T2 for specific models), what is the performance degradation, if any, when ART-Plan is used with data from MR scanners with different field strengths, vendors, or sequences not heavily represented in the training set?; What are the specific user validation steps recommended or enforced by the ART-Plan workflow before exporting AI-generated contours or pseudo-CT data to a treatment planning system, and how does the system flag uncertainties or areas requiring closer scrutiny?

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 Score55/100
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(training data, training set, deep learning, algorithm, dataset)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cloud)
✓ Detected
HBOMHardware Bill of Materials(hardware)
✓ Detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials(deployment)
✓ 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, 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, CBOM, VDR/VEX. These may be present in the full FDA submission.

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ART-PLAN - TheraPanacea | ESL FDA AI Device Intelligence