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Radiation Planning Assistant (RPA)

University of Texas, MD Anderson Cancer Center • Radiology • 05/17/2023

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The Radiation Planning Assistant (RPA) is an assistive software tool designed to streamline radiotherapy treatment planning for specific cancers by employing deep learning algorithms for automated contouring and optimized plan generation using CT images. Its methodology integrates with existing clinical workflows by requiring user review and finalization in their primary Treatment Planning System, with performance data indicating comparable dosimetric outcomes to conventional planning, often with a conservative approach to organ sparing.

Summary

The Radiation Planning Assistant (RPA) is a web-based software designed to aid in radiotherapy treatment planning for head and neck, cervix, breast, and brain metastasis cancers. It utilizes CT images for external beam photon therapy planning, offering automated contouring, automated planning with dose optimization, and quality control checks. The system's science relies on deep learning algorithms for contouring, trained on extensive patient CT datasets, and for VMAT planning, it employs pre-set optimization objectives leveraging some Eclipse system features. Critically, the RPA serves as an assistive tool; all its outputs require import, review, editing, and final dose calculation within a user's primary Treatment Planning System (TPS). Non-clinical software validation confirmed the RPA's adherence to specifications. Multicenter clinical studies evaluated its performance across various anatomical sites (cervix, chest wall, head and neck, whole brain) and CT scanner types. Results generally demonstrated high concordance with clinical plans regarding dosimetric metrics for safety and effectiveness, often with the RPA exhibiting a more conservative approach to organ-at-risk sparing (e.g., bowel bag in cervix, cochlea in head/neck, lenses in whole brain). Across all sites, the RPA showed proficient body contouring (Surface DSC > 0.8) and accurate isocenter identification (<3mm deviation), underscoring its utility in the initial stages of radiation treatment planning.

AI Regulatory Concerns

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Keywords

Radiation Planning Assistant (RPA)Automated ContouringRadiotherapy PlanningDeep Learning AlgorithmsCT-based PlanningTreatment Plan OptimizationPhoton Beam TherapyDosimetric EvaluationClinical PerformanceAssistive Software Tool

Device Metadata

Submission Number
K222728
Company
University of Texas, MD Anderson Cancer Center
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 RPA's deep learning contouring algorithms vary across different CT image qualities or scanner protocols not included in the training/testing datasets?; Given that RPA-generated VMAT plans have pre-set optimization objectives and are not easily editable within the RPA, what is the typical extent of modification required when these plans are imported into a user's primary TPS, and how does this impact overall planning efficiency?; The document notes some differences in dosimetric outcomes (e.g., cochlea in head/neck, bowel bag/kidney/bladder in cervix VMAT) compared to clinical plans, often citing RPA's 'conservative' nature. What specific aspects of the RPA's algorithms lead to this conservatism, and could it potentially compromise optimal target coverage or lead to unnecessary organ-at-risk sparing in certain clinical scenarios?; For the 'simple plans' where the plan is generated before contour review, what mechanisms are in place to flag potentially suboptimal contours that could significantly impact the initial plan, especially if a user might overlook subtle contouring errors before proceeding to their TPS?; The RPA was trained on data from MD Anderson. How robust is the system's performance when applied to patient populations with significantly different anatomical variations, disease presentations, or imaging protocols encountered in diverse global oncology practices?

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 Score5/100
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, algorithm, dataset)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not 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 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, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Radiation Planning Assistant (RPA) - University of Texas, MD Anderson Cancer Center | ESL FDA AI Device Intelligence