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REMI AI Discrete Detection Module

Epitel, Inc. • Neurology • 01/03/2024

510(k)IEC 62304 Class B§524B Cyber Device
FDA Summary PDF

Device Purpose

The REMI-AI Discrete Detection Module is an assistive software tool that analyzes 4-channel REMI EEG recordings to automatically mark potential electrographic seizures lasting at least 10 seconds in adult and pediatric patients (6+ years), aiding physician review. Its scientific basis lies in a machine learning algorithm trained and validated against expert epileptologist consensus on concurrently acquired EEG data, demonstrating specific performance in terms of sensitivity and false alarm rate for seizure event identification.

Summary

The REMI-AI Discrete Detection Module (REMI-AI DDM) is a software as a medical device (SaMD) intended for the analysis of electroencephalogram (EEG) recordings from the REMI Remote EEG Monitoring System. Its purpose is to assist qualified physicians by automatically identifying and annotating sections of previously acquired 4-channel REMI EEG data that may correspond to potential electrographic seizures lasting at least 10 seconds. The system analyzes recordings from bilateral, bipolar scalp electrodes at frontal and temporoparietal regions and is indicated for use in adult and pediatric patients (6 years and older). Importantly, REMI-AI DDM does not operate in real-time and is not intended to provide diagnostic conclusions, but rather to serve as an aid to a physician's professional judgment during EEG review. The REMI-AI DDM's algorithm was trained and validated using EEG data where a reference standard was established through a consensus review by a panel of three independent expert epileptologists evaluating concurrently acquired standard 19+channel wired EEG. The clinical validation involved a dataset of 50 patient records, including 31 with seizures and 19 without. Performance testing demonstrated that the REMI-AI DDM achieved an event-level sensitivity with a 95% confidence interval lower bound of 79.5% and a False Alarm Rate (FAR) with a 95% confidence interval upper bound of 0.221 False Positives (FP)/hr. Across all patients with seizures, the event-level sensitivity was 86.2%, and the mean per-patient FAR across all 50 patients was 0.162 FP/hr. The device includes an authorized Predetermined Change Control Plan (PCCP) for future algorithm performance improvements.

AI Regulatory Concerns

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Keywords

Electroencephalogram (EEG)Seizure DetectionSoftware as a Medical Device (SaMD)AlgorithmClinical ValidationSensitivityFalse Alarm Rate (FAR)Pediatric NeurologyRemote EEG MonitoringEpileptologist Review

Device Metadata

Submission Number
K231779
Company
Epitel, Inc.
Panel
Neurology
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
detection/diagnosis

Relevant Clinical Questions

  • Q1. How does the performance of the 4-channel REMI-AI DDM compare to seizure detection algorithms using full-montage (e.g., 19+ channel) EEG, particularly for subtle or focal seizures not well represented by the 4-channel configuration?; What specific electrographic features or patterns does the REMI-AI DDM algorithm prioritize for identifying potential seizures, and how does its performance vary across different seizure types (focal, focal evolving to generalized, generalized) and durations?; Considering the False Alarm Rate (FAR) of 0.162 FP/hr, what is the projected impact on clinician workflow efficiency and review burden, especially in continuous long-term EEG monitoring settings?; How does the Predetermined Change Control Plan (PCCP) specifically address the potential for dataset shift or drift as new patient data is incorporated, and what are the re-validation triggers for algorithm modifications?; What are the documented limitations of the REMI-AI DDM in detecting seizures in the presence of common EEG artifacts or for patient populations with characteristics underrepresented in the validation dataset (e.g., specific age subgroups within pediatrics, rare epileptic syndromes)?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Qualifies as a cyber device under §524B (post-Dec 2023, networked)

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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 Score30/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment⚠ Not in summary - likely in full submission per §524B
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

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, drift)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(remote)
✓ 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(configuration)
✓ 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.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Cybersecurity risk assessment not referenced in AI-generated device summary. FDA cybersecurity guidance (2023) expects this for cyber devices.

• 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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REMI AI Discrete Detection Module - Epitel, Inc. | ESL FDA AI Device Intelligence