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CLEWICU System

Clew Medical Ltd. • Cardiovascular • 01/13/2024

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The CLEWICU System is an adjunctive predictive analytics tool employing machine learning to forecast the likelihood of hemodynamic instability in adult critical care patients, using EHR and monitoring data. Its methodology involves validated models, CLEWHI and CLEWLR, which provide physiological insights predicting events up to 8 hours in advance to clinicians for enhanced patient assessment, with provisions for ongoing model adaptation to diverse clinical environments.

Summary

The CLEWICU System is an analytical software product designed to assist clinicians in hospital critical care settings by predicting a patient's likelihood of future hemodynamic instability. It utilizes machine learning models operating on patient data imported from Electronic Health Records (EHR) and patient monitoring devices. The system comprises two main components: the ClewICUServer, a backend platform that processes data and computes the CLEWHI index (likelihood of hemodynamic instability requiring vasopressor/inotrope support) and CLEWLR index (indication of low risk for deterioration), and the ClewICUnitor, a web-based user interface that displays these predictions and associated notifications. The system is intended for adult patients (18 years and over) across various critical care units including ICUs, ED critical care areas, and PACUs, providing adjunctive information to support clinical assessment; predictions are for reference only and should not solely guide therapeutic decisions. The scientific basis of the CLEWICU System lies in its machine learning algorithms, which have been trained and validated to identify patterns indicative of impending hemodynamic changes, predicting events up to 8 hours in advance. Recent validation, using a reduced set of 50 input features, was conducted through a retrospective cohort study involving two large, independent healthcare datasets (UMass eICU and MIMIC-III). The CLEWHI model demonstrated sensitivities of 63-69% and positive predictive values (PPVs) of 10-12%, while the CLEWLR model achieved specificities around 90% and sensitivities of 35.5-47%, meeting all predefined performance targets. These results confirm that the system maintains clinically acceptable predictive performance with a streamlined input dataset. The system also incorporates a Predetermined Change Control Plan, allowing for model retraining with new or modified datasets to adapt to diverse hospital EMR systems and monitoring protocols and potentially improve sensitivity, while adhering to strict validation protocols and maintaining established performance standards for predicting hemodynamic events.

AI Regulatory Concerns

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Keywords

Hemodynamic InstabilityPredictive AnalyticsMachine LearningCritical CareClinical DeteriorationAdjunctive IndicatorSoftware as a Medical DeviceRetrospective Cohort StudyModel ValidationElectronic Health Records

Device Metadata

Submission Number
K233216
Company
Clew Medical Ltd.
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
predictive

Relevant Clinical Questions

  • Q1. How does the reduction in model features from 80 to 50 impact the system's ability to generalize across patient populations with varying data availability and completeness in real-world critical care settings?; What specific physiological parameters or EHR data points constitute the 50 features used by the current CLEWHI and CLEWLR models, and what is the relative importance of these features in predicting hemodynamic instability?; Given the PPV for the CLEWHI model is around 10-12%, what is the anticipated clinical workflow integration and how are clinicians guided to interpret and act upon these predictions to minimize alert fatigue and optimize patient benefit?; The PCCP allows for model retraining with new datasets; what governance and ongoing monitoring processes are in place to ensure that model performance does not degrade over time or with the introduction of data from new, diverse hospital systems?; How does the system define 'hemodynamic instability requiring vasopressor/inotrope support,' and what is the typical validated lead time of prediction provided by the CLEWHI index for an impending event?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Post-§524B but no clear network capability detected

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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, model performance, model validation)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(server, platform, backend)
✓ 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.

• 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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CLEWICU System - Clew Medical Ltd. | ESL FDA AI Device Intelligence