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SleepStageML

Beacon Biosignals, Inc. • Neurology • 03/08/2024

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

Device Purpose

SleepStageML is an AI-powered software device designed to automatically score sleep stages from polysomnography recordings by analyzing EEG signals using deep learning algorithms. Its efficacy is supported by clinical validation demonstrating non-inferior performance to expert consensus and a predicate device, with a predetermined plan for future algorithm enhancements.

Summary

SleepStageML is an artificial intelligence and machine learning (AI/ML) enabled software-only medical device designed to assist qualified clinicians in evaluating sleep quality for patients aged 18 and older. The device analyzes level 1 polysomnography (PSG) recordings, specifically utilizing only the electroencephalography (EEG) signals, to automatically score sleep stages: Wake (W), non-REM 1 (N1), non-REM 2 (N2), non-REM 3 (N3), and REM (R). Clinicians provide PSG recordings in European Data Format (EDF), and SleepStageML processes these using a deep learning algorithm based on convolutional neural networks, returning an EDF+ file containing the original PSG data along with the software-generated sleep stage annotations. These outputs are intended to be comparable to American Association of Sleep Medicine (AASM) guidelines and are always subject to review by a qualified clinician. The clinical performance of SleepStageML was established through a retrospective validation study involving 100 diverse patient PSG recordings. These recordings were independently scored by three registered PSG technologists (RPSGTs), with a 2/3 majority consensus forming the ground truth. SleepStageML's automated scores were compared against this consensus, demonstrating non-inferiority to a predicate device (Sleep Profiler K153412) in terms of positive, negative, and overall agreement for each sleep stage, achieving an overall multi-stage agreement of 84.02%. The device also includes a Predetermined Change Control Plan (PCCP) that outlines specific modifications allowed for the machine learning model, signal preprocessing, probability postprocessing, and signal quality checks, aiming to improve sleep staging performance while ensuring continued safety and effectiveness through rigorous re-validation.

AI Regulatory Concerns

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Keywords

SleepStageMLPolysomnography (PSG)Sleep StagingElectroencephalograph (EEG)Artificial Intelligence (AI)Machine Learning (ML)Deep LearningConvolutional Neural Networks (CNN)Clinical ValidationPredetermined Change Control Plan (PCCP)

Device Metadata

Submission Number
K233438
Company
Beacon Biosignals, Inc.
Panel
Neurology
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does SleepStageML's performance vary across different EEG montages or in the presence of common EEG artifacts not explicitly filtered by the signal quality check?; Given that SleepStageML only uses EEG signals, what is the potential impact on staging accuracy for sleep stages where EOG and EMG are traditionally considered important discriminators (e.g., REM sleep, differentiating N1 from wakefulness)?; The clinical validation used a 2/3 RPSGT consensus. What was the inter-rater reliability among the three RPSGTs, and how does SleepStageML's performance compare to individual expert scorers, not just the consensus?; Regarding the Predetermined Change Control Plan (PCCP), what specific neural network architecture limitations (beyond 'model size and type') are in place for the 'Update of Machine Learning Model' to ensure changes remain within a defined scope?; How does the device handle PSG recordings with significant signal loss or poor quality in some, but not all, required EEG channels, and does the 'signal quality check' provide granular feedback on which channels are problematic?

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 Score10/100
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⚠ Not in summary - likely in full submission per §524B
§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, deep learning, neural network, algorithm, ground truth)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(network)
✓ 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, SaaSBOM 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.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• Not detected in AI-generated device summary: SBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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SleepStageML - Beacon Biosignals, Inc. | ESL FDA AI Device Intelligence