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REMI-AI Rapid Detection Module (REMI-AI RDM)

Epitel, Inc • Neurology • 10/17/2024

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

Device Purpose

The REMI-AI Rapid Detection Module is a Class II physiological signal monitor designed for the automated, near real-time detection of potential electrographic seizures in non-ICU settings by analyzing EEG data. Its development involved rigorous validation, demonstrating substantial equivalence and meeting performance requirements for sensitivity and false alarm rates, establishing it as a safe and effective tool for alerting clinicians to seizure activity.

Summary

The REMI-AI Rapid Detection Module (REMI-AI RDM) is a Class II device designed to automatically detect potential electrographic seizures in near real-time by analyzing EEG data. Integrated with the REMI Remote EEG Monitoring System, it notifies qualified clinicians when a seizure prevalence of 10% or greater is identified within a 5-minute rolling window, indicating at least 30 seconds of activity, alongside a confidence measure. Intended for adult and pediatric patients aged 6 years and older in non-ICU healthcare settings, it functions as a physiological signal monitor, not a diagnostic tool, and is specifically not indicated for detecting electrographic status epilepticus.The device's safety and effectiveness were affirmed through a substantial equivalence determination against other legally marketed devices, supported by comprehensive development processes. This included rigorous software verification, interoperability testing, human factors validation, and clinical validation, which confirmed the device met its performance requirements for sensitivity and false alarm rates across diverse patient populations. Furthermore, it incorporates an authorized Predetermined Change Control Plan to streamline future algorithm improvements and remains subject to general controls and quality system regulations ensuring ongoing quality and compliance.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

REMI-AI Rapid Detection ModuleElectrographic Seizure DetectionEEG MonitoringNear Real-time AnalysisClass II DeviceClinical ValidationSensitivityFalse Alarm RatePredetermined Change Control PlanNon-ICU Settings

Device Metadata

Submission Number
K240408
Company
Epitel, Inc
Panel
Neurology
Product Code
N/A
Data Type
N/A
Clinical Function
N/A
AI Function
N/A
AI Subclass
N/A

Relevant Clinical Questions

  • Q1. What specific EEG features or algorithms does the REMI-AI RDM utilize to detect seizures and determine the 10% prevalence threshold?; How does the "event detection confidence" metric influence clinical decision-making, and what are its performance characteristics (e.g., correlation with true positive rate)?; Given its non-diagnostic classification, how is the device's output integrated into existing clinical workflows to ensure timely and appropriate patient management without misinterpretation?; What was the typical duration of EEG monitoring sessions during clinical validation, and how might performance vary with longer or shorter monitoring periods?; What types of algorithm improvements are anticipated under the Predetermined Change Control Plan, and how will these updates be evaluated for their impact on clinical utility?

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 Score25/100
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(algorithm)
✓ 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
- 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.

• 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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REMI-AI Rapid Detection Module (REMI-AI RDM) - Epitel, Inc | ESL FDA AI Device Intelligence