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Canvas Dx

Cognoa, Inc. • Neurology • 04/11/2025

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

Canvas Dx is a software-based medical device designed to aid in the diagnosis of Autism Spectrum Disorder in young children by classifying neurodevelopmental and neurobehavioral data. It leverages a machine learning model, continuously updated via a Predetermined Change Control Plan, to provide diagnostic classifications.

Summary

Canvas Dx, a device manufactured by Cognoa, Inc., has received clearance for marketing as an aid in the diagnosis of Autism Spectrum Disorder (ASD) for children aged 18 to 72 months who are at risk for developmental delay. Functioning as an adjunct to the clinical diagnostic process, this software and data system-based device provides diagnostic outputs classified as 'Positive for autism,' 'Negative for autism,' or 'Indeterminate,' thereby streamlining the initial assessment phase. A critical element enabling its marketing clearance is the inclusion of a Predetermined Change Control Plan (PCCP). This plan allows for prospective, planned updates and modifications to the device's underlying machine learning model and performance thresholds, utilizing real-world data within its cleared indications. Such modifications can encompass optimizing decision thresholds, retraining the model with new datasets, and incorporating additional neurodevelopmental or neurobehavioral features as inputs, all while maintaining rigorous performance evaluation, software verification, and validation, ensuring ongoing regulatory compliance for device quality, labeling, and reporting.

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

Canvas DxAutism Spectrum Disorder (ASD)Diagnostic aidMachine learningPredetermined Change Control Plan (PCCP)Software as a Medical Device (SaMD)Developmental delayReal-world dataRegulatory complianceSubstantial equivalence

Device Metadata

Submission Number
K243558
Company
Cognoa, 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. How does the specific machine learning model within Canvas Dx process various inputs to arrive at its diagnostic outputs of positive, negative, or indeterminate for autism?; What specific neurodevelopmental and neurobehavioral features are utilized as inputs by the Canvas Dx device, and how are these features objectively collected or assessed?; What are the established performance evaluation metrics and thresholds that trigger or validate updates to the machine learning model under the Predetermined Change Control Plan?; Beyond its role as a diagnostic aid, what are the recommended clinical next steps or pathways for patients who receive 'indeterminate' or 'negative' results from Canvas Dx?; How does the integration of real-world data through the PCCP ensure the long-term diagnostic accuracy and address potential biases or evolving characteristics of ASD in the target population?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (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 Score20/100
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, dataset, retraining, bias, labeling)
✓ 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.

• 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, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Canvas Dx - Cognoa, Inc. | ESL FDA AI Device Intelligence