Computer-Assisted Detection Devices in Radiology: Performance Testing, Documentation and Labeling Requirements
This guidance applies to computer-assisted detection (CADe) devices applied to radiology images and radiology device data, classified under 21 CFR 892.2050. These devices are computerized systems intended to identify, mark, highlight, or direct attention to portions of radiology images or data that may reveal abnormalities during interpretation by clinicians. The guidance covers CADe devices marketed as complete packages with review workstations or as add-on software for imaging equipment or platforms.
Recommended Actions
- Determine if clinical performance assessment is needed based on ability to directly compare standalone performance with predicate
- Design comprehensive standalone performance testing protocol with independent test dataset
- Establish reference standard definition and scoring process before testing
- Develop detailed algorithm documentation including design, features, and processing steps
- Conduct generalizability testing across different imaging technologies
- Create user training program covering device capabilities and limitations
- Prepare comprehensive labeling including performance data and warnings
- Document all testing methodologies and maintain data integrity controls
- Submit electronic data for statistical analyses when possible
- Establish audit trail if reusing any test data
Key Considerations
Clinical testing
- Clinical performance assessment may be required when standalone performance cannot be directly compared to predicate device
- Clinical study should compare device performance to control modality (typically unaided reading)
- Study should demonstrate statistical significance in performance improvement
- Study population should be representative of intended use population
Non-clinical testing
- Standalone performance testing required for all submissions
- Testing database must be independent from training data
- Performance metrics should include sensitivity and false positive rates with confidence intervals
- Stratified analysis by relevant confounders required
- Generalizability testing across different acquisition technologies needed
Human Factors
- User training procedures must be provided
- Training should cover device advantages and limitations
- Training should help users identify appropriate device settings and reading scenarios
Software
- Documentation level is generally “Basic” for CADe devices
- Software documentation should follow FDA software guidance
- Algorithm design and function must be described in detail
- Processing steps, features, models and classifiers must be documented
Labeling
- Must include indications for use, directions, warnings and precautions
- Should describe device limitations and potential adverse events
- Must include summary of clinical and standalone performance
- Should specify compatible devices and acquisition techniques
Safety
- Warnings about not relying solely on CADe output
- Discussion of potential adverse events from false positives and missed abnormalities required
Other considerations
- Reference standard definition and scoring process must be established before testing
- Electronic submission of study data recommended
- Audit trail required when reusing test data
Relevant Guidances
- Content of Premarket Submissions for Device Software Functions
- Technical Performance Assessment and Premarket Requirements for Digital Diagnostic Radiology Display Devices
- Applying Human Factors Engineering and Usability Engineering to Medical Devices
- Content and Decision-Making Process for 510k Submissions: Determining Substantial Equivalence
Related references and norms
- DICOM Std: Digital Imaging and Communications in Medicine Standard
- JPEG Std: Joint Photographic Experts Group Standard
- SMPTE Test Pattern: Society of Motion Picture and Television Engineers Test Pattern
Original guidance
- Computer-Assisted Detection Devices in Radiology: Performance Testing, Documentation and Labeling Requirements
- HTML / PDF
- Issue date: 2022-09-28
- Last changed date: 2022-09-27
- Status: FINAL
- Official FDA topics: Medical Devices, Radiation-Emitting Products, Radiology, Premarket
- ReguVirta summary file ID: 5b6f4cc7c6f81c81ef864a4c9e419bcf
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