IDx-DR
DEN180001IDx, LLC · granted 2018-04-11 · product code PIB · Ophthalmic
Premarket evidence — what FDA accepted
source quote (p.1)
“Retinal diagnostic software device. A retinal diagnostic software device is a prescription software device that incorporates an adaptive algorithm to evaluate ophthalmic images for diagnostic screening to identify retinal diseases or conditions.”
source quote (p.1)
“A retinal diagnostic software device is a prescription software device that incorporates an adaptive algorithm to evaluate ophthalmic images for diagnostic screening to identify retinal diseases or conditions.”
source quote (p.1)
“A retinal diagnostic software device is a prescription software device that incorporates an adaptive algorithm to evaluate ophthalmic images for diagnostic screening to identify retinal diseases or conditions.”
source quote (p.4)
“A protocol was provided to mitigate the risk of algorithm changes leading to changes in the device's technical specifications, which would lead to changes in false positive or false negative results. These changes could significantly affect clinical functionality or performance specifications directly associated with the intended use of the device. The protocol specifies the level of change in device specifications that could significantly affect the safety or effectiveness of the device, triggering the requirement for a 510(k) premarket notification submission before commercial introduction. This protocol implements the recommendations provided in the FDA guidance document “Deciding When to Submit a 510(k) for a Software Change to an Existing Device: Guidance for Industry and FDA Staff.””
source quote (p.4)
“The cybersecurity considerations of data confidentiality, data integrity, data availability, denial of service attacks and malware were adequately addressed using platform controls, application controls and procedure controls and evidence was provided for the controls performance as intended.”
Validation studies (3)
Retrospective clinical
n=900 patients · 10 site(s)
endpoints: sensitivity; specificity; positive predictive value; negative predictive value
standards: ETDRS scale, DRCR grading paradigm
Standalone
n=24 patients
endpoints: repeatability; reproducibility
Bench
sample size not stated
endpoints: user interface assessment; user performance evaluation; usability mitigation
Reported performance (4 observations)
source quote (p.7)
“IDx-DR correctly identified 173 of the 198 fully analyzable participants with fundus mtmDR+, thus observed sensitivity was at 87.4% (95%CI, 81.9% - 92.9%).”
source quote (p.7)
“Among the 621 fully analyzable participants who did not have fundus mtmDR according to FPRC grading, there were 556 participants with an mtmDR not detected output, thus observed specificity was 89.5% (95% CI, 86.9%-93.1%).”
source quote (p.7)
“Positive predictive value was 72.7% (173/238)”
source quote (p.7)
“negative predictive value was 95.7% (556/581).”
Each value carries its own analysis unit and task — never compare or pool across devices. Source: De Novo decision summary PDF.
Predicate network
Postmarket — what happened after clearance
Not yet tracked — the weekly postmarket refresh hasn't snapshotted this device.
Reimbursement — how devices like this got paid
CPT 92229 (bare code — descriptor at CMS source) · MPFS rate $40.28
First Category I CPT code for a fully autonomous AI diagnostic (point-of-care retinal imaging analyzed without physician overread); CMS set national MPFS pricing in the CY2022 final rule via crosswalk. Rate applies in the physician-office (non-facility) setting. Verified national amounts: $47.06 (2022), $45.74 (2023), $40.28 (2024); the 2024 value is used because later years were not fetch-verifiable. Descriptor at the CMS/AMA source.
Eyenuk — CY2022 PFS final rule (national pricing)Ophthalmology Science (PMC) — 92229 MPFS rates 2022-2024
CPT 92229 (bare code — descriptor at CMS source) · OPPS rate $57.12
Hospital-outpatient companion to the office-setting MPFS rate: the CY2022 OPPS final rule assigned 92229 to APC 5733 (Level 3 Minor Procedures) at $57.12. Later-year OPPS updates were not fetch-verified. Reported separately from the MPFS figure — the two settings are never pooled.
3 payer coverage policies reference this clearance or its codes.
Applicable FDA guidance — what the submission is measured against
FDA guidance documents and guiding principles applicable to De Novo AI/ML devices in the Ophthalmic panel. A curated reference index, not legal or regulatory advice — each item states its own status, and a draft is never binding.
- Final guidance2021-10De Novo Classification Process (Evaluation of Automatic Class III Designation)
De Novo pathway
Final (Oct 2021), issued with the De Novo final rule. Most relevant to first-of-a-kind devices without a predicate (DEN-numbered clearances).
- Final guidance2026-01Clinical Decision Support Software
Clinical decision support · SaMD (general)
New final guidance issued Jan 2026, superseding the Sept 2022 version; narrows the device-CDS scope. Applies to software that informs clinical management.
- Final guidance2026-01General Wellness: Policy for Low Risk Devices
SaMD (general) · Clinical decision support
Revised final (Jan 2026); now addresses noninvasive products estimating physiologic parameters (SpO2, BP, glucose). Reshapes the device / non-device line for AI wellness features.
- Final guidance2025-09Computer Software Assurance for Production and Quality Management System Software
SaMD (general) · Postmarket
Final (Sept 2025). Covers software used in production/QMS (incl. ML development-pipeline tooling), superseding Section 6 of the 2002 GPSV — not device software functions themselves.
- Final guidance2025-06Cybersecurity in Medical Devices: Quality Management System Considerations and Content of Premarket Submissions
Cybersecurity · Software premarket content
Reissued June 2025 (retitled 'Quality Management System', was Sept 2023 'Quality System'); adds coverage of FD&C Act §524B cyber devices.
- Final guidance2024-12Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions
Predetermined Change Control Plan · AI/ML lifecycle · Software premarket content
Final (Dec 2024). Supersedes the April 2023 AI/ML PCCP draft.
- Final guidance2023-10Electronic Submission Template for Medical Device 510(k) Submissions
Software premarket content
eSTAR has been mandatory for 510(k)s since Oct 2023 — operationally unavoidable, though not AI-specific.
- Final guidance2023-08Off-The-Shelf Software Use in Medical Devices
Software premarket content · SaMD (general)
Final (Aug 2023). Applies when a device incorporates off-the-shelf software components (common in ML stacks).
- Final guidance2023-06Content of Premarket Submissions for Device Software Functions
Software premarket content · SaMD (general)
Final (June 2023); replaced the May 2005 'Software Contained in Medical Devices' guidance. Documentation level drives the software content of the submission.
- Final guidance2022-09Policy for Device Software Functions and Mobile Medical Applications
SaMD (general) · Clinical decision support
Current version Sept 2022. Frames which software functions FDA regulates as devices.
- Final guidance2016-12Postmarket Management of Cybersecurity in Medical Devices
Cybersecurity · Postmarket
- Final guidance2002-01General Principles of Software Validation
SaMD (general) · Software premarket content
Still active except Section 6 (superseded Sept 2025 by the Computer Software Assurance final guidance).
- Draft guidance2025-01Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations
AI/ML lifecycle · Software premarket content · Transparency
Draft as of July 2026 (published Jan 2025); finalization is on CDRH's FY2026 agenda but not yet published. Treat as FDA's stated direction, not a binding expectation.
- Draft guidance2024-08Predetermined Change Control Plans for Medical Devices
Predetermined Change Control Plan · Postmarket
Draft (Aug 2024) extending PCCPs beyond AI to all devices under FD&C §515C; not final as of July 2026.
- Guiding principles2024-06Transparency for Machine Learning-Enabled Medical Devices: Guiding Principles
Transparency · AI/ML lifecycle
- Guiding principles2023-10Predetermined Change Control Plans for Machine Learning-Enabled Medical Devices: Guiding Principles
Predetermined Change Control Plan · AI/ML lifecycle
FDA/Health Canada/MHRA joint principles (Oct 2023); companion to the GMLP and Transparency principles.
- Guiding principles2021-10Good Machine Learning Practice for Medical Device Development: Guiding Principles
AI/ML lifecycle · SaMD (general)
FDA/Health Canada/MHRA joint principles (Oct 2021). Foundational, not a binding guidance; IMDRF issued a related GMLP document Jan 2025.
Applicability is derived from the device's FDA advisory panel and pathway — cross-cutting guidances apply to every AI/ML device; panel-specific ones are flagged. Titles, dates, and links verified against fda.gov as of July 2026.