Sepsis ImmunoScore
DEN230036Prenosis, Inc. · granted 2024-04-02 · product code SAK · General Hospital
Premarket evidence — what FDA accepted
source quote (p.1)
“The Sepsis ImmunoScore is an Artificial Intelligence/Machine Learning (AI/ML)-Based Software that identifies patients at risk for having or developing sepsis.”
source quote (p.3)
“The device uses an artificial intelligence/machine learning (AI/ML) based algorithm that is locked to compute the risk score and place the patient in a risk category. The core of the algorithm is a fixed machine learning model (probability random forest model) trained to identify sepsis in patients. A probability random forest calculates the mean predicted class probabilities from multiple simple models. Probability random forest performs bagging, a method of sampling a dataset with replacement. An individual simple model is trained on this sampled dataset. This sampling with replacement followed by training is performed many times to generate an ensemble, or forest, of simple models. The probability random forest used for the development of the ImmunoScore algorithm used 1000 decision trees as the base model to generate the forest.”
source quote (p.3)
“The device uses an artificial intelligence/machine learning (AI/ML) based algorithm that is locked to compute the risk score and place the patient in a risk category.”
source quote (p.43)
“The device manufacturer must develop and implement a post-market performance management plan that ensures regular assessment of the generalizability and device performance in the intended patient population in real-world use.”
source quote (p.41)
“For cybersecurity, the recommended information from FDA guidance document "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices" was provided. This includes a threat model, software bill of materials, data security training, validation and mitigation of adversarial examples, cyber risk management, labeling, cyber testing, and post market cyber vulnerabilities and exploits and other information for safeguarding the algorithms.”
Validation studies (2)
Retrospective clinical
n=746 patients · 3 site(s)
endpoints: monotonic increase in sepsis diagnostic predictive value and risk stratification category; in-hospital mortality; ICU admission; mechanical ventilation usage; vasopressor usage within 24 hours of patient assessment; median length of stay
Bench
n=746 patients
endpoints: Sepsis Risk Score Imprecision; Sepsis Risk Score Reproducibility; Impact of Input Parameter Bias on Device Performance; Diagnostic Accuracy; Primary Endpoint Acceptance Criteria
standards: CLIA 1988
Reported performance (1 observation)
source quote (p.15)
“An estimate of the AUROC for 95% confidence intervals was calculated for both the forced majority and forced unanimous adjudication schemes. There was a pre-specified performance goal of 0.75, which was achieved for both schemes: Adjudicated Forced Majority 0.81 [0.76, 0.86] Adjudicated Forced Unanimous 0.84 (0.78, 0.90]”
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
Not yet tracked — no payment pathway indexed for this clearance (the reimbursement corpus is a growing seed set).
Applicable FDA guidance — what the submission is measured against
FDA guidance documents and guiding principles applicable to De Novo AI/ML devices in the General Hospital 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.