EndoTool SubQ
K142918MONARCH MEDICAL TECHNOLOGIES · cleared 2015-04-24 · product code NDC · Anesthesiology
Premarket evidence — what FDA accepted
source quote (p.3)
“EndoTool SubQ is a software application for use by trained healthcare professionals to calculate and recommend an individual patient's next dose of insulin to be administered subcutaneously to manage blood glucose levels in patients with Diabetes Mellitus in both adult and pediatric patients (age 2 years and above and 12 kg or more).”
source quote (p.5)
“The EndoTool SubQ Glucose Management System uses feedback mathematics to individualize insulin dosing by calculating limited proportional incremental changes in the insulin dosing model (total daily dose and the physician set basal/bolus distribution) or carbohydrate recommendations based on a patient's previous blood glucose readings in response to prior insulin doses. These calculations are repeated by the software when new data is entered into the system, constantly seeking the optimal, patient specific insulin dose for the targets set by the physician. The system is installed on a server and deployed via an internal website on the hospital's infrastructure. Insulin and carbohydrate therapy are managed using blood glucose measurements, available patient information and a set of algorithms that includes a nonlinear dosing equation that is individualized and optimized through time based on blood glucose response to previous doses administered.”
source quote (p.5)
“The EndoTool SubQ Glucose Management System uses feedback mathematics to individualize insulin dosing by calculating limited proportional incremental changes in the insulin dosing model (total daily dose and the physician set basal/bolus distribution) or carbohydrate recommendations based on a patient's previous blood glucose readings in response to prior insulin doses. These calculations are repeated by the software when new data is entered into the system, constantly seeking the optimal, patient specific insulin dose for the targets set by the physician. The system is installed on a server and deployed via an internal website on the hospital's infrastructure. Insulin and carbohydrate therapy are managed using blood glucose measurements, available patient information and a set of algorithms that includes a nonlinear dosing equation that is individualized and optimized through time based on blood glucose response to previous doses administered.”
Validation studies (1)
Bench
sample size not stated
endpoints: Requirements-based testing for all functionality.; Requirements-based testing for all risk-related requirements.; Integration testing to ensure that data flows correctly into and out of the database.; Automated algorithm test case execution.; Off The Shelf (OTS) software embedded in the application was included in the technical verification protocols. Each OTS component was tested to ensure that it functioned as intended.
Reported performance (0 observations)
FDA source did not state a quantitative performance metric — non-reporting is itself the signal.
Each value carries its own analysis unit and task — never compare or pool across devices. Source: 510(k) summary PDF.
Predicate network
Postmarket — what happened after clearance
- recall_reason_pattern
Software/algorithm-related recall in product code NDC (Medtronic MiniMed, Inc., initiated 2025-11-13): "When app is uninstalled and reinstalled, insulin pen software issue causes Choose Notification Style Screen to not show during setup so users can't choose to allow notifications to" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:97904
- recall_reason_pattern
Software/algorithm-related recall in product code NDC (Medtronic MiniMed, Inc., initiated 2025-06-16): "Medtronic MiniMed, Inc. is recalling InPen App for iOS and Android users due to software design errors that could lead to a missed short-acting insulin dose reminder and a recommen" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:97237
Recalls attributed to this device
Recalling firm matches this device's applicant (Monarch Medical Technologies) — same firm and product code, not necessarily this device · initiated 2019-10-01
Product was distributed prior to approval or clearance from FDA.
recall event 83926 (openFDA)
Recalling firm matches this device's applicant (Monarch Medical Technologies) — same firm and product code, not necessarily this device · initiated 2019-05-03
Insulin dosing calculations were erroneously high.
recall event 82828 (openFDA)
Recall and MAUDE counts are product-code-level (reports aren't reliably attributable to one device); a recall is shown as device-attributed only when the recall record itself lists this clearance number. Signals are descriptive observables with sources — never a judgment that the device is unsafe or drifting. Snapshot 2026-07-08.
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 510(k) AI/ML devices in the Anesthesiology panel. A curated reference index, not legal or regulatory advice — each item states its own status, and a draft is never binding.
- Draft guidanceAnesthesiology-specific2025-01Pulse Oximeters for Medical Purposes - Non-Clinical and Clinical Performance Testing, Labeling, and Premarket Submission Recommendations
Software premarket content
Draft (Jan 2025) on skin-pigmentation performance equity; relevant to AI-based SpO2 estimation. Still draft as of July 2026.
- 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 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 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.