ZEUS System (Zio Watch)
K213409iRhythm Technologies, Inc. · cleared 2022-07-19 · product code DQK · Cardiovascular
Premarket evidence — what FDA accepted
source quote (p.5)
“The ZEUS System (Zio Watch), the subject device of this 510(k) submission, is a software as a medical device (SaMD) system consisting of a collection of modules designed to process and analyze data from the Zio Watch into a curated report of preliminary findings intended for use by clinicians to aid in AF diagnosis.”
source quote (p.5)
“The subject ZEUS System utilizes an artificial intelligence (AI) based ECG Analysis Software (ECGDL) to generate the initial ECG-based cardiac information provided to the clinician in Transmission Reports. In addition, continuously recorded PPG-based data is processed by a separate artificial intelligence (AI) based analysis software, the AF Context Engine (ACE), that detects the presence of AF. Specifically, the subject ZEUS System (Zio Watch) utilizes machine learning techniques for both the ECGDL and AF Context Engine algorithms.”
source quote (p.7)
“Guidance for Industry and FDA Staff – Content of Premarket Submissions for Management of Cybersecurity in Medical Devices”
Validation studies (2)
Bench
sample size not stated
standards: AAMI ANSI ISO 14971:2012(R)2010 (Corrected 4 October 2017), IEC 62304 Edition 1.1 2015-06 CONSOLIDATED VERSION, AAMI ANSI IEC 60601-2-47:2012, AAMI ANSI EC57:2012, U.S. FDA October 2, 2014 Guidance for Industry and FDA Staff – Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, U.S. FDA May 5, 2005 Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, U.S. FDA September 6, 2017 Design Considerations and Premarket Submission Recommendations for Interoperable, U.S. FDA July 2014 The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]
Bench
sample size not stated
standards: AAMI ANSI ISO 14971:2012(R)2010 (Corrected 4 October 2017), IEC 62304 Edition 1.1 2015-06 CONSOLIDATED VERSION, AAMI ANSI IEC 60601-2-47:2012, AAMI ANSI EC57:2012, U.S. FDA October 2, 2014 Guidance for Industry and FDA Staff – Content of Premarket Submissions for Management of Cybersecurity in Medical Devices, U.S. FDA May 5, 2005 Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, U.S. FDA September 6, 2017 Design Considerations and Premarket Submission Recommendations for Interoperable, U.S. FDA July 2014 The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)]
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
- re_clearance
The FDA AI/ML device list shows a newer 510(k) K222389 (decision 2023-02-15) from iRhythm Technologies, Inc. for a matching device line ("ZEUS System") — a new clearance for the same line is a change event.
first seen 2026-07-08 · k_number:K222389
- recall_reason_pattern
Software/algorithm-related recall in product code DQK (Spacelabs Healthcare, Ltd. Unit B Foxholes Centre; John Tate Road Hertford United Kingdom, initiated 2025-09-16): "Due to two distinct issues: 1. During patient admission, patient demographic fields may default to those of a previously viewed patient. 2. Systems configured with Resting/Rhythm " Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:97686
- recall_reason_pattern
Software/algorithm-related recall in product code DQK (Boston Scientific Corporation, initiated 2024-09-05): "Boston Scientific has received reports indicating the grid mark overlay on the cross-sectional view did not present correctly when an OptiCross 18 Peripheral Imaging Catheter was c" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:95331
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 Cardiovascular panel. A curated reference index, not legal or regulatory advice — each item states its own status, and a draft is never binding.
- 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.