Prescription home intravaginal NMES + EMG-biofeedback device for stress urinary incontinence, coded to E0740 and RTM
9/9
factors scored
4/4
core factors
7/54
claims verified
3
refuted
How to read a tag. Only
verified counts toward a score — it means a typed connector
resolved this against a primary US federal record.
unconfirmed means the Verifier checked and could not confirm,
which very often means the source could not be queried at all rather than that
the claim is doubtful. refuted means a primary source
contradicts it. unverified means nothing has checked it yet.
claim 1verifiedUS
FDA product code KPI covers non-implanted electrical pelvic floor / continence stimulators and is Class II
jurisdiction: US — confidence: verified — source: classification --product-code KPI --jurisdiction US → openFDA device/classification product_code=KPI. Detail: "Device class 2: Stimulator, Electrical, Non-Implantable, For Incontinence (regulation 876.5320, review panel GU)". Checked against the stated…the full checkintended_use: (treatment of stress urinary incontinence in cognitively intact adult women, home setting, by prescription, after a documented failed four-week pelvic muscle exercise trial). Residual, NOT verified: the lookup establishes what KPI is, not that this device — closed-loop EMG-gated, app-linked — falls inside it. Whether the EMG-gating element keeps it in KPI or triggers a second product code is an FDA pre-submission question, not a database lookup
claim 2verifiedUS
The classification regulation for a non-implanted electrical continence device is 21 CFR 876.5320, Class II
jurisdiction: US — confidence: verified — source: classification --product-code KPI --jurisdiction US → openFDA device/classification product_code=KPI, which returns regulation_number 876.5320 and device_class 2 for "Stimulator, Electrical, Non-Implantable, For Incontinence". The same record carries…the full checksubmission_type_id 1 (510(k)). Note for the Scorer: 876.5320 is the intravaginal/non-implanted continence stimulator regulation; the adjacent regulation 876.5330 (product code QAJ, "Cutaneous Electrode Stimulator For Urinary Incontinence") is a different code covering skin-electrode devices — see the K183585/K223884 lines below, which sit under QAJ, not KPI. Re-verification 2026-08-23 — now confirmed against the regulation text itself, a second independent primary source:regulation 876.5320 --title 21 --expect "Class II" --jurisdiction US → verified, eCFR versioner title-21, issue 2026-08-19, section=876.5320: "§ 876.5320 Nonimplanted electrical continence device... a pair of electrodes on a plug or a pessary... inserted into the rectum or into the vagina and used to stimulate the muscles of the pelvic floor to maintain urinary or fecal continence... (b) Classification. Class II (performance standards)." The intravaginal, non-implanted, pelvic-floor-stimulation description matches this candidate's mechanism, and Class II is stated in the CFR, not merely in an openFDA field. (An --expect "incontinence" probe returns unconfirmed on a phrase miss — the section is worded "continence", not "incontinence"; that is a wording artifact, not a finding.) New wrinkle surfaced by the regulation text and run down: 876.5320 expressly "excludes... the powered vaginal muscle stimulator for therapeutic use (§ 884.5940)", which is Class III (premarket approval). regulation 884.5940 --title 21 --jurisdiction US → verified, eCFR issue 2026-08-19: that section is scoped to devices "intended and labeled for therapeutic use in increasing muscular tone and strength in the treatment of sexual dysfunction" and states "This generic type of device does not include devices used to treat urinary incontinence." So the exclusion does not capture this candidate under its stated intended_use: — the PMA-adjacent regulation is carved away by indication. Recorded because it is a live class risk if the indication ever broadens beyond continence
claim 3unconfirmedUS
K133826 is a 510(k) clearance held by InControl Medical for a non-implanted pelvic floor stimulator and is a usable predicate for this device
jurisdiction: US — confidence: unconfirmed — note: tag lowered from verified on 2026-08-23 by a re-verification pass that could, for the first time, read the cleared Indications for Use; see residual (b) — source: openFDA device/510k k_number=K133826 (queried through connectors.fda against the same typed…the full check endpoint the 510k subcommand uses, by k_number rather than device name). Record: device_name "INTONEMV", applicant "Incontrol Medical, LLC", product_code KPI, regulation 876.5320, device_class 2, clearance_type Special, decided 2014-01-06. Correction to frontmatter: K133826 is InToneMV specifically; InTone is a separate clearance, K150180 (Incontrol Medical, KPI, Traditional, decided 2015-03-16) — also verified, 510k "InTone" --applicant "InControl Medical" --jurisdiction US. Residual, NOT verified: (a) "usable predicate" is a regulatory judgment, not a database fact — it depends on indication and technological-characteristics comparison and is settled by FDA, not by openFDA; (b) the cleared Indications for Use has now been read, and it does not say what this candidate says.clearance-summary K133826 --expect-indication "stress urinary incontinence" --jurisdiction US → unconfirmed, source: FDA 510(k) summary K133826 (https://www.accessdata.fda.gov/cdrh_docs/pdf13/K133826.pdf). Verbatim IFU (OCR artifacts as returned): "The lnToneMVV device is a nan-implanted electrical stimulator Indicated for use In the treatment of female urinary incontinence. It applies electrical stimulation to the pelvic floor musculature and surrounding structures. It Is Intended for acute and ongoing treatment of mixed urinary incontinence where the following results may improve urinary control: strengthening of pelvic floor muscles and inhibition of the detrusor muscle through reflexive mechanisms. The biofeedback feature can be used for muscle re-education purposes." The same is true of K150180 — clearance-summary K150180 --expect-indication "stress urinary incontinence" --jurisdiction US → unconfirmed, https://www.accessdata.fda.gov/cdrh_docs/pdf15/K150180.pdf:"...indicated for use in the treatment of female urinary incontinence... intended for acute and ongoing treatment of mixed urinary incontinence... InTone is intended to provide electrical stimulation and/or visual biofeedback (via manometry) for the treatment of female urinary incontinence."Why this is unconfirmed and not refuted: an IFU is free prose, and whether "treatment of female urinary incontinence / mixed urinary incontinence" still supports a stress-UI predicate claim is an FDA substantial-equivalence judgment, not a database fact — the connector says so explicitly and a human makes that call. What changed for the Scorer: the line's existence half remains fully verified (clearance, applicant, product code, regulation, class, dates — all openFDA facts, none contradicted). It is the predicate half, the load-bearing half, that is now affirmatively unsupported rather than merely unread, so the line as written ("is a usable predicate for this device") cannot stand at verified. Two specific mismatches a human should weigh: this candidate's indication is stress UI while both InControl clearances name mixed UI, and K150180's biofeedback is manometry (pressure) while this candidate's is surface EMG — a technological-characteristics difference as well as an indication one
claim 4verifiedUS
K183585 (ELITONE) is a cleared non-implanted muscle stimulator indicated for stress urinary incontinence in women
jurisdiction: US — confidence: verified — note: tag raised from unconfirmed on 2026-08-23; the indication half is now read, not inferred — source: clearance-summary K183585 --expect-indication "stress urinary incontinence" --jurisdiction US → verified, FDA 510(k) summary K183585…the full check (https://www.accessdata.fda.gov/cdrh_docs/pdf18/K183585.pdf). Verbatim Indications for Use: "ELITONE is a non-implanted muscle stimulator designed to treat stress urinary incontinence in women. It applies stimulation to the pelvic floor muscles and surrounding tissues." That is a word-for-word match to the claim as written — non-implanted muscle stimulator, stress urinary incontinence, women. Also verified: openFDA device/510k k_number=K183585. What is verified: the clearance exists — device_name "Elitone Device", applicant "Elidah, Inc.", decided 2019-02-11, Traditional 510(k), device_class 2. The previously load-bearing gap is closed: the openFDA 510(k) record carries no Indications for Use text, and the prior pass recorded the summary PDF as unreachable. That was wrong; the summary reads cleanly and is quoted above. Material correction the Scorer must still carry — and it is now confirmed against the regulation text, not just the openFDA field: this device is product_code QAJ, regulation 876.5330 — not KPI / 876.5320 as the predicate_or_analog: frontmatter groups it. regulation 876.5330 --title 21 --expect "cutaneous" --jurisdiction US → verified, eCFR versioner title-21, issue 2026-08-19: "§ 876.5330 Transcutaneous electrical continence device. (a) Identification. A transcutaneous electrical continence device consists of cutaneous electrodes that are used to apply external stimulation to reduce urinary incontinence. (b) Classification. Class II (special controls)." So the indication matches this candidate (stress UI in women) while the delivery route does not — external skin electrodes versus this candidate's intravaginal probe. That is the shape of the finding a human needs: a verified same-indication analog under a different regulation, not a predicate in this candidate's code. Note also that 876.5330 carries enumerated special controls (electrical-output characterization, biocompatibility, EMC/electrical/thermal/mechanical safety, software V&V, labeling) added at 86 FR 73971 (Dec. 29, 2021), whereas 876.5320 is a bare performance-standards Class II section
claim 5verifiedUS
K223884 (ELITONE URGE) is a cleared device indicated for urge urinary incontinence, i.e. a separate clearance was required to extend beyond SUI
jurisdiction: US — confidence: verified — source: openFDA device/510k k_number=K223884 (also the top hit for 510k "ELITONE" --jurisdiction US and 510k "ELITONE URGE" --jurisdiction US). Record: device_name "ELITONE Urge Urinary Incontinence Device", applicant "Elidah, Inc.", decided 2023-02-24, Traditional 510(k),…the full check product_code QAJ, regulation 876.5330, device_class 2. Verified: Elidah holds two distinct clearances four years apart, and FDA's own device_name on the later one names urge urinary incontinence — the submission-count half of the claim stands. Residual now closed (2026-08-23 re-verification): the inference that the earlier clearance was SUI-limited rested on K183585's Indications for Use, which is now read. clearance-summary K223884 --expect-indication "urge urinary incontinence" --jurisdiction US → verified, FDA 510(k) summary K223884 (https://www.accessdata.fda.gov/cdrh_docs/pdf22/K223884.pdf): "ELITONE Urge is a non-implanted muscle stimulator designed to treat urge urinary incontinence in women. It applies stimulation to the pelvic floor muscles and surrounding tissues." Set against K183585's "designed to treat stress urinary incontinence in women", the two IFUs are identical in wording except for the incontinence type. That is direct primary-source evidence for the claim's actual point: Elidah had to file a second 510(k) to move from stress to urge on the same hardware, so indication scope drives submission count. This is the strongest support in the file for the Generator's narrow-indication strategy, and equally the strongest evidence that broadening later costs another clearance. Still carries the same QAJ / 876.5330 correction — this is not a KPI device, and the delivery route differs (cutaneous electrodes, not intravaginal)
claim 6unconfirmedUS
A device with this intended use is eligible for 510(k) clearance and does not require a De Novo or PMA
jurisdiction: US — confidence: unconfirmed — source: denovo "<device description>" → unconfirmed: "openFDA publishes no De Novo endpoint (device/denovo.json does not exist), and this repo has no cached copy of FDA's De Novo listing... Do NOT substitute a web search." Supporting but not determinative: the KPI…the full check classification record carries submission_type_id 1 (510(k)) and multiple KPI clearances exist (K133826, K150180, K121820). That establishes the product code is a 510(k) code; it does not establish that this device with this intended use is substantially equivalent to a predicate, and the negative half of the claim ("does not require a De Novo") was not searched at all — absence of a De Novo record here is absence of a query, not evidence. Settling it needs FDA's De Novo listing cached under data/, or a human checking fda.gov, plus a pre-submission on the closed-loop EMG element. Re-verification 2026-08-23 — the PMA half of the negative is now partly addressed, the De Novo half is not. The one Class III (PMA) regulation that could plausibly capture an intravaginal electrical stimulator is 884.5940, cross-referenced as an exclusion from 876.5320. regulation 884.5940 --title 21 --jurisdiction US → verified, eCFR issue 2026-08-19: it covers stimulators "intended and labeled for therapeutic use in increasing muscular tone and strength in the treatment of sexual dysfunction", is "Class III (premarket approval)", and states outright "This generic type of device does not include devices used to treat urinary incontinence." Under this candidate's stated intended_use: (treatment of stress urinary incontinence), that PMA route is carved away by indication in the regulation text itself. This does not upgrade the claim: it addresses one named PMA regulation, not "PMA" in general, and it says nothing at all about De Novo, whose listing was never searched because data/ holds no cached FDA De Novo file (still true this pass — data/ contains only README.md). Absence of a De Novo record here remains absence of a query. Re-verification 2026-08-30 — data/fda_denovo.csv is now populated (487 records) and the De Novo half has finally been searched.denovo "intravaginal electrical stimulation EMG biofeedback urinary incontinence" --jurisdiction US → refuted: "No granted De Novo request matching '...' in the cached FDA De Novo listing (487 records). A device with no De Novo grant may still be cleared via 510(k) or approved via PMA — this refutes the De Novo route specifically, not market authorization generally." Re-ran with two narrower device descriptions ("pelvic floor electrical stimulator"; "vaginal probe electrical stimulation incontinence") — both also refuted (no match). A manual grep of the cache for "pelvic", "incontinence" and "vaginal" turns up nothing on-point (a vaginal hydrogel packing system, a vaginal panel assay, a trigger-point wand, a trichomonas assay — none an electrical stimulator). What this establishes and what it does not: the "refuted" status here answers "does a De Novo grant matching this description exist" — no — which is evidence consistent with (not proof of) the claim's assertion that De Novo is not the pathway, since it shows FDA has never had to classify a device like this through that route; it does not, by itself, prove a De Novo could never be required for this device's specific closed-loop EMG-gating element (the live pre-submission question flagged elsewhere in this claim). Tag held at unconfirmed rather than moved to either verified or refuted: the compound claim's 510(k)-eligibility half still rests on other claims, the PMA half was already addressed via 884.5940, and this new search closes the "never searched" gap on the De Novo half without being dispositive proof of "does not require one." The negative claim about this exact device is still not something a description-matching search over granted De Novos can prove outright
claim 7verifiedUS
HCPCS code E0740 exists with a descriptor covering a non-implanted pelvic floor electrical stimulator, complete system
jurisdiction: US — confidence: verified — note: tag raised from unconfirmed on 2026-08-30 now that data/hcpcs_level_ii.csv is populated — source: hcpcs E0740 --expect "pelvic floor" --jurisdiction US → verified, "local cache of CMS HCPCS Level II file, code=E0740" — "HCPCS E0740: Non-implanted pelvic floor…the full check electrical stimulator, complete system". The official descriptor is a direct match to the claim as written, including "complete system"
claim 8unconfirmedUS
Per PDAC coding guidance, E0740 is intended to describe non-implantable pelvic floor electrical stimulators with integrated monitoring capability, so a stim-only device without EMG sensing may not code to E0740
jurisdiction: US — confidence: unconfirmed — source: no connector covers PDAC coding-verification decisions; the nearest check, hcpcs E0740 --jurisdiction US, returned unconfirmed for the missing data/hcpcs_level_ii.csv cache and would only return the descriptor anyway, never PDAC's application guidance.…the full check Unresolvable in this repo as built. Settling it needs the current PDAC Coding Verification decision list (human-attached) and ideally a PDAC coding verification request filed on this device. Flagged because the Scorer treated this as a competitive tailwind — it is currently an unchecked web-search recollection. Re-verification 2026-08-30:data/hcpcs_level_ii.csv is now populated and hcpcs E0740 returns verified with the official descriptor "Non-implanted pelvic floor electrical stimulator, complete system" (see the HCPCS-existence claim above) — but that descriptor says nothing about "integrated monitoring capability," which is PDAC coding-verification-article language, not HCPCS Level II descriptor language. The underlying gap is unchanged: no connector in this repo reaches DME MAC/PDAC coding-verification articles (see the near-identical, separately-sourced PDAC claim later in this file, which got a one-off WebFetch read of a named document as a lead for a human — that same document, if it names E0740, would be the thing that actually settles this one). Stays unconfirmed
claim 9refutedUS
Medicare NCD 230.8 covers pelvic floor electrical stimulation with a non-implantable stimulator for stress and/or urge urinary incontinence in cognitively intact patients who failed a documented four-week trial of pelvic muscle exercise training
jurisdiction: US — confidence: refuted — note: re-verified 2026-08-30 now that data/medicare_coverage_policies.csv is populated (646 rows); tag moved from unconfirmed (missing-cache) to refuted, but read the caveat below before treating this as a clean kill on Factor 2 — source: `coverage E0740…the full check --expect-stance covered --jurisdiction US → **refuted**: "local cache of CMS Medicare Coverage Database (no policy names this code), code=E0740" — "No NCD or LCD in the cached coverage file names E0740. That means Medicare has published no explicit coverage determination for it — claims are left to case-by-case contractor adjudication. This is a real reimbursement risk signal, but it is NOT the same as a denial." **Adversarial follow-up the connector's code-column match cannot see, found by reading the same cache file directly:** grep -n "^230.8," data/medicare_coverage_policies.csv returns a row that exists — 230.8,NCD,Non-Implantable Pelvic Floor Electrical Stimulator, — an exact document-number and title match to this claim's premise, but its codes column is blank. That is not unique to this row: 356 of the file's 646 rows have an empty codes field, so a blank-codes miss here is consistent with a cache-linkage gap (CMS's NCD title/number was captured but the HCPCS cross-reference was not populated for this row) rather than proof that CMS never issued NCD 230.8 or that it doesn't name E0740. I attempted to read the actual NCD 230.8 policy text directly (a targeted fetch of a named, resolvable CMS document, not an open-ended search) via