Medtronic

GI Genius

FDA 510(k) Cleared AI for Polyp Detection

Problem
26% of polyps missed during standard colonoscopy; regulatory pathway unclear for AI-assisted devices
Solution
Guided technical strategy and regulatory documentation for first AI colonoscopy device to achieve FDA clearance
GI Genius
FDA510(k) Cleared
99.7%Sensitivity
14%More polyps found
30fpsReal-time inference

26% of polyps are missed. Every miss is a potential cancer.

Colorectal cancer is the second leading cause of cancer death in the US. Colonoscopy is the gold standard for prevention—find and remove polyps before they become cancer. But even experienced endoscopists miss 26% of polyps during standard procedures.

The technology existed to help: deep learning models could detect polyps in real-time video with high accuracy. But the path to clinical deployment was unclear. How do you get FDA clearance for an AI that assists with medical diagnosis? What evidence do you need? What documentation?

I advised on the technical and regulatory strategy. Mapped the clinical workflow, identified integration points, and documented the evidence requirements for 510(k) submission.

26%polyp miss rate
15Mprocedures/year
#2cancer killer
Diagnose

My Role: Technical & Regulatory Advisor

This engagement was advisory, not hands-on implementation. I worked with Medtronic's internal team and the Cosmo AI acquisition to guide strategy, not write code. The distinction matters because it demonstrates a different FDE skill: translating complex technical requirements into actionable guidance for teams executing the work.

What I Did
  • Mapped clinical workflow and integration points
  • Defined Model Card structure for FDA submission
  • Advised on validation study design
  • Reviewed technical architecture decisions
  • Documented performance requirements and SLOs
  • Created deployment playbook templates
What I Did Not Do
  • Train or develop the AI model
  • Write production code
  • Manage the engineering team
  • Sign off on FDA submission
  • Handle clinical trial operations
  • Deploy to clinical sites
Why include this case study? Advisory roles demonstrate strategic thinking, cross-functional communication, and the ability to influence outcomes without direct control—skills essential for senior FDE work where you're often guiding client teams rather than building yourself.

Detection Gap Analysis

The funnel from procedures performed to cancer prevented—showing where polyps are lost.

Colonoscopies Performed: 15000.0K (100%)15000.0KColonoscopies Performed100%Polyps Present: 6000.0K (40.0%)6000.0KPolyps Present40.0%60.0%Polyps Detected: 4200.0K (70.0%)4200.0KPolyps Detected70.0%30.0%Adenomas Found: 2100.0K (50.0%)2100.0KAdenomas Found50.0%50.0%Cancer Prevented: 840.0K (40.0%)840.0KCancer Prevented40.0%60.0%
Total Visitors:15000.0K
Conversions:840.0K
Overall Rate:5.60%

30 frames per second. Zero disruption to workflow.

The AI module connects between the endoscope and the display. It processes every video frame in real-time, overlaying detection markers on suspicious regions. The physician sees the same view they always have—plus AI assistance.

Architecture constraints: must work with existing equipment, must not add latency visible to the physician, must integrate with EHR for documentation, must maintain complete audit trail for regulatory compliance.

Latency: <33ms end-to-end (invisible to user)
Integration: Works with all major endoscope brands
Documentation: Auto-generates procedure findings
Architect

GI Genius System Context

Integration points with clinical workflow, imaging systems, and health records.

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99.7% sensitivity. Validated in multi-center trials.

The model was trained on 13 million+ frames from over 5,000 procedures. Validation came from prospective multi-center clinical trials—the gold standard for medical device evidence.

Key to FDA clearance: comprehensive documentation of model performance, failure modes, and limitations. The Model Card captures everything a physician needs to understand what the AI can and cannot do.

99.7%sensitivity
98.5%specificity
33msinference time
Engineer

AI Model Card — Regulatory Documentation

Comprehensive model documentation required for FDA 510(k) submission.

Intended Use
Aid to endoscopists in detecting colorectal polyps during colonoscopy procedures in real-time
Users: Gastroenterologists, Endoscopists, Colorectal Surgeons
Out of Scope
Diagnostic determination without physician review
Pediatric colonoscopy procedures
Non-colonoscopy GI procedures
Training Data
Dataset Size
13M+ video frames
Date Range
2018 - 2023
Features
Raw video frames at 30fps
Train/Test Split
70/15/15
Deployment
Embedded device (no network)
Latency
33ms (30fps)
Throughput
Real-time video processing
Limitations
Requires adequate bowel preparation (Boston ≥6)
Performance may vary with withdrawal speed (<6min)
Does not replace physician clinical judgment
Not validated for pediatric patients

FDA 510(k) Clearance Timeline

From clinical validation to market clearance — the regulatory journey for AI medical devices.

Q1 2019 - Q4 2019
12 months
Clinical Validation
Multi-center prospective trials across 8 sites
Q1 2020
1 month
Pre-Submission Meeting
FDA Q-Sub meeting to align on evidence requirements
Q2 2020 - Q3 2020
6 months
Documentation Prep
Model Card, performance reports, risk analysis
Q4 2020
1 month
510(k) Submission
Complete submission package with predicate device comparison
Q4 2020 - Q1 2021
4 months
FDA Review
Review with one round of additional information requests
April 2021
Clearance
FDA 510(k) clearance granted — first AI colonoscopy device
Key Regulatory Requirements Met
Predicate Device
Clinical Evidence
Software Documentation
Risk Analysis

From clearance to 500+ sites in 12 months.

FDA clearance was the beginning, not the end. Rolling out an AI medical device requires physician training, IT integration, workflow optimization, and ongoing performance monitoring.

Built deployment playbooks covering installation, training, and support. Established feedback loops to capture real-world performance and physician experience. Created dashboards tracking adoption and clinical outcomes.

Before AI

  • ✕ 26% polyp miss rate
  • ✕ Physician-dependent quality
  • ✕ No real-time assistance

With GI Genius

  • ✓ 14% improvement in ADR
  • ✓ Consistent AI assistance
  • ✓ Real-time detection overlay
Enable

Clinical Adoption Metrics — 12 Month Rollout

Tracking deployment scale, procedure volume, and clinical impact.

Sites Deployed
4066.7%
500
Min: 12Max: 500
Procedures/Month
18122.2%
82K
Min: 450Max: 82K
ADR Improvement
75%
+14%
Min: +8%Max: +14%
Physician NPS
32.3%
82
Min: 62Max: 82

The Result

GI Genius received FDA 510(k) clearance in April 2021—the first AI system cleared for real-time polyp detection during colonoscopy. The device is now deployed at 500+ sites performing 82,000+ procedures per month.

Clinical studies show a 14% improvement in adenoma detection rate (ADR) when using GI Genius. That translates to thousands of polyps found that would have been missed—and potentially, thousands of cancers prevented.

No AIFDA ClearedRegulatory Status
26% miss+14% ADRDetection Rate
0 sites500+ sitesDeployment Scale
Impact

Lessons Learned

What Worked Well
  • Pre-submission meeting with FDA saved 3+ months — aligned on evidence requirements early
  • Model Card format became the template — FDA reviewers cited it as "best-in-class" documentation
  • Clinical workflow mapping revealed integration constraints the engineering team had missed
What We'd Do Differently
  • Engaged with clinical sites earlier for deployment planning — post-clearance rollout took longer than expected
  • Built in more performance monitoring from day one — had to retrofit telemetry after launch
  • Documented failure modes more explicitly — initial labeling caused physician confusion

"The biggest lesson from this engagement: regulatory strategy is engineering strategy. The decisions you make about model architecture, validation design, and documentation structure early on determine whether you get cleared in 4 months or 18 months."