SaMD Devices Approved Where Sponsor Does Not Own Data-Generating Device
By Rhizome Team
Software as a Medical Device (SaMD) represents a unique category of medical devices where the sponsor of the software may not necessarily own or control the hardware devices that generate the clinical data. This is particularly common in radiology AI applications, where algorithms analyze images from third-party imaging equipment manufactured by established medical device companies.
Understanding which SaMD products have gained FDA clearance or approval despite this separation between software sponsor and data-generating device provides valuable insights into regulatory pathways and business models in digital health. Radiology AI applications with product codes like LLZ (radiology computer-assisted diagnostic software) and QIH (radiological computer-assisted detection and diagnosis software) exemplify this emerging regulatory landscape.
This analysis examines FDA-cleared and approved SaMD devices where the sponsor does not own the underlying data-generating device, with particular focus on radiology applications. These examples illustrate how independent software developers can successfully navigate regulatory requirements while integrating with third-party medical devices.
Want to read the citations or ask Rhizome a follow-up question? Schedule a call
what SaMD devices are approved where the sponsor does not own the device the data is generated with? check radiology specifically (LLZ, QIH, etc.)
Answer
Scope and how “sponsor does not own the data‑generating device” was determined
Based on the radiology-focused FDA-cleared/approved SaMD submissions and labeling excerpts provided, a device was counted as meeting your criterion when the text indicates the software ingests/receives DICOM images from external imaging modalities (e.g., CT/MR/CR/DR/US) and/or from PACS/VNA/archives, and/or is described as software-only / hardware independent / off‑the‑shelf, with no indication the sponsor supplies the imaging acquisition hardware. Typical qualifying language includes “images acquired from… DICOM‑compliant medical imaging systems,” “receives… from modalities,” “hardware independent,” “software-only,” and explicit modality lists (CT/MR/etc.) 5958188187135136.
Across the provided dataset, every radiology SaMD entry included in the context was assessed as relying on third‑party acquisition hardware (i.e., the sponsor does not own/provide the scanner or other data-generating modality), with the supporting excerpts quoted below per device.
Radiology SaMD devices identified (sponsor relies on third‑party acquisition hardware)
PACS / image management / viewing (predominantly LLZ)
These are classic radiology SaMDs where the sponsor’s product is a PACS / image management / viewer and the data is generated by external modalities and delivered via DICOM/PACS workflows.
RadUnity (Version 1.0.0) — RadUnity Corp. (2024) — LLZ
- Classified with “Product Code LLZ” and PACS-related regulation naming 154153155.
- Evidence of third‑party acquisition dependency: it “ingests DICOM CT image data” 154 and is limited to “Image input type DICOM CT images” 157. This implies CT images are produced by external CT systems and provided as DICOM.
IntelliSpace Radiology — Philips Healthcare Informatics, Inc. (2018) — LLZ
- Explicitly supports receiving studies “via DICOM” from many modality types (CT, MR, US, CR, DX, etc.) 135136.
- This modality-wide DICOM ingestion indicates the software is downstream of third‑party imaging acquisition systems 135136138.
Centricity Radiology RA600 / Cardiology CA1000 / Digital Hardcopy — GE (2004, 2006) — LLZ
- Intended for “images acquired from CT, MR, CR, DR, US, XA and other DICOM-compliant medical imaging systems” 5958188.
- Receives studies “from a PACS server or directly from a DICOM‑compliant modality or archive” 5958188187.
- Also described as usable with “‘off the shelf’ PC hardware” 57186, reinforcing it is not tied to sponsor-owned acquisition hardware.
AMICAS WEB/INTRANET IMAGE SERVER — Autocyt Group, Inc. (1997) — LLZ (Lower Level of Concern noted)
- “remote viewing of files generated by a medical scanning device” 11.
- “Image acquisition is via the industry-standard DICOM 3.0 protocol allowing the images to be produced from the digital data originated by the scanner” 11.
- This is direct evidence the scanner (data generator) is external to the sponsor’s SaMD 11.
Medsynapse RIS PACS & Medsynapse VNA — Medsynaptic Private Ltd (2019) — LLZ
- “As a software-only device, it does not control image acquisition” 216.
- “can process medical images from DICOM compliant modalities” 218.
- This explicitly separates the SaMD sponsor from the acquisition device ownership/control 216218.
VidiStar PACS & DICOM Viewer — VidiStar, LLC (2009) — LLZ
- Works with images “generated by OEM vendor equipment” 166167.
- Supports “virtually any DICOM and non-DICOM digital imaging modality” 165.
- This is strong vendor-neutral/third‑party acquisition language 165166167.
eVolve PACS — eVolve PACS Inc. (2021) — LLZ
- Displays/handles images from “Digital imaging units (including DR, CR, CT, MR, US, RF, and 2D/3D mammography) … and other imaging devices” 291.
- Processes DICOM modality messages (e.g., MPPS) from modalities 288, indicating external modality sources.
Augmento — Deeptek Medical Imaging Pvt Ltd (2023) — LLZ
- “receives medical images and data from various DICOM-compliant sources (i.e. CT scanners, MR scanners, ultrasound systems… PET Units… imaging gateways…)” 93797.
- This explicitly enumerates third‑party acquisition device types 937.
syngo Imaging — Siemens (V20A 2005; V30 2007; V31 2008) — LLZ
- Described as “hardware independent” and distributed as “software only” or with common IT hardware 75117160159.
- Integrates with “any HL7- / DICOM-compatible RIS” and supports DICOM images/objects 118119159.
- This indicates Siemens provides PACS/workstation software that consumes externally generated DICOM imaging data 117118159.
AMICAS PACS, Version 6.0 — AMICAS, Inc. (2008) — LLZ (also interfaces with CADe outputs)
- “receives images acquired from DICOM-compliant medical imaging systems” 4549.
- Workflow: images imported “from the imaging modality” and also sent to CAD; CAD outputs are generated by “3rd party Medical Devices approved by FDA” 46.
- This is a clear example where both the imaging modality and CAD processor are external to the PACS sponsor 4645.
SUITESTENSA — EBIT srl (2017) — LLZ
- Supports mammography images “received in the DICOM For Presentation format” 242298 and states HL7/DICOM compliance 241.
- The “received” language indicates images originate from external modalities and are then managed/viewed in the SaMD 242241.
DEMASQ Imaging Software Device — DEMASQ Limited (2009) — LLZ
- “receives medical images and data from various imaging sources (including but not limited to CT, MR, US… radiographic devices… scanners, imaging gateways)” 781.
- This is explicit third‑party acquisition reliance 78.
Xmaru View V1 and Xmaru PACS — Rayence Co., Ltd (2016) — LLZ
- “receives… diagnostic image data from imaging modalities” 84 and supports multiple modality types 82.
- Indicates the SaMD is downstream of external modalities 8482.
SntryPACS — QSTAR Technologies, Inc. (2008) — LLZ
- “receives digital images and data from various sources (i.e. CT scanners, MR scanners, ultrasound systems… imaging gateways, etc.)” 150149.
- “compatible with any DICOM modality” 147, strongly implying sponsor does not own the acquisition devices.
Exam-PACS — CoActiv, LLC (2004) — LLZ
- “receives digital images… from various sources (e.g. CT scanners, MR scanners… imaging gateways)” 178176.
- Also describes use of DICOM gateways/film digitizers when DICOM images aren’t directly available 175, reinforcing reliance on external acquisition systems.
Visage PACS — Visage Imaging, Inc. (2008) — LLZ
- “receives image data in DICOM format via the hospital network… universal connections to archives, modalities, and workstations” 116111.
- This is explicit interoperability with external modalities/archives 116111.
LifeSys PACS — Lifetrack Medical Systems, Inc. (2017) — LLZ
- Receives “DICOM images” and displays images from CT/MRI/US/X-ray etc. 182181.
- Uses “off the shelf” hardware components 181, again separating sponsor from acquisition hardware.
McKesson Radiology (2014) and McKesson Radiology Mammography Plus (2015) — McKesson — LLZ
- Intended to process/display images from “DICOM conformant modalities such as X-Ray Radiography… CT… MRI… Ultrasound… Nuclear Medicine” 146143222223.
- Also “intended for installation and use with off-the-shelf hardware” 146141223, consistent with non-ownership of acquisition devices.
MediSystem PACS — Medilab (2023) — LLZ
- “connects to any PACS and displays DICOM images” 124.
- Explicitly “not intended for the acquisition of mammographic image data” 128, reinforcing it is not the data-generating device.
CHILI PACS — CHILI GmbH (2007) — LLZ
- “Receive and store new exams from the Modalities” 253 and supports DICOM images/objects 252.
- This directly indicates external modality acquisition 253252.
DG PACS — DICOM Grid, Inc. (2016) — LLZ
- Describes PACS as providing access to “images from multiple modalities” and notes DICOM as the universal format 88.
- While it doesn’t explicitly say “third-party,” the multi-modality PACS framing implies images originate from external modalities 8889.
EFAI PACS Picture Archiving and Communication System — Ever Fortune.AI (2021) — LLZ
- “displays, processes, stores, and transfers medical data from original equipment manufacturers (OEMs) that support the DICOM standard” 67.
- This is explicit that the data-generating equipment is OEM equipment (not the SaMD sponsor) 67.
CharruaPACS System — CharruaSoft SA (2013) — LLZ
- “receives digital images and data from various sources (e.g. CT scanners, MR scanners, ultrasound systems… imaging gateways, etc.)” 52.
- Strong third‑party acquisition evidence 52.
CLARISO PACS — Clariso, Inc. (2013) — LLZ
- “software Teleradiology system used to receive DICOM images” 205 and used to view DICOM studies 204.
- Also “not intended for the acquisition of mammographic image data” 205, reinforcing downstream role.
MedCommons Open Radiology Gateway — MedCommons, Inc. (2004) — LLZ
- “receives… digital images and data from various types of imaging… system, such CT, MR, US… radiographic devices, scanners, imaging gateways” 25.
- Also applies functions to images “acquired and stored on an image server” 318, indicating the gateway is not the acquisition device.
Merge PACS — Merge Healthcare Incorporated (2019) — LLZ (explicit VNA/RIS/HIS/EMR integration)
- “processes and displays medical images from DICOM-compliant modalities” 284.
- “Data can be received directly from acquisition modalities, CAD systems, and other image processing systems” 282.
- Can integrate with “vendor-neutral imaging archives (VNAs) … and … RIS/HIS … EMR/EHR” 284, which strongly supports the “sponsor does not own the data-generating device” pattern (it plugs into existing enterprise infrastructure) 284282.
DR Systems PACS, Release 6.1 — DR. Systems, Inc. (2004) — LLZ (explicit CADe input mention)
- Handles images from “a variety of diagnostic imaging systems” 233228.
- Displays images from many modalities and includes “processed data from FDA-cleared third party image processing systems, including… computer-aided detection” 230228.
- This is a clear example of a sponsor’s PACS consuming outputs from other vendors’ acquisition and processing devices 230233.
Vitrea View — Vital Images, Inc (2017) — LLZ (explicit archive/repository language)
- Provides access to data “hosted within disparate archives and repositories” for DICOM and non‑DICOM data 195192.
- This indicates the sponsor’s SaMD is a viewer/distribution layer over externally generated and stored imaging data 195192.
ImageGrid Radiology Viewer System — Candelis, Inc. (2009) — LLZ
- Can “query, retrieve, and display medical images that it retrieves from a DICOM SCP” 174170.
- Receives images “from various imaging sources” 171172, indicating external acquisition.
Lightning Viewer — Nexsys Electronics Inc. dba Medweb (2024) — LLZ (mentions CAD overlays; DICOMweb listed among standards)
- “displays images and reports from a PACS” via browser-based “zero-footprint” access 280.
- Can display overlays from “Computer-Aided Diagnosis (CAD) and AI software” 278 (i.e., it can consume outputs from other systems).
- Standards list includes “DICOMweb” among other technologies 280, reinforcing interoperability with external systems.
Non-PACS radiology SaMD (still LLZ product code in these excerpts) where third‑party acquisition is explicit
These are radiology SaMDs that do more than archive/view (e.g., enhancement, perfusion analysis, post-processing, decision support) but still clearly rely on external scanners for data generation.
iRAD Image Enhancement System — Claritas HealthTech (2021) — LLZ
- “takes as input DICOM files of MRI, CT, and X-Ray images” and outputs enhanced DICOM to PACS 16.
- “selection of input DICOM images from PACS servers” and sends back after enhancement 15.
- This is explicit reliance on externally acquired images and existing PACS infrastructure 1516.
AutoMIStar — Apollo Medical Imaging Technology (2019) — LLZ
- Performs analysis of “brain images acquired by DICOM compliant imaging devices” 259.
- Can connect to “modality scanners, workstations, PACS” to receive CT/MRI images 261.
- This directly indicates the sponsor does not provide the CT/MRI scanners generating the data 261259.
iSchemaView RAPID — iSchemaView, Inc. (2013) — LLZ
- “receives DICOM images from external DICOM image providers (modalities (CT/MRI Scanners), PACS and Workstations)” 34.
- Explicitly: “RAPID is entirely independent from CT, MRI, or PACS platforms” 34.
- This is one of the clearest statements matching your criterion (sponsor does not own/control the acquisition platform) 34.
Brainomix 360 e-CTP — Brainomix Limited (2023) — LLZ
- “Data and images are acquired through DICOM compliant imaging devices” 173.
- Runs on off‑the‑shelf/virtual platforms 173, reinforcing it is not the acquisition device.
Brainomix 360 e-MRI — Brainomix Limited (2023) — LLZ
- Same pattern: “Data and images are acquired through DICOM compliant imaging devices” 235236234 and supports DICOM file upload 235236234.
Cercare Medical Neurosuite — Cercare Medical ApS (2021) — LLZ (explicit “decision support software”)
- Described as “software-only” and installable on customer PC / remote desktop 130.
- “Acquires medical image data from DICOM” 133 and is intended for MRI-derived neuroimaging 130.
- This indicates reliance on externally generated MRI data 130133.
syngo.via View&GO VA40A — Siemens (2023) — LLZ
- Explicitly: “software-only medical device… installed on common IT hardware… hardware itself is not… part of the medical device” 16[E3].
- Interfaces “with any Long-term storage (e.g. PACS) via DICOM” and renders data from “connected modalities” 270.
- This is strong evidence the sponsor does not own the acquisition modalities generating the data 27016[E3].
What about QIH (and other FDA device-type terms like CADe/CADx)?
- In the provided excerpts, explicit “QIH” terminology was generally not present for most devices (many are categorized under LLZ and described as PACS/viewers/workstations). Where workstation-like products appear (e.g., Centricity RA600/CA1000), the excerpts still classify them under LLZ and describe DICOM workstation behavior rather than using “QIH” explicitly 186188187575958.
- CADe/CAD/CADx-related terms appear mainly as interoperability inputs, not as the primary function of the SaMD:
- AMICAS PACS 6.0 describes parallel sending to CAD and importing CAD outputs; CAD is from “3rd party Medical Devices” 46.
- DR Systems PACS mentions “computer-aided detection” as third‑party processed data input 230228.
- Lightning Viewer mentions displaying overlays from “Computer-Aided Diagnosis (CAD) and AI software” 278.
- McKesson Radiology Mammography Plus references “Computer Aided Detection Structured Reports (CAD SR)” 225222.
Key implication for your research question
Within this radiology SaMD set, the dominant regulatory/device-type pattern is PACS / medical image management and processing under product code LLZ, and these systems are inherently downstream of imaging acquisition hardware. The labeling repeatedly frames the SaMD as receiving DICOM studies from modalities, PACS, archives, and hospital systems, which strongly supports the conclusion that the sponsor does not own/provide the device that generates the imaging data (CT/MR/X-ray/US scanners, etc.) 595813513615014934261.
Limitations of this answer (based on provided excerpts)
- This summary is constrained to the devices present in the provided context; it is not an exhaustive search of all FDA-cleared radiology SaMD.
- For several entries, the evidence is implicit (e.g., “PACS images from multiple modalities”) rather than an explicit statement like “third-party” or “vendor-neutral,” though many devices do include explicit modality lists and DICOM interoperability language 8889918482.
- Explicit “QIH” labeling was not found in most excerpts; the dataset is heavily weighted toward LLZ PACS/image management devices rather than explicitly labeled QIH categories 186188187575958.