Early feasibility study CRO in Latin America: how MedTech startups accelerate FDA pathways

· BioAccess Editorial Team

How MedTech startups plan early feasibility studies with a Latin American CRO: study-specific timelines, published sample budgets, and FDA-usable data under GCP/ISO 14155.

How MedTech startups reach first patient sooner, on a timeline we confirm for each protocol, through Latin American EFS CRO partnerships.

April 3, 2026

13

min read

By

BioAccess Editorial Team

early feasibility study

EFS

CRO

FDA

medical devices

Latin America

MedTech startups

**Key Takeaways**

  • • Parallel start-up from MSA signing — contracts, protocol and ethics packages move at the same time instead of one after another
  • • Published sample budgets — illustrative, not a quote, on the bioaccess® sample budget page
  • • Colombia and Chile are bioaccess®'s top EFS destinations with proven site networks
  • • FDA accepts LatAm EFS data — multiple bioaccess® datasets referenced in IDE/De Novo submissions
  • • EFS before pivotal is the most capital-efficient strategy for MedTech startups

**Who Is This For?**

This guide is for MedTech startup CEOs, clinical development leads, and investors evaluating early feasibility study strategies — particularly those seeking the fastest, most cost-effective path to initial clinical proof-of-concept data for novel medical devices.

**The short answer**

MedTech startups can often reach first patients sooner by running early feasibility studies with a LatAm CRO, while generating data FDA can review under 21 CFR 812.28 when the study follows GCP/ISO 14155. Budgets are study-specific; see our published sample budgets (illustrative, not a quote). Compare how to evaluate CRO proposals and what trials cost in Latin America before you commit.

What does FDA require for an early feasibility study?

Early feasibility studies (EFS) are the critical first step in clinical development for novel medical devices. Under FDA's EFS guidance, these small-scale studies (typically 5-15 patients) provide initial safety and performance data before committing to larger, more expensive pivotal trials.

For MedTech startups with limited capital, EFS represents the most efficient use of clinical development resources: generate enough clinical data to validate the concept, refine the device, optimize the protocol, and attract pivotal-trial funding — all before spending $2-5M on a US pivotal study.

What does FDA EFS guidance mean for LatAm execution?

FDA's EFS guidance (published 2013, updated 2021) explicitly acknowledges that early feasibility studies may be conducted with:

  • Limited preclinical data (including non-GLP animal studies when justified by risk analysis)
  • Prototype-stage devices (not requiring full GMP manufacturing for investigational use)
  • Small patient cohorts (as few as 5-10 patients for initial performance evaluation)
  • Modified stopping rules (allowing earlier study termination based on safety signals)
  • Iterative device modifications (design changes between patient cohorts based on clinical findings)

This flexibility maps directly to Latin America's regulatory environment, where several countries accept R&D-grade preclinical data and non-GMP investigational devices — making LatAm the natural execution ground for EFS programs that would face significant regulatory barriers in the US.

How fast can you go from MSA to first patient?

What does the 6-month sprint look like?

PhaseWeeksKey Activitiesbioaccess® Role
MSA & Work Order1-4Contract negotiation, budget finalization, team assignmentLead negotiation, cost modeling
Protocol Optimization3-6Protocol adaptation for LatAm sites, endpoint refinementRegulatory strategy, site matching
Ethics Submission5-8CEI/CEC package preparation, informed consent translationSubmission management, EC liaison
Ethics Approval8-14Committee review, query responses, final approvalResponse coordination, timeline tracking
Site Activation12-18Investigator training, EDC setup, device importationFull site activation management
First Patient18-24Patient screening, enrollment, first procedureMonitoring, safety oversight

The critical difference between bioaccess® and traditional CRO timelines is parallelization. While most CROs execute sequentially (MSA → protocol → ethics → site activation → enrollment), bioaccess® overlaps phases to shorten the overall timeline. How much depends on the protocol, the country and the device; we confirm it at the proposal stage.

Which site networks recruit fastest for EFS?

For a medical device early feasibility study, bioaccess® leads with Panama, El Salvador, Chile, Costa Rica, the Dominican Republic, and Colombia. Colombia is included. bioaccess® runs first-in-human studies in Colombia now, devices included:

  • Colombia: bioaccess® runs first-in-human studies in Colombia now, devices included. Drug and biologic trials stay under Resolución 8430 de 1993
  • Chile: ISP-registered sites in Santiago with subspecialty surgical capability and established device importation pathways
  • Both countries offer GCP-trained investigators with US training backgrounds who understand FDA submission requirements
  • bioaccess® pre-qualified sites maintain active IRB/CEI relationships, which helps avoid avoidable ethics-review delays
  • Patient recruitment leverages KOL referral networks — not advertising — for faster, higher-quality enrollment

Should you run an EFS or go straight to pivotal?

ParameterEarly Feasibility StudyPivotal Trial
PurposeProof of concept, design iterationRegulatory approval evidence
Patient count5-15 patients50-300+ patients
Duration6-12 months18-36 months
Device maturityPrototype/R&D-grade acceptableFinal commercial-grade required
Preclinical dataLimited/non-GLP acceptableFull GLP required
FDA submissionSupports IDE applicationSupports 510(k)/PMA/De Novo
Best for startups?Yes — capital-efficient proofAfter EFS validates concept

**Strategic Insight: The EFS-First Approach**

For MedTech startups with $500K-$2M in available clinical budget, the optimal strategy is: EFS in Latin America → Use data for Series A/B fundraising → Pivotal trial with adequate funding. This approach generates clinical proof-of-concept early, while producing FDA-referenced data that strengthens both the regulatory and investor narratives.

What does a LatAm EFS cost?

For budgeting: budget depends on study design; we provide a study-specific quote.

Frequently asked questions

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bioaccess® · A CRO purpose-built exclusively for first-in-human and early feasibility clinical trials across Latin America. 50 companies accelerated since 2010.

EFS Services

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bioaccess®'s EFS-specialized CRO model is built to reach first patient enrollment quickly, on a timeline we confirm for each protocol, with clinical data FDA can review that supports your next regulatory submission and fundraising milestone.

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Related resources:

  • Early Feasibility Studies — /early-feasibility-studies
  • First-in-Human CRO — /first-in-human-cro
  • FIH Medical Device Trial Chile — /blog/first-in-human-medical-device-trial-chile
  • INVIMA Approval Colombia — /blog/invima-clinical-trial-approval-process-colombia
  • Medical Device CRO LatAm — /blog/medical-device-cro-latin-america

Frequently asked questions

What is an early feasibility study (EFS) for medical devices?

An early feasibility study (EFS) is a small-scale clinical study (typically 5-15 patients) designed to provide initial clinical data on a novel medical device before committing to a larger pivotal trial. Under FDA guidance, EFS studies evaluate device performance, refine the clinical protocol, and identify potential safety signals in a controlled setting. EFS studies are critical for MedTech startups because they generate the clinical proof-of-concept data needed for investor discussions, pivotal trial design, and regulatory strategy refinement.

Why is Latin America preferred for early feasibility studies?

Latin America offers three key advantages for EFS: (1) Speed — in several countries the ethics committee is the main gate for early device studies, so start-up can move faster than the sequential US path of Q-Sub, IDE, IRB and hospital contracting; we confirm the timeline for each protocol; (2) Cost — published sample budgets (illustrative, not a quote) on the bioaccess® sample budget page; (3) Regulatory flexibility — several LatAm countries accept R&D-grade preclinical data and non-GMP prototypes for early-stage investigational studies, removing barriers that would delay or prevent EFS execution in the US.

How does bioaccess® shorten the time to first patient enrollment?

bioaccess® shortens MSA-to-first-patient time through parallelized execution: while the master service agreement (MSA) and work order are being finalized (weeks 1-4), protocol optimization and ethics committee packages are simultaneously prepared. Ethics submission follows as soon as the package is ready, and site activation proceeds in parallel with ethics review. This avoids the sequential hand-offs that stretch many US start-ups. We confirm the expected timeline for each protocol.

What is the difference between EFS and pivotal trials?

EFS studies are exploratory (5-15 patients), focused on initial safety and performance data, and designed to refine the device and protocol. Pivotal trials are confirmatory (typically 50-300+ patients), powered for statistical significance, and designed to support regulatory approval. EFS generates proof-of-concept; pivotal generates approval-grade evidence. For startups, EFS in LatAm followed by pivotal in the US is often the most capital-efficient regulatory strategy.

Is EFS clinical data from Latin America accepted by FDA?

Yes. FDA accepts foreign clinical data under 21 CFR 812.28 when studies are conducted under GCP (ISO 14155), data quality meets FDA standards, and patient rights were protected. bioaccess® structures all EFS studies with 21 CFR Part 11-compliant EDC, ISO 14155-compliant monitoring, and FDA-format clinical study reports. Multiple bioaccess® EFS datasets have been successfully referenced in FDA IDE and De Novo submissions.

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