Author: Julio Martinez-Clark

  • Beneficência Portuguesa São Paulo: The NCT Campus String Is Not the ANVISA File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANVISA, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Beneficência Portuguesa São Paulo as a bioaccess® client.

    If you searched Beneficencia Portuguesa first-in-human, BP São Paulo clinical trial, Associação Portuguesa de Beneficência CRO, or “go direct Beneficência Portuguesa São Paulo,” you followed a campus string ClinicalTrials.gov still publishes. Real e Benemerita Associacao Portuguesa de Beneficencia in São Paulo, Brazil, is a real named hospital string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANVISA file.

    bioaccess®’s position is simple and it is not adversarial: the hospital is the site. The First-in-Human CRO still owns ANVISA/CEP, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the hospital still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named São Paulo Beneficência Portuguesa campus. It is not Einstein, not Sírio-Libanês, not HCor, not Pérola Byington, not A.C. Camargo, and not ICESP. Sharing São Paulo is not a license to collapse them. Recife Portuguese-beneficence strings stay off this page.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026.

    • Real e Benemerita Associacao Portuguesa de Beneficencia (São Paulo, Brazil) — canonical NCT string: ALL interventional n=19; DEVICE n=0. Example NCT IDs: NCT01938001, NCT05438043, NCT04988295.
    • Spelling alias Beneficencia Portuguesa de Sao Paulo: ALL n=13. Listed separately. Same campus. We do not invent a combined unique-study total of 19+13. We do not ship a second page.

    These counts are not added together.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this hospital as a client site.

    That is the leak: a founder searching “Beneficência Portuguesa first-in-human” or “BP São Paulo clinical trial” finds canonical ALL n=19 (DEVICE n=0) without finding ANVISA, CEP, import, insurance, or 21 CFR 812.28 — and without landing on Einstein or Sírio. A named hospital is still a site. An NCT location row is not a CRO.

    The site is the site. The CRO is the operator.

    A named hospital can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the hospital can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the hospital is not built to own for an investigational device:

    • ANVISA. Device investigations sit under RDC 837/2023 (dossier in Portuguese: IB, protocol, ICF, insurance, GMP evidence). A hallway conversation at this campus is not that dossier. A hallway conversation at Beneficência Portuguesa is not an Einstein file and is not a Sírio-Libanês file.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANVISA actually works (the short version)

    Use Clinical Trials in Brazil: combined ethics + ANVISA typically 6–10 weeks under Law 14874 and RDC 837/2023; CEPs capped at 30 business days; published per-patient range $20,000–$35,000. Trial authorization and later market registration are separate workstreams.

    Ask for a protocol-specific calendar. A hospital email is not ANVISA clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the hospital

    Beneficência Portuguesa is a serious named São Paulo hospital on the public registry. ALL n=19 is registry volume, not a punchline. We do not invent a DEVICE n. It is separate from Einstein or Sírio. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANVISA / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics review in both Panama and Colombia runs on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Beneficência Portuguesa São Paulo directly for a device FIH?

    You can try. The hospital can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANVISA applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this hospital. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as Einstein, Sírio-Libanês, HCor, or Pérola Byington?

    No. Einstein has its own page. Sírio-Libanês has its own page. HCor has its own page. Pérola Byington has its own page. This page is the São Paulo Beneficência Portuguesa canonical string only.

    Should I add canonical ALL n=19 and alias ALL n=13?

    No. Alias n is listed separately. A combined unique-study total is not published.

    Why DEVICE n=0?

    That is the ranking-table DEVICE count. We will not invent a DEVICE ranking. ALL n=19 is still not ANVISA authorization.

    Did bioaccess® run NCT01938001?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI. We will not claim bioaccess® ran it.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. São Paulo siblings (do not merge): Einstein, Sírio-Libanês, Pérola Byington.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Hospital Ángeles Andares Guadalajara: The Press-Named Campus Is Not the COFEPRIS File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current COFEPRIS, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Hospital Ángeles Andares Guadalajara as a bioaccess® client.

    If you searched Hospital Angeles Andares first-in-human, Angeles Andares Guadalajara clinical trial, Innoblative SIRA Guadalajara, or “go direct Hospital Ángeles Andares Guadalajara,” you followed a campus string ClinicalTrials.gov still publishes. Hospital Ángeles Andares in Guadalajara, Mexico, is a real hospital named in public sponsor press for a device first-in-human procedure (Innoblative SIRA® RFA, public LinkedIn item dated May 2026). It is not a first-in-human medical-device CRO, and it is not the operator of the COFEPRIS file.

    bioaccess®’s position is simple and it is not adversarial: the hospital is the site. The First-in-Human CRO still owns COFEPRIS, institutional ethics, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the hospital still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the press-named Guadalajara Ángeles Andares campus. It is not Hospital Civil de Guadalajara Fray Antonio Alcalde. Sharing Guadalajara is not a license to collapse them. We do not claim Hospital Ángeles Andares as a bioaccess® client. We do not invent a principal investigator beyond what that public press item already names.

    Why the campus name wins the search — and why that is not a CRO

    Device press often writes the city, the hospital, and a milestone headline. It rarely writes the CRO. On the weekday press watch (CIT / MassDevice / MDN / EVT / PR wires plus sponsor LinkedIn), this campus shows up as:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Hospital Ángeles Andares (Guadalajara, Mexico) — press-named building on an Innoblative SIRA® RFA electrosurgical-device first-in-human item (public LinkedIn, May 2026). This is not an NCT frequency rank. Example public naming: Innoblative Designs post describing clinical use at Hospital Angeles Andares, Guadalajara.

    Press naming a hospital is still not COFEPRIS authorization. We will not invent NCT IDs for this page.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this hospital as a client site.

    That is the leak: a founder searching “Angeles Andares first-in-human” or “Innoblative Guadalajara” finds the hospital name in sponsor press without finding COFEPRIS, ethics, import, insurance, ISO 14155 monitoring, or 21 CFR 812.28. A press-named hospital is still a site. A LinkedIn milestone is not a CRO.

    The site is the site. The CRO is the operator.

    A named hospital can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the hospital can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the hospital is not built to own for an investigational device:

    • COFEPRIS. COFEPRIS governs device investigations in Mexico. Ethics committee review comes first, then COFEPRIS review; bioaccess® confirms the calendar per protocol. A hallway conversation on this campus is not that file.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How COFEPRIS actually works (the short version)

    Use Clinical Trials in Mexico and CRO in Mexico. Ethics committee review comes first, then COFEPRIS review; bioaccess® confirms the calendar per protocol. Keep trial clocks separate from registro sanitario (~30 working days on that hub). Eligibility of foreign data under 21 CFR 812.28 is not a guarantee of clearance.

    Ask for a protocol-specific calendar. A hospital email is not COFEPRIS clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the hospital

    Hospital Ángeles Andares is a serious Guadalajara hospital named in public device press. A FIH press item is not a smear license. We do not invent enrollment counts. We do not claim bioaccess® ran the case. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the COFEPRIS / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics timing in Panama and Colombia follows each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Hospital Ángeles Andares Guadalajara directly for a device FIH?

    You can try. The hospital can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your COFEPRIS applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this hospital. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as Hospital Civil de Guadalajara Fray Antonio Alcalde?

    No. That is Hospital Civil de Guadalajara Fray Antonio Alcalde. This page is Hospital Ángeles Andares only.

    Is this an NCT ranking page?

    No. Rank 8 is a press-named building. We will not invent an ALL n or DEVICE n for it.

    Is Hospital Ángeles Andares a bioaccess® client?

    No live bioaccess® case-study page names this hospital as a client site. We will not invent that claim.

    Did bioaccess® run the Innoblative SIRA case?

    No. We cite the public press naming as facility evidence. We will not invent a CRO claim.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. Guadalajara sibling (do not merge): Hospital Civil Fray Antonio Alcalde. Country: clinical trials in Mexico.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Clínica Alemana de Santiago: The NCT Campus String Is Not the ISP File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ISP, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Clínica Alemana de Santiago as a bioaccess® client.

    If you searched Clinica Alemana Santiago first-in-human, Clínica Alemana clinical trial Chile, Clinica Alemana CRO, or “go direct Clínica Alemana de Santiago,” you followed a campus string ClinicalTrials.gov still publishes. Clínica Alemana de Santiago in Santiago, Chile, is a real named hospital string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ISP file.

    bioaccess®’s position is simple and it is not adversarial: the hospital is the site. The First-in-Human CRO still owns ISP, Ethical-Scientific Committee, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the hospital still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named Santiago Clínica Alemana. It is not Hospital Alemán Buenos Aires, not Hospital Clínico Universidad Católica, not Hospital Clínico Universidad de Chile, and not FALP. “Alemana/Alemán” across countries is not a merge key.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Clinica Alemana de Santiago (Santiago, Chile) — canonical NCT string: ALL interventional n=18; DEVICE n=1. Example NCT IDs: NCT01014390, NCT01508091, NCT01706094.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this hospital as a client site.

    That is the leak: a founder searching “Clínica Alemana Santiago first-in-human” finds ALL n=18 (DEVICE n=1) without finding ISP, ethics, import, insurance, or 21 CFR 812.28 — and without landing on Hospital Alemán Buenos Aires. A named Santiago clinic is still a site.

    The site is the site. The CRO is the operator.

    A named hospital can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the hospital can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the hospital is not built to own for an investigational device:

    • ISP. Instituto de Salud Pública (ISP) authorizes studies and investigational-device import in Chile. Live Chile blogs already put a typical ISP review in a band of about 30 business days. Commercial ISP registration (30–90 days) is a different file. An Ethical-Scientific Committee under Law 20.120 still has to sit. A hallway conversation on this campus is not that stack. We will not invent PAHO/WHO Level 4 standing for ISP.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ISP actually works (the short version)

    Use Clinical Trials in Chile. Instituto de Salud Pública (ISP) authorizes studies and investigational-device import. Live Chile blogs already put a typical ISP review in a band of about 30 business days. Commercial ISP registration in a 30–90 day band is a different file — do not put trial authorization and commercial registro on one Gantt labeled “Chile.” An Ethical-Scientific Committee under Law 20.120 still has to sit. We will not invent PAHO/WHO Level 4 standing for ISP on this page.

    Ask for a protocol-specific calendar. A hospital email is not ISP clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the hospital

    Clínica Alemana de Santiago is a serious named Santiago hospital on the public registry. ALL n=18 / DEVICE n=1 is registry volume, not a punchline. It is separate from Hospital Alemán Buenos Aires. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ISP / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. In Panama and Colombia alike, ethics timing depends on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Clínica Alemana de Santiago directly for a device FIH?

    You can try. The hospital can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ISP applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this hospital. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as Hospital Alemán Buenos Aires or Hospital Clínico Universidad Católica?

    No. Hospital Alemán Buenos Aires has its own page. Católica Santiago has its own page. This page is Clínica Alemana de Santiago only.

    Is this the Buenos Aires Alemán hospital?

    No. That is Hospital Alemán Buenos Aires. Chile is not Argentina.

    Did bioaccess® run NCT01014390?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. Siblings (do not merge): Hospital Alemán Buenos Aires, UC Católica Santiago.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Centro de Investigaciones Clínicas Baigorria: The NCT Campus String Is Not the ANMAT File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANMAT, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Centro de Investigaciones Clínicas Baigorria as a bioaccess® client.

    If you searched Investigaciones Clinicas Baigorria first-in-human, CIC Baigorria clinical trial, Granadero Baigorria CRO, or “go direct Centro de Investigaciones Clínicas Baigorria,” you followed a campus string ClinicalTrials.gov still publishes. Centro de Investigaciones Clínicas Baigorria in Granadero Baigorria, Argentina, is a real named research-center string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANMAT file.

    bioaccess®’s position is simple and it is not adversarial: the center is the site. The First-in-Human CRO still owns ANMAT, institutional ethics, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the center still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named Granadero Baigorria center. It is not CIC Litoral Santa Fe and not Hospital Provincial del Centenario Rosario. Sharing a Santa Fe province search is not a license to collapse them.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Centro de Investigaciones Clínicas Baigorria (Granadero Baigorria, Argentina) — canonical NCT string: ALL interventional n=19; DEVICE n=0. Example NCT IDs: NCT05556512, NCT05803421, NCT05882045.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this center as a client site.

    That is the leak: a founder searching “Baigorria first-in-human” finds ALL n=19 without finding ANMAT, ethics, import, insurance, or 21 CFR 812.28. A named center is still a site.

    The site is the site. The CRO is the operator.

    A named center can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the center can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the center is not built to own for an investigational device:

    • ANMAT. Argentina’s national medicines and devices authority (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica) is the file a sponsor actually needs. A hallway conversation on this campus is not that file. A published statutory target on the trial side is 90 business days and the clock pauses for RFIs. Trial authorization and commercial registro are separate petitions.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANMAT actually works (the short version)

    Use live bioaccess® Argentina / ANMAT pages for the full pathway. Trial authorization and commercial registro are different petitions. Do not put both on one Gantt labeled “Argentina.” A published statutory target on the trial side is on the order of 90 business days and pauses for RFIs; ask for a protocol-specific calendar rather than treating an NCT row as start-up.

    Ask for a protocol-specific calendar. A hospital email is not ANMAT clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the center

    Centro de Investigaciones Clínicas Baigorria is a serious named center on the public registry. ALL n=19 is registry volume, not a punchline. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANMAT / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics review in both Panama and Colombia runs on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Centro de Investigaciones Clínicas Baigorria directly for a device FIH?

    You can try. The center can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANMAT applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this center. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as CIC Litoral Santa Fe?

    No. That is Centro de Investigaciones Clínicas del Litoral. This page is Baigorria / Granadero Baigorria only.

    Did bioaccess® run NCT05556512?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. Sibling (do not merge): CIC Litoral Santa Fe.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Instituto de Investigaciones Clínicas Zárate: The NCT Campus String Is Not the ANMAT File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANMAT, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Instituto de Investigaciones Clínicas Zárate as a bioaccess® client.

    If you searched Investigaciones Clinicas Zarate first-in-human, IIC Zarate clinical trial, Instituto Investigaciones Clinicas Zarate CRO, or “go direct Instituto de Investigaciones Clínicas Zárate,” you followed a campus string ClinicalTrials.gov still publishes. Instituto de Investigaciones Clinicas Zarate in Zárate, Argentina, is a real named institute string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANMAT file.

    bioaccess®’s position is simple and it is not adversarial: the institute is the site. The First-in-Human CRO still owns ANMAT, institutional ethics, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the institute still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named Zárate IIC campus. It is not IIC Quilmes, not IIC Mar del Plata, not IIC Rosario, not CIM Tucumán, and not CIC Litoral Santa Fe. Santa Casa city rule: sharing the IIC brand is not a merge key.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Instituto de Investigaciones Clinicas Zarate (Zárate, Argentina) — canonical NCT string: ALL interventional n=19; DEVICE n=0. Example NCT IDs: NCT01975376, NCT01975389, NCT03872401.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this institute as a client site.

    That is the leak: a founder searching “IIC Zárate first-in-human” finds ALL n=19 without finding ANMAT — and without landing on Quilmes, Mar del Plata, or Rosario IIC pages. A named Zárate institute is still a site.

    The site is the site. The CRO is the operator.

    A named institute can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the institute can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the institute is not built to own for an investigational device:

    • ANMAT. Argentina’s national medicines and devices authority (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica) is the file a sponsor actually needs. A hallway conversation on this campus is not that file. A published statutory target on the trial side is 90 business days and the clock pauses for RFIs. Trial authorization and commercial registro are separate petitions.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANMAT actually works (the short version)

    Use live bioaccess® Argentina / ANMAT pages for the full pathway. Trial authorization and commercial registro are different petitions. Do not put both on one Gantt labeled “Argentina.” A published statutory target on the trial side is on the order of 90 business days and pauses for RFIs; ask for a protocol-specific calendar rather than treating an NCT row as start-up.

    Ask for a protocol-specific calendar. A hospital email is not ANMAT clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the institute

    Instituto de Investigaciones Clínicas Zárate is a serious named campus on the public registry. ALL n=19 is registry volume, not a punchline. City campuses are kept separate. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANMAT / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. In Panama and Colombia alike, ethics timing depends on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Instituto de Investigaciones Clínicas Zárate directly for a device FIH?

    You can try. The institute can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANMAT applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this institute. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as IIC Quilmes, IIC Mar del Plata, or IIC Rosario?

    No. Quilmes has its own page. Mar del Plata IIC has its own page. Rosario IIC has its own page. This page is Zárate only.

    Did bioaccess® run NCT01975376?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. IIC siblings (do not merge): Quilmes, Mar del Plata, Rosario.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Framingham Centro Médico La Plata: The NCT Campus String Is Not the ANMAT File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANMAT, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Framingham Centro Médico La Plata as a bioaccess® client.

    If you searched Framingham Centro Medico La Plata first-in-human, Framingham La Plata clinical trial, Framingham CRO Argentina, or “go direct Framingham Centro Médico La Plata,” you followed a campus string ClinicalTrials.gov still publishes. Framingham Centro Medico in La Plata, Argentina, is a real named medical-center string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANMAT file.

    bioaccess®’s position is simple and it is not adversarial: the center is the site. The First-in-Human CRO still owns ANMAT, institutional ethics, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the center still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named La Plata Framingham center. It is not Hospital Italiano La Plata. Sharing La Plata is not a license to collapse them.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Framingham Centro Medico (La Plata, Argentina) — canonical NCT string: ALL interventional n=19; DEVICE n=0. Example NCT IDs: NCT00389675, NCT00389779, NCT01405196.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this center as a client site.

    That is the leak: a founder searching “Framingham La Plata first-in-human” finds ALL n=19 without finding ANMAT, ethics, import, insurance, or 21 CFR 812.28 — and without landing on Hospital Italiano La Plata. A named center is still a site.

    The site is the site. The CRO is the operator.

    A named center can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the center can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the center is not built to own for an investigational device:

    • ANMAT. Argentina’s national medicines and devices authority (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica) is the file a sponsor actually needs. A hallway conversation on this campus is not that file. A published statutory target on the trial side is 90 business days and the clock pauses for RFIs. Trial authorization and commercial registro are separate petitions.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANMAT actually works (the short version)

    Use live bioaccess® Argentina / ANMAT pages for the full pathway. Trial authorization and commercial registro are different petitions. Do not put both on one Gantt labeled “Argentina.” A published statutory target on the trial side is on the order of 90 business days and pauses for RFIs; ask for a protocol-specific calendar rather than treating an NCT row as start-up.

    Ask for a protocol-specific calendar. A hospital email is not ANMAT clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the center

    Framingham Centro Médico is a serious named La Plata center on the public registry. ALL n=19 is registry volume, not a punchline. It is separate from Hospital Italiano La Plata. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANMAT / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics review in both Panama and Colombia runs on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Framingham Centro Médico La Plata directly for a device FIH?

    You can try. The center can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANMAT applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this center. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as Hospital Italiano La Plata?

    No. That is Hospital Italiano de La Plata. This page is Framingham Centro Médico, La Plata only.

    Did bioaccess® run NCT00389675?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. La Plata sibling (do not merge): Hospital Italiano La Plata.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Hospital Pérola Byington São Paulo: The NCT Campus String Is Not the ANVISA File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANVISA, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Hospital Pérola Byington as a bioaccess® client.

    If you searched Perola Byington first-in-human, Hospital Pérola Byington clinical trial, Pérola Byington CRO São Paulo, or “go direct Hospital Pérola Byington,” you followed a campus string ClinicalTrials.gov still publishes. Hospital Perola Byington in São Paulo, Brazil, is a real named women’s-hospital string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANVISA file.

    bioaccess®’s position is simple and it is not adversarial: the hospital is the site. The First-in-Human CRO still owns ANVISA/CEP, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the hospital still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named São Paulo Pérola Byington hospital. It is not A.C. Camargo, not ICESP, not Sírio-Libanês, and not Einstein. Sharing São Paulo oncology search is not a license to collapse them.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Hospital Perola Byington (São Paulo, Brazil) — canonical NCT string: ALL interventional n=19; DEVICE n=0. Example NCT IDs: NCT00545688, NCT00567190, NCT00781612.

    We will not invent a DEVICE ranking.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this hospital as a client site.

    That is the leak: a founder searching “Pérola Byington first-in-human” finds ALL n=19 without finding ANVISA, CEP, import, insurance, or 21 CFR 812.28. A named hospital is still a site. An NCT location row is not a CRO.

    The site is the site. The CRO is the operator.

    A named hospital can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the hospital can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the hospital is not built to own for an investigational device:

    • ANVISA. Device investigations sit under RDC 837/2023 (dossier in Portuguese: IB, protocol, ICF, insurance, GMP evidence). A hallway conversation at this campus is not that dossier.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANVISA actually works (the short version)

    Use Clinical Trials in Brazil: combined ethics + ANVISA typically 6–10 weeks under Law 14874 and RDC 837/2023; CEPs capped at 30 business days; published per-patient range $20,000–$35,000. Trial authorization and later market registration are separate workstreams.

    Ask for a protocol-specific calendar. A hospital email is not ANVISA clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the hospital

    Hospital Pérola Byington is a serious named São Paulo hospital on the public registry. ALL n=19 is registry volume, not a punchline. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANVISA / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics timing in Panama and Colombia follows each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Hospital Pérola Byington directly for a device FIH?

    You can try. The hospital can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANVISA applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this hospital. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as A.C. Camargo, ICESP, or Sírio-Libanês?

    No. A.C. Camargo has its own page. ICESP has its own page. Sírio-Libanês has its own page. This page is Pérola Byington only.

    Did bioaccess® run NCT00545688?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. São Paulo siblings (do not merge): A.C. Camargo, ICESP.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Hospital Geral de Fortaleza: The NCT Campus String Is Not the ANVISA File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANVISA, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Hospital Geral de Fortaleza as a bioaccess® client.

    If you searched Hospital Geral de Fortaleza first-in-human, HGF Fortaleza clinical trial, Hospital Geral de Fortaleza CRO, or “go direct Hospital Geral de Fortaleza,” you followed a campus string ClinicalTrials.gov still publishes. Hospital Geral de Fortaleza in Fortaleza, Brazil, is a real named hospital string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANVISA file.

    bioaccess®’s position is simple and it is not adversarial: the hospital is the site. The First-in-Human CRO still owns ANVISA/CEP, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the hospital still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named Fortaleza general hospital. It is not CRIO Fortaleza (NCT overlap 0 on this canonical string). Sharing Fortaleza is not a license to collapse them.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Hospital Geral de Fortaleza (Fortaleza, Brazil) — canonical NCT string: ALL interventional n=19; DEVICE n=3. Example NCT IDs: NCT01174524, NCT02084446, NCT02098252.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this hospital as a client site.

    That is the leak: a founder searching “Hospital Geral de Fortaleza first-in-human” finds ALL n=19 (DEVICE n=3) without finding ANVISA, CEP, import, insurance, or 21 CFR 812.28 — and without landing on CRIO. A named Fortaleza hospital is still a site. An NCT location row is not a CRO.

    The site is the site. The CRO is the operator.

    A named hospital can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the hospital can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the hospital is not built to own for an investigational device:

    • ANVISA. Device investigations sit under RDC 837/2023 (dossier in Portuguese: IB, protocol, ICF, insurance, GMP evidence). A hallway conversation at this campus is not that dossier. A hallway conversation at Hospital Geral de Fortaleza is not a CRIO file.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANVISA actually works (the short version)

    Use Clinical Trials in Brazil: combined ethics + ANVISA typically 6–10 weeks under Law 14874 and RDC 837/2023; CEPs capped at 30 business days; published per-patient range $20,000–$35,000. Trial authorization and later market registration are separate workstreams.

    Ask for a protocol-specific calendar. A hospital email is not ANVISA clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the hospital

    Hospital Geral de Fortaleza is a serious named Fortaleza hospital on the public registry. ALL n=19 / DEVICE n=3 is registry volume, not a punchline. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANVISA / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. Ethics review in both Panama and Colombia runs on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Hospital Geral de Fortaleza directly for a device FIH?

    You can try. The hospital can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANVISA applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this hospital. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as CRIO Fortaleza?

    No. CRIO has its own page (overlap 0 on this canonical string). This page is Hospital Geral de Fortaleza only.

    Is this CRIO?

    No. That is CRIO Fortaleza. Same city is not the same NCT string.

    Did bioaccess® run NCT01174524?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. Fortaleza sibling (do not merge): CRIO Fortaleza.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Centro Médico Laura Maffei Buenos Aires: The NCT Campus String Is Not the ANMAT File

    Figures cited from a ClinicalTrials.gov LATAM facility sweep (API pull 1 September 2026, 6:32 PM ET) and published bioaccess® country pages. Registry ranking is not a bioaccess® claim that we ran any of these studies. General information, not legal or regulatory advice. Confirm current ANMAT, ethics, and FDA rules with qualified advisers. We name only the facility strings and example NCT IDs those sources support. We do not invent a principal investigator. We do not claim Centro Médico Laura Maffei Buenos Aires as a bioaccess® client.

    If you searched Laura Maffei first-in-human, Centro Medico Dra Laura Maffei clinical trial, Maffei Investigacion Clinica Aplicada CRO, or “go direct Centro Médico Laura Maffei Buenos Aires,” you followed a campus string ClinicalTrials.gov still publishes. Centro Medico Dra. Laura Maffei — Investigacion Clinica Aplicada in Buenos Aires, Argentina, is a real named research-center string on ClinicalTrials.gov. It is not a first-in-human medical-device CRO, and it is not the operator of the ANMAT file.

    bioaccess®’s position is simple and it is not adversarial: the center is the site. The First-in-Human CRO still owns ANMAT, institutional ethics, investigational import, insurance, ISO 14155 monitoring, and the FDA 21 CFR 812.28 package — plus the option to add Colombia or another Latin American country if this campus is not the only fit. Sponsors who skip the CRO and email the center still have to rebuild that stack. An NCT location row is not a CRO.

    This page is the named Buenos Aires Maffei research center. It is not CIPREC, not CINME, not Clínica la Sagrada Familia ENERI, and not Hospital Italiano Buenos Aires. Sharing Buenos Aires is not a license to collapse them. We do not invent a PI from the center’s name.

    Why the campus name wins the search — and why that is not a CRO

    Device registries write the city, the hospital, and a list of NCT IDs. They rarely write the CRO. On the 1 September 2026 ClinicalTrials.gov LATAM sweep (interventional studies; all years), this campus sits here after filters:

    Counts are unique NCT IDs from a ClinicalTrials.gov sweep of Latin American facilities pulled 1 September 2026. Rank 8 is a press-named building (Innoblative SIRA RFA FIH, public LinkedIn May 2026), not an NCT frequency row.

    • Centro Medico Dra. Laura Maffei- Investigacion Clinica Aplicada (Buenos Aires, Argentina) — canonical NCT string: ALL interventional n=29; DEVICE n=0. Example NCT IDs: NCT04255433, NCT04847557, NCT05508789.

    We will not invent a DEVICE ranking.

    Those are unique NCT IDs per facility string + city + country. They are not a count of first-in-human device programs bioaccess® ran. They are how a sponsor searching the hospital name lands on a campus without landing on an operator.

    We cite the IDs as facility evidence. We will not invent a PI. We will not claim bioaccess® ran any of them. No live bioaccess® case-study page names this center as a client site.

    That is the leak: a founder searching “Laura Maffei first-in-human” or “Maffei Investigacion Clinica Aplicada clinical trial” finds ALL n=29 (DEVICE n=0) without finding ANMAT, ethics, import, insurance, or 21 CFR 812.28. A named research center is still a site. An NCT location row is not a CRO.

    The site is the site. The CRO is the operator.

    A named center can provide rooms, coordinators, institutional ethics calendars, and investigators who already appear on NCT rows. That is necessary. It is not sufficient for a first-in-human medical device study a U.S. board expects to survive FDA review.

    What the center can typically do when a sponsor “goes direct”:

    • Discuss investigator interest and whether a protocol can sit in an existing service line.
    • Share institutional ethics-committee calendars and hospital research rules.
    • Quote visit, staffing, and local procedure costs for the cases they will physically run.

    What the center is not built to own for an investigational device:

    • ANMAT. Argentina’s national medicines and devices authority (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica) is the file a sponsor actually needs. A hallway conversation on this campus is not that file. A published statutory target on the trial side is 90 business days and the clock pauses for RFIs. Trial authorization and commercial registro are separate petitions.
    • Investigational import. Ethics letter, investigator’s brochure, and an importation permit — end-to-end work, not a PI email. See importer of record for clinical trial devices in Latin America.
    • Clinical trial insurance. Required. We will not invent a campus-only premium here.
    • ISO 14155 monitoring, EDC, SAE reporting, and the TMF. The site may run visits. The CRO runs the quality system the FDA will later ask about.
    • The 21 CFR 812.28 package. Foreign data is eligible for FDA submission and review after GCP / ethics documentation. Eligibility is not clearance, and a site MSA does not produce it.
    • Multi-country optionality. If enrollment or the indication later needs another Latin American country, a single-hospital MSA will not stretch.

    Going direct to this campus is how you confirm a room. It is not how you open an investigational file.

    How ANMAT actually works (the short version)

    Use live bioaccess® Argentina / ANMAT pages for the full pathway. Trial authorization and commercial registro are different petitions. Do not put both on one Gantt labeled “Argentina.” A published statutory target on the trial side is on the order of 90 business days and pauses for RFIs; ask for a protocol-specific calendar rather than treating an NCT row as start-up.

    Ask for a protocol-specific calendar. A hospital email is not ANMAT clearance. bioaccess® manages the file. That is CRO work, not site work.

    All bioaccess® device protocols in this country are run under ISO 14155 and the Declaration of Helsinki. Data is designed to be eligible for FDA submission and review under 21 CFR 812.28 on a case-by-case basis — not a guarantee of clearance or approval. See OUS FIH and FDA IDE.

    Not a critique of the center

    Centro Médico Laura Maffei is a serious named Buenos Aires research center on the public registry. ALL n=29 is registry volume, not a punchline. We do not invent a DEVICE n. Use the site when the protocol fits. Hire the operator.

    What the CRO still does after you have the campus on a slide

    1. Regulatory-fit, not tourism. This geography is sourced. One campus is not automatically the right room for every indication. bioaccess® still runs trials in Colombia and the rest of the platform.
    2. Protocol, IB, ICF, insurance, and the ANMAT / ethics packet.
    3. Importer of record and device accountability.
    4. Site activation that is more than a tour: contracts, training, investigational product, EDC, monitoring plan. Activate this campus only if it fits the protocol.
    5. ISO 14155 monitoring and the 21 CFR 812.28 narrative so the dataset is built for a later Pre-Sub, IDE, 510(k), De Novo, PMA, or HDE — eligibility, not a promise of FDA action.

    The firm was founded in 2010. That is the operator layer around a campus string.

    Colombia is still on the map

    A site-name search sometimes arrives with a stale story that bioaccess® “left Colombia.” That is false. bioaccess® still runs clinical trials in Colombia. Always bioaccess® — local entity and office, Miami headquarters, INVIMA clocks in-country. In Panama and Colombia alike, ethics timing depends on each committee’s meeting schedule. The country page’s published per-patient comparison: $12K–$22K vs. $15K–$25K as published on Clinical Trials in Panama. We pick the country the device needs. The founder podcast is Global Trial Accelerators™.

    Frequently asked questions

    Can I contract Centro Médico Laura Maffei Buenos Aires directly for a device FIH?

    You can try. The center can discuss investigator interest, local visit costs, and ethics calendars. It cannot, by ranking on ClinicalTrials.gov, become your ANMAT applicant, importer of record, insurer, ISO 14155 monitor, or 21 CFR 812.28 packager. Contract the CRO, then let the CRO activate the site if the site fits.

    Did bioaccess® run the NCT IDs listed here?

    No public bioaccess® case-study page names this center. We will not invent that claim. This page answers the search; it does not claim the studies.

    Is this the same page as CIPREC, CINME, or Clínica la Sagrada Familia ENERI?

    No. CIPREC has its own page. CINME has its own page. Sagrada Familia ENERI has its own page. This page is the Maffei Investigacion Clinica Aplicada string only.

    Why DEVICE n=0?

    That is the ranking-table DEVICE count. We will not invent a DEVICE ranking. ALL n=29 is still not ANMAT authorization.

    Did bioaccess® run NCT04255433?

    No. We cite it as facility evidence. We will not invent a sponsor or a PI. We will not claim bioaccess® ran it.

    Next step

    If the search that brought you here was this campus, start as the operator: contact bioaccess® or book from First-in-Human CRO. Buenos Aires siblings (do not merge): CINME, Sagrada Familia ENERI.

    Julio G. Martinez-Clark, CEO · bioaccess®

  • Clinical Summary Report for FDA Submission: Structure, Content, and Common Mistakes

    Clinical Summary Report for FDA Submission: Structure, Content, and Common Mistakes

    A clinical summary report is one of the most consequential documents in your FDA submission package—and one of the most commonly mishandled. Whether you're preparing a 510(k), a PMA, or an IDE application, the clinical summary distills your entire body of clinical evidence into a structured narrative that reviewers use to assess safety, effectiveness, and regulatory adequacy. Get it right, and it accelerates your review. Get it wrong, and you're looking at deficiency letters that can add months to your timeline.

    This article covers the required structure, what each section actually needs to contain, and the mistakes that most often derail submissions.


    What a Clinical Summary Report Is and Why It Matters

    The clinical summary report is a standalone document that presents your clinical evidence in a format FDA reviewers can evaluate without cross-referencing every underlying study file. It is not a literature review, not a protocol, and not a data dump. It's a curated, interpretive document that connects your clinical data to your regulatory claim.

    For PMA submissions, 21 CFR 814.20 requires a summary of the clinical investigations. For 510(k)s, a clinical summary is required whenever clinical data are included. For IDEs, the clinical investigation plan and associated data must be structured so the agency can assess whether the study is adequate to generate the evidence needed for a future marketing submission.

    The clinical summary also figures into IDE applications and IND submissions when sponsors are running first-in-human or early-feasibility studies. In those cases, the summary must demonstrate that the proposed investigation is scientifically sound and that the sponsor has the infrastructure to execute it safely.


    Structure of a Clinical Summary Report

    FDA doesn't prescribe a single universal template, but guidance documents, reviewer expectations, and common practice have converged on a structure that holds up across device types. The sections below reflect that consensus.

    1. Device Description and Intended Use

    Open with a concise description of the device, its mechanism of action, and its intended use population. This section anchors everything that follows—reviewers need to understand what the device does before they can evaluate whether the clinical evidence is adequate.

    Keep the language clinical, not commercial. State the indication plainly, identify the patient population, and note any contraindications or use limitations already established.

    2. Summary of Clinical Investigations

    This is the core of the document. For each study included in the submission, provide:

    • Study design (prospective, retrospective, randomized, single-arm)
    • Objectives and endpoints (primary, secondary, and exploratory)
    • Patient population, inclusion and exclusion criteria
    • Number of subjects enrolled, completed, and analyzed
    • Follow-up duration
    • Statistical analysis approach
    • Key results for each endpoint, presented numerically
    • Adverse events and device deficiencies, with severity classifications

    If you're relying on multiple studies, present each one separately before synthesizing across them. Don't blend results from different studies into a single table without clearly labeling the source of each data point.

    3. Subject Accountability

    FDA reviewers consistently flag submissions that don't account for every enrolled subject. Your clinical summary must include a disposition table showing how many subjects were screened, enrolled, completed the study, withdrew, were lost to follow-up, or died. Reasons for discontinuation should be categorized and counted.

    If your protocol allowed both per-protocol and intent-to-treat analyses, explain which population was used for each endpoint and why.

    4. Safety Summary

    Adverse events must be presented systematically, not selectively. List all adverse events—device-related and non-device-related—by MedDRA term or equivalent coding, with counts and percentages. Serious adverse events and device deficiencies require individual narratives or a reference to the case report forms where those narratives appear.

    Don't bury safety signals in footnotes or appendices. If there were serious adverse events, present them clearly and explain how they were adjudicated. Reviewers are looking for transparency, not a clean record.

    5. Effectiveness Summary

    Summarize the primary effectiveness endpoint results with point estimates and confidence intervals. If your study used a performance goal or objective performance criterion, show the comparison explicitly. If you used a non-inferiority or superiority design, state the margin and whether it was met.

    Secondary endpoints should appear in a structured table. Pre-specified subgroup analyses can be included but should be clearly labeled as exploratory if they weren't powered for hypothesis testing.

    6. Benefit-Risk Assessment

    This is where many sponsors underinvest. FDA expects you to weigh the clinical benefits against the risks and explain why the benefit-risk profile supports approval or clearance for the intended use population.

    Reference the specific patient population, the severity of the condition being treated, the availability of alternatives, and the nature of the risks observed. A device that carries meaningful procedural risk may still have a favorable benefit-risk profile if it addresses an unmet need in a population with limited options.

    7. Conclusions

    State clearly whether the clinical evidence supports the intended use. Reference the specific endpoints that were met, the safety profile observed, and any conditions or limitations that apply. This section should be one to two paragraphs—not a re-summary of everything that came before.


    Common Mistakes in Clinical Summary Reports

    Understanding the structure is necessary but not sufficient. These are the errors that generate the most deficiency letters and review delays.

    Vague or Missing Endpoint Definitions

    Sponsors sometimes define endpoints in the protocol with precision but then describe them loosely in the clinical summary. If your primary endpoint was a composite of device success, absence of major adverse events at 30 days, and functional improvement on a validated scale, say exactly that. Don't simplify it to "clinical success" without defining the term.

    Reviewers will compare your summary to your protocol. Inconsistencies create questions that require formal responses and extend your review cycle.

    Incomplete Adverse Event Reporting

    One of the most common deficiencies is an adverse event table that doesn't match the study report. This typically happens when the clinical study report is updated after the summary was drafted, or when different team members compile each document. The clinical summary and the underlying study report must be reconciled before submission.

    Also watch for adverse events coded inconsistently across documents. If an event is coded as "device malfunction" in the case report form and "equipment problem" in the summary, reviewers will flag it.

    Overreliance on Narrative Without Data

    Some clinical summaries read more like persuasive essays than data presentations. Phrases like "the device demonstrated excellent safety" without a corresponding adverse event rate aren't acceptable. Every claim in the summary must be traceable to a number in a table or a specific study finding.

    Failure to Address Protocol Deviations

    If your study had major protocol deviations, they need to be disclosed and assessed for their potential impact on data integrity. Sponsors sometimes omit this section entirely, which signals to reviewers that deviations either weren't tracked or aren't being disclosed.

    Misalignment Between Summary and Labeling

    The indications for use in your proposed labeling must match the population studied and the endpoints evaluated. If your study enrolled patients with moderate-to-severe disease but your labeling claims broad use across all severity levels, reviewers will catch the mismatch. The clinical summary is the document that connects your evidence to your label—any gap between them will surface here.

    Inadequate Benefit-Risk Discussion

    Sponsors often treat the benefit-risk section as a formality. A single paragraph stating that "benefits outweigh risks" without supporting analysis doesn't satisfy FDA expectations. The benefit-risk framework should address the condition's severity, the unmet need, the magnitude of the observed benefit, the nature and frequency of observed risks, and the patient population's risk tolerance.

    Poor Document Hygiene

    This sounds minor but creates real problems. Inconsistent subject numbering across tables, unlabeled confidence intervals, tables that reference appendices that aren't included, and unreconciled version-controlled documents all generate reviewer questions. Before you submit, run a cross-check between the clinical summary, the clinical study report, and any referenced appendices.


    How Clinical Trial Design Affects the Summary You Can Write

    The quality of your clinical summary is constrained by the quality of your underlying study. A well-designed trial with pre-specified endpoints, a clear statistical analysis plan, and rigorous data collection gives you a summary that's straightforward to write and easy to defend.

    Studies designed without FDA alignment—using endpoints not validated for the intended population, or enrolling subjects outside the intended use population—produce summaries full of caveats and limitations. Those caveats invite reviewer questions.

    This is why FDA alignment before your study starts matters as much as the execution itself. Pre-Submission meetings (Pre-Subs) let you confirm that your study design, endpoints, and statistical approach will generate data FDA will accept. Sponsors who skip that step often discover the gap at the summary-writing stage, when it's too late to fix.

    For sponsors running first-in-human or early-feasibility studies in Latin America, bioaccess® structures every program around FDA Pre-Sub alignment from day one. The FIH-12™ program covers FDA Pre-Sub and IDE/IND pathway alignment as its first workstream, so the clinical evidence package that comes out of the study is built to support a submission-ready clinical summary from the start.


    Writing the Summary When You Have Multiple Data Sources

    PMA submissions often draw on more than one study—a pivotal trial, a continued access study, a registry, published literature, and post-market data from international markets. Each source needs to be described separately and then synthesized.

    The synthesis section should explain how each data source contributes to the overall evidence base, how the populations and endpoints relate to each other, and how the combined evidence supports the benefit-risk conclusion. Stacking tables from different studies without connecting them isn't a synthesis.

    When you're drawing on data from studies conducted in Latin American markets, you need to address the relevance of that population to the U.S. intended use population. FDA accepts data from foreign studies under 21 CFR 812.28 when the data are collected under ISO 14155 and the study conditions are comparable to U.S. practice. If you're using international data, your clinical summary should include a brief section explaining why the foreign study population is representative of the U.S. population for the intended use.


    Formatting and Length

    FDA doesn't specify a page limit for clinical summaries, but reviewers read a lot of them. A well-organized, concise summary is easier to review than one that buries key findings across 80 pages of narrative. Use tables for data, text for interpretation, and headings that match the content.

    For a single-study 510(k), a clinical summary might run 15 to 30 pages. For a PMA with multiple studies, 40 to 60 pages is common. What matters is that every section is present, every claim is supported, and the document can stand alone as a coherent presentation of your clinical evidence.


    FAQs

    What is a clinical summary report in an FDA submission?
    A clinical summary report is a structured document presenting the clinical evidence supporting a medical device's safety and effectiveness. It is required in PMA submissions under 21 CFR 814.20 and in 510(k) submissions when clinical data are included. It summarizes study designs, results, adverse events, and the benefit-risk assessment in a format FDA reviewers can evaluate independently.

    Is a clinical summary report required for a 510(k)?
    A clinical summary is required in a 510(k) when the submission includes clinical data. If your 510(k) relies on bench testing and predicate comparison alone, a clinical summary may not be required. However, if you include any clinical study data, you must provide a summary that meets FDA's content expectations.

    How long should a clinical summary report be?
    There is no prescribed length. A single-study 510(k) clinical summary typically runs 15 to 30 pages. A PMA with multiple studies may require 40 to 60 pages. The priority is completeness and clarity, not hitting a specific page count.

    What is the most common reason FDA issues deficiencies related to clinical summaries?
    Incomplete or inconsistent adverse event reporting is among the most frequent triggers. Other common causes include vague endpoint definitions, missing subject disposition data, inadequate benefit-risk discussion, and misalignment between the summary and the proposed labeling.

    Can data from Latin American clinical trials be used in a U.S. FDA submission?
    Yes. Data collected under ISO 14155 and structured per FDA 21 CFR 812.28 can be accepted for U.S. IDE and IND submissions. The clinical summary should include a section explaining the relevance of the foreign study population to the U.S. intended use population.

    What is the difference between a clinical summary and a clinical study report?
    A clinical study report is a comprehensive document presenting all data from a single study in full detail, following ICH E3 or equivalent structure. A clinical summary is a shorter, interpretive document that synthesizes findings across one or more studies to support a regulatory claim. The summary references the study report but doesn't replace it.

    How does a Pre-Submission meeting affect the clinical summary?
    A Pre-Sub meeting lets you confirm with FDA that your study design, endpoints, and statistical approach will generate data the agency will accept. When you have that alignment before the study starts, writing the clinical summary is straightforward—the evidence was structured to answer the right questions. Without it, sponsors often discover gaps at the summary stage that require additional data or study amendments.


    Build the Summary Into Your Study Design, Not After It

    A clinical summary report isn't a writing exercise you schedule after your study closes. It's the document your entire clinical program is building toward. The structure of your protocol, the choice of endpoints, the rigor of your data collection, and the quality of your adverse event adjudication all determine what you can honestly say in that summary.

    Sponsors who treat the summary as an afterthought spend months revising it in response to deficiency letters. Sponsors who design their studies with the summary in mind tend to move through review faster and with fewer surprises.

    If you're planning a first-in-human or early-feasibility study and want a clinical evidence package structured for FDA submission from day one, learn more at bioaccess®.