IRB Approval for a Medical Device Study in Colombia: The CEI Playbook

Sponsors from the U.S. and Europe often ask “how do I get IRB approval in Colombia?” The short answer: Colombia doesn’t use “IRB.” Ethics review is handled by a CEI — Comité de Ética en Investigación. The concept is the same as an IRB or EC; the operating rules, timelines, and documentation expectations are not. This is the CEI playbook bioaccess® uses on every medical device study we run in Colombia.

What a CEI is and the legal framework

CEIs are governed primarily by Resolución 8430/1993 (the foundational health research ethics regulation) and the 2024 CEI accreditation rules, which tightened institutional CEI requirements and created a national accreditation registry maintained by INVIMA and the Ministerio de Salud.

Key implications for sponsors:

  • Only accredited CEIs can approve interventional device studies. Non-accredited hospital committees can only handle observational/minimal-risk work.
  • CEI membership must include a physician, a scientist, a lawyer, a bioethicist, and at least one community representative independent of the institution.
  • Sponsors can select an institutional CEI (tied to a hospital) or an independent CEI (freestanding, INVIMA-registered).

Choosing a CEI

For a multi-site FIH device study, a single independent CEI acting for all sites is faster and cleaner than each site’s institutional CEI reviewing in parallel. For a single-site study, the institutional CEI is usually the right choice.

bioaccess® maintains active working relationships with 7 accredited CEIs across Bogotá, Medellín, Bucaramanga, and Barranquilla. Median first-review turnaround across this network: 32 calendar days.

Documents required (13 items)

  1. Protocol in Spanish (full document + executive summary).
  2. Investigator’s Brochure, current version.
  3. Informed Consent Form in Spanish (plus Indigenous-language variants if applicable to the study population).
  4. Investigator CVs with Colombian medical license numbers (Registro Médico).
  5. Study budget breakdown, including patient reimbursement.
  6. Clinical trial insurance certificate (Colombian carrier, per Resolución 2378).
  7. Sponsor delegation letter authorizing the CRO to submit and manage on behalf of the sponsor.
  8. CEI fee proof of payment.
  9. Device labeling in Spanish (mandatory for CEI review).
  10. Explant / device removal plan (for implantables).
  11. Post-trial access plan (mandatory under Colombian bioethics guidance).
  12. Recruitment materials — patient flyers, screening scripts, ads — all in Spanish.
  13. Data management plan and confidentiality safeguards (Habeas Data Ley 1581/2012 compliance).

Parallel-track strategy with INVIMA

File CEI and INVIMA the same week. INVIMA does not require CEI approval to open evaluation — it requires it before authorizing enrollment. Filing them in parallel compresses total time-to-first-patient-in by 45–60 days versus sequential filing.

Typical CEI review timelines

  • First review: 30–45 calendar days from submission to written response.
  • Re-review (if stipulations are issued): 15–25 days.
  • Amendment review: 20–35 days for substantial amendments.
  • Continuing review: Annual, aligned with the study anniversary.

Common CEI stipulations for device studies

Device-specific stipulations that CEIs commonly issue on first review:

  • Device labeling in Spanish — required even for imported investigational devices.
  • Explant plan — mandatory for implantable devices, must describe device removal at study end or study withdrawal.
  • Post-trial access — for devices that benefit the patient, the sponsor must describe continued access mechanism.
  • Compensation for injury language in ICF must reference the specific Colombian insurance policy and carrier.
  • Community engagement plan — for studies in Indigenous or rural populations.

Ongoing CEI obligations after approval

  • Amendments: Substantial amendments filed before implementation.
  • SAE notification: 15 calendar days for non-fatal serious events, 7 days for fatal or life-threatening.
  • Continuing review: Annual continuing-review report, includes enrollment, safety summary, protocol deviations.
  • Close-out: Final study report + database lock evidence.

bioaccess® CEI relationships

bioaccess® has active submission relationships with 7 accredited CEIs: three in Bogotá, two in Medellín, one in Bucaramanga, and one in Barranquilla. Median first-review turnaround: 32 days. Approval rate at first review: 89% over the last 24 months; the remaining 11% received minor stipulations and were re-approved inside 15 days.

Global Trial Accelerators™ coordinates CEI review alongside INVIMA, insurance binding, legal-rep filing, and site contracting under a single accountable operating team.

For a scoped CEI feasibility call, contact bioaccess®.

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