CDRH Early Feasibility Study Program
The CDRH Early Feasibility Study (EFS) program offers a limited clinical investigation of a medical device early in development. It typically enrolls a small number of subjects, is used to evaluate the device design concept with respect to initial clinical safety and device functionality, and may guide device modifications, according to an online EFS information sheet.
According to the sheet, the EFS program “provides a mechanism for innovators to work directly with sponsors, FDA review teams, and clinicians to work together early so they can increase the efficiency of their device development.” Program components include opportunities for interactive review, assistance in submission preparation from an EFS program representative, potential for less non-clinical data to support study initiation relative to the data needed for larger clinical studies based on use of clinical mitigation strategies, and new mechanisms for timely device and clinical protocol modifications.
The program is open to devices subject to PMA, 510(k), de novo classification, or humanitarian device exemption.