Before a clinical trial starts, someone has to decide where it will find its patients: which countries, which hospitals and clinics, and how long it will take. That decision is clinical trial feasibility. Get it wrong and a trial pays to open sites that never enroll anyone, and it finishes late.
This guide is for anyone who plans, approves or pays for that decision: feasibility leads, study leads, country managers, medical leads, heads of clinical operations, contract research organizations (CROs, the firms hired to run parts of a trial), and sites who want to know how they get chosen. No background needed.
Imagine you are the feasibility lead at a mid-sized biotech, planning VLT-401, a Phase 3 study (the large test before approval) of a new antibody for Crohn's disease, a long-term bowel illness. It needs 480 participants. It is October 7, 2026. You sent questionnaires to 186 sites. One came back from a university hospital in Duisburg, Germany, and your German country manager wants it as a primary site, one that opens at the start, because its professor leads the national society for the disease.
Question 7 asks how many patients a year would meet the entry criteria. The site writes: "About 80 a year." You open your own records from an earlier study at that hospital, which show how many patients it screened, that is, checked against the entry criteria.
The questionnaire · question 7
Eligible a year
About 80
Competing trials
2 named
Who signed
The professor
Your records · VLT-208
Screened in a year
14
Enrolled against plan
3 of 10
Competing, by registry
4 within 25 km
80 claimed, 14 screened5.7 times the recordcounted at 28, twice the record, until the site confirms its number.
The professor may be excellent, and the hospital may have changed. The record still has to be answered. So you keep the site as a back-up that opens if a German primary site falls behind after month 6, and you write down why, where your country manager can read it and an inspector can find it.
The check caught a claim more than five times the site's record before the trial paid to open that site as a primary, and the reason stays on file.
Choosing where a trial recruits: countries, sites, approval clocks and the rules as of November 2026
What study feasibility is, which rules govern it, what evidence it rests on, how the arithmetic works, what goes wrong, and how teams do it today, explained without selling anything. If you are new to clinical operations, start here.
01 · In plain words
Clinical trial feasibility explained: deciding where a study will find its patients
A drug company has a new medicine and a plan to test it. The plan, called a protocol, says who may join: their diagnosis, how sick they are, which treatments they have already tried. It also says how many people the study needs and by when. What the protocol does not say is where those people are.
Finding that out is feasibility. The company that runs the study, called the sponsor, asks a set of questions. Which countries have enough of these patients? How long will each country's regulators and ethics committees take to approve the study? Which hospitals and clinics have treated these patients and run trials well? Who else is recruiting the same patients down the road? The doctor who runs a trial at a hospital is the investigator, and the hospital or clinic is the site.
Much of the answer comes from a questionnaire sent to the sites, which can run from 10 to 40 pages.1 Sites often fill it in without pay, and they want the study. The sponsor's team then checks the answers against its own trial records, public trial registries and licensed counts of patients. They argue about it in meetings, build a spreadsheet, and produce a list: these countries, these sites, this many participants at each, with the last patient expected on this date.
The list matters because opening a site costs money and months, and the trial cannot easily take the decision back. In one study by the Tufts Center for the Study of Drug Development (Tufts CSDD), 48% of the sites that were ready to recruit fell short of their target, and that count includes the 11% that never enrolled a single patient.2 Under ICH E6(R3), the current international guideline on good clinical practice, the sponsor is responsible for the choice, even when a contract research organization (CRO) did the work.3
One Crohn's study, from protocol synopsis to a signed site list
The protocol sets who may joinVLT-401 needs 480 adults with moderate-to-severe Crohn's disease who have failed an advanced therapy. The target for the last patient is June 2028.
Countries and sites are askedQuestionnaires go to 186 sites in 14 countries on September 12. They close on October 2 with 131 back.
Claims are checked and everything is ranked90 questionnaires are usable. Each is compared with site history, registries and patient counts, and ranked. Most of this guide lives at this step.
Allocation is argued and approvedAllocation means how many participants each country gets. Should Brazil, strong but slow to approve, move from back-up to core? The study lead wants to see what it does to the date.
The list is signed and filedA named person signs. The reasons go to the trial master file, the study's official record, and site start-up begins.
The people, sites and figures in this example are fictional.
Why a site that never enrolls is common, and three more feasibility surprises
About one ready site in nine enrolled nobody
That Tufts study covered 151 Phase II and III trials, the mid-stage and late-stage tests in people, and nearly 16,000 sites, from 2008 to 2010. It found 11% of ready sites enrolled no one: 20% in Latin America and 7% in Western Europe.2 It is an old figure, and the most recent regional split we could read.
A questionnaire answer alone may not meet the guideline's test
ICH E6(R3) asks an investigator to demonstrate a potential for recruiting, "e.g., based on retrospective or currently available data".3 A hopeful estimate in a box supplies neither until someone checks it.
The famous "80% of trials miss enrollment" has no study behind it that we could find
A professional body repeats it, footnoting a trade article.1 Treat it as what the field believes about itself. A peer-reviewed figure measures something narrower: 19.3% of 1,197 National Cancer Institute-affiliated trials failed on low accrual, meaning too few people joined.4
In some diseases the average site enrolls one patient in ten months
Average recruitment in moderate-to-severe Crohn's trials fell from 0.65 to 0.1 patients per site per month between 1998 and 2018.5 A plan built on hopeful rates can be wrong by years.
Questionnaire, zero-enrolling site, last patient in and P50
Feasibility questionnaire
The form a sponsor or CRO sends to a site, asking about its patients, staff, equipment, timelines and competing studies.
Zero-enrolling site
A site that the study pays to open and that never enrolls a participant.
Last patient in
The date the final participant joins the study. The date an enrollment forecast usually leads with.
P10, P50, P90
Dates from a forecast range. By P50 half of simulated futures have finished enrolling, by P90 nine in ten have. P10 is the optimistic end.
Country feasibility, site feasibility and the enrollment forecast answer three separate questions
In shortStudy feasibility is three decisions that lean on each other. Country feasibility asks where the patients are and how fast the study can get approved. Site feasibility asks which investigators can recruit and run the study well. The forecast asks when it will end. Change one and the other two move.
Country feasibility
Where, and how many in each place
Eligible patients, standard of care, competing studies, approval path and start-up time. The output is a tier for each country, such as lead, core or back-up, and a number of participants.
Site feasibility
Which investigators
Past enrollment, screening history, equipment, staff, contract and ethics timelines, nearby competition, and the people the site serves. The output is primary, back-up or not selected, with a reason.
Enrollment forecast
When the last patient joins
Each site's opening date and rate, added up and simulated. The output is a range. A single date hides how much of the plan rests on things nobody has seen yet.
One pass through all this, from questionnaires to a list, is called a feasibility round, and it shrinks a long list quickly. In the guide's example, a little under half of the sites asked end up scored at all. Nothing is published on how typical that is, because the numbers belong to sponsors, so measure your own.
Of 186 sites asked, 64 become the plan's primary sites
VLT-401, from questionnaires sent to primary sites
Questionnaires sent186 sites
Returned131 sites
Usable and scored90 sites
On the list, primary or back-up76 sites
Primary64 sites
Fictional example from this guide
Show the numbers
Stage
Sites
Questionnaires sent
186 sites
Returned
131 sites
Usable and scored
90 sites
On the list, primary or back-up
76 sites
Primary
64 sites
No single source answers every site selection question
Good feasibility puts sources side by side because each is strong on some questions and blind on others. Site history shows what happened, though only on your own studies. Questionnaires hold the only view of what changed last month. Registries show competition, up to their reporting lag.
Past enrollment and registries are strong where the questionnaire is weakest
How well each source answers each question
SilentWeakUsefulStrong
Can it recruit?Are the patients there?Who competes?When can it open?Your site historyStrongWeakSilentStrongQuestionnaireWeakWeakWeakWeakPublic registriesSilentSilentStrongSilentLicensed patient countsSilentStrongSilentSilentApproval pathSilentSilentSilentStrong
Our reading of the sources3,1,6 · Our judgment from the guideline's evidence language and the registries' update rule. Yours may differ by disease.
Show the numbers
Can it recruit?
Are the patients there?
Who competes?
When can it open?
Your site history
Strong
Weak
Silent
Strong
Questionnaire
Weak
Weak
Weak
Weak
Public registries
Silent
Silent
Strong
Silent
Licensed patient counts
Silent
Strong
Silent
Silent
Approval path
Silent
Silent
Silent
Strong
Feasibility, site qualification and study start-up come in that order
Three neighboring activities are often confused. From site identification to initiation, the whole process took about 31 weeks in a Tufts follow-up study, with no improvement on figures from almost ten years earlier.7
First · Feasibility
Whether and where to approach
Decides which countries and sites are worth asking, and what each could bring to the study.
Then · Site qualification
Is this investigator fit to run it?
Confirms a chosen investigator's fitness, sometimes through a pre-study visit. ICH E6(R3) lists site selection monitoring reports among essential records that should generally be in place before the trial starts.3
Then · Study start-up
Contracts, budgets, ethics and activation
Covers what a chosen site needs before it can recruit.
03 · The rules and their dates
ICH E6(R3) investigator selection and 21 CFR 312.53: what sponsors must show, and since when
In shortNo rule gives a scoring formula. The rules make the sponsor responsible for selecting qualified investigators, ask each investigator to demonstrate recruiting potential and resources, and require records that can be verified later. ICH E6(R3) took effect in the EU on July 23, 2025, and FDA published it as final guidance in September 2025.
Eight dates since 2024 changed the rules around site selection
Aug 27, 2024Brazil's clinical research law takes effect
Law 14,874/2024; Decree 12,651 followed on October 7, 2025.
Jan 6, 2025ICH finalizes E6(R3)
Step 4 of its process: principles and Annex 1.
Jan 31, 2025EU transition ends
Every ongoing EU trial falls under Regulation 536/2014.
Jul 23, 2025E6(R3) in effect in the EU
Principles and Annex 1.
Sep 2025FDA publishes E6(R3)
Final guidance, docket FDA-2023-D-1955.
Apr 28, 2026New UK clinical trial rules
Applications from this date follow the new regime.
Jun 11, 2026ICH M11 in effect in the EU
A structured protocol template, adopted by ICH on November 19, 2025.
Jan 15, 2027E6(R3) Annex 2 in effect in the EU
Adopted by ICH on June 3, 2026, and by the human medicines committee of the European Medicines Agency (EMA) on June 25, 2026.
"The sponsor is responsible for selecting the investigator(s)/institution(s)." Each investigator should be qualified and "demonstrate they have adequate resources and facilities".3
The investigator should be able to demonstrate, "e.g., based on retrospective or currently available data", a potential for recruiting the proposed number within the agreed period.3
Same
ICH E6(R3) 2.2.2
Sufficient time, qualified staff and adequate facilities "for the foreseen duration of the trial".3
Same
ICH E6(R3) 10.1, 10.2, 3.6.4
A sponsor may transfer tasks and retains overall responsibility. Anything transferred to a service provider goes in an agreement; anything not transferred stays with the sponsor.3
Same
ICH E6(R3) 3.9.5, principle 9.4, Appendix C
Selection is a "fundamental" part of oversight. Record processes should keep integrity and traceability so that information can be accurately reported, interpreted and verified. An essential record can document "sponsor oversight of investigator site selection".3
Same
21 CFR 312.53
"A sponsor shall select only investigators qualified by training and experience as appropriate experts to investigate the drug." Before a study starts: a signed Form FDA 1572, a CV or similar record, the plan and financial information.14
In force
EU Regulation 536/2014
One scientific Part I for all countries in the application; a national Part II that differs by member state.15
Sponsors of certain studies would submit plans with enrollment goals for underrepresented groups.
Still a June 2024 draft, on a page restored by court order.16 One analyst report says final guidance had not been issued as of July 2026.17 Check before relying on it.
What the guideline leaves to your own site selection criteria
Read E6(R3) looking for a list of site selection criteria and you will not find one: no required weighting, no minimum enrollment rate, no limit on competing studies. A rare-disease study and a primary-care study could not share one rule. The guideline fixes the questions and leaves the answers to the sponsor, with the obligation to keep what it relied on.
The guideline also sets a courtesy that fast feasibility rounds tend to strain: section 3.7.2 asks the sponsor to give potential investigators the protocol, an up-to-date Investigator's Brochure and "sufficient time" to review them.3
04 · Approval clocks by country
How long clinical trial approval takes in the US, EU, UK, Canada, Japan, South Korea and Brazil
In shortA country with many patients can still arrive late. Regulators in the US and Canada default to about 30 days, the EU can take 60 to 106, and Brazil's law allows its regulator 90 business days. These are legal clocks. A site still needs its contract and budget, and in most of these countries its ethics review, before it can recruit, and that whole path averaged about 31 weeks in a Tufts survey.7
Brazil's regulatory clock runs about four times as long as the US default
Standard clock for a new trial when the regulator asks no questions, in calendar days; working days converted at five to a week
Brazil, Anvisa90 business days126 days
EU, multinationalup to 106 with questions60 days
South Korea, MFDS30 working days42 days
United Kingdom, combined review7 to validate, then 30; up to 107 with questions37 days
United States, INDunless FDA places a hold30 days
Canada, clinical trial applicationdefault period30 days
Japan, first notificationno trial for 30 days30 days
Australia, notification (CTN)5 to 7 working days to acknowledge10 days
Our reading of the sources18,19,20,21,15,22,23,24,25 · Our comparison. The EU and UK clocks include ethics review; elsewhere ethics is separate, and in Australia it comes first. Contracts and imports are extra everywhere. Australia's figure is the regulator's acknowledgement target for a notification it does not evaluate; its 50-working-day approval route is the other path. Questions from a regulator can extend any of these. Anvisa and MFDS are the Brazilian and South Korean regulators; an IND is a US investigational new drug application.
Show the numbers
Country
Calendar days
Brazil, Anvisa
126 days
EU, multinational
60 days
South Korea, MFDS
42 days
United Kingdom, combined review
37 days
United States, IND
30 days
Canada, clinical trial application
30 days
Japan, first notification
30 days
Australia, notification (CTN)
10 days
Brazil
A new law, a system in transition
Law 14,874/2024 gives Anvisa, the national health regulator, 90 business days on primary petitions, and development may begin if Anvisa has not answered, provided ethics approval is in place. Ethics committees have 10 working days to check the documents, then 30 business days from accepting them.24,11 Applications may go in parallel, and a drug trial starts only with both approvals. Decree 12,651 is moving the country to a new national ethics system. A court challenge to the law is pending, and the law stays in effect.11
European Union
One application, several countries
Part I is common and Part II is national, with authorization taking 60 to 106 days, the longer path when questions are asked.15,26 FAST-EU, a voluntary pilot, aims for 70 calendar days on multinational trials; by May 2026 three procedures had finished at or near that target.27,28 The Commission's Biotech Act proposal would shorten multinational trials to 75 days and could apply in 2028 or later.26 On November 3, 2026, the European Parliament's file read "Awaiting committee decision".29
United Kingdom
A combined decision within 30 days
Since April 28, 2026, validation comes within 7 days and the authorities take all reasonable steps to issue a combined decision within 30 days of that.20,10 A request for further information gives the sponsor up to 60 days, within a 107-day maximum.21 Applications made on or before April 27 stay under the old regime.10
Japan
No trial for 30 days after a first notification
A sponsor's first notification for a new drug starts a review period: the law bars the trial until 30 days after submission, and PMDA, the national regulator, publishes a checklist for that 30-day review.22
South Korea
30 working days on paper, longer in practice
The regulator is reported to review within 30 working days, and the text we could read is a consultancy's.23 A Korean newspaper's survey of listed biotechs found an average of 128 days across 32 applications from January 2023 to February 2025.30 In July 2026 the regulator announced a 10-day period for applications that carry a prior-review notice, planned for June 2027.31
Australia
Ethics review comes first
Under the notification route, the ethics committee reviews first, and the regulator evaluates no trial data at submission.25
Geography is shifting under every feasibility plan
The European Commission says the European Economic Area's share of global clinical trials fell from 18% in 2013 to 9% in 2023, while China's rose from under 10% to nearly 30%.32 Another count, "over the past decade", gives the European Economic Area 22% falling to 12% and China doubling to 18%.33 The counts differ, and the direction agrees. Old habits about which countries are "standard" deserve a fresh look.
Europe's share of global trials halved in a decade while China's roughly tripled
Share of global clinical trials, Commission figures; China's 2013 figure is given as less than 10%
20132023
European Economic Area18%9%
China10%30%
Source32 · The Commission gives China as "less than 10%" and "nearly 30%". Drawn at 10 and 30.
Show the numbers
2013
2023
European Economic Area
18%
9%
China
10%
30%
05 · The evidence behind a list
Protocol criteria, site history, questionnaires, registries and patient counts: what each one proves
In shortA defensible site list rests on five kinds of evidence. Each has a known trap: criteria that get paraphrased, site history that covers only your own studies, questionnaires that flatter, registries that lag, and patient counts that describe a population and say little about who will walk in the door.
Evidence
What it gives you
The trap
What careful teams do
Protocol synopsis
Population, inclusion and exclusion criteria, procedures, visit burden, target size.
A paraphrased threshold changes the pool. "Moderate to severe at endoscopy" cannot be applied to a count; a named score with a number can.
Copy each threshold word for word with its section. ICH M11's structured template, now adopted, makes criteria easier to read.13
CTMS site history
Enrolled against planned, months recruiting, screen failures, start-up weeks, by study. CTMS means clinical trial management system.
It covers only studies you ran. Almost a third of a study's sites can be new to the sponsor or CRO.7
Score a site with no history as neutral, and say so. Compare like with like: similar population, similar burden.
Feasibility questionnaire
What changed recently: a new investigator, a referral clinic, equipment, staff, other studies at the site.
Long, duplicated across sponsors and often unpaid.1 The American Society of Clinical Oncology (ASCO) calls current assessments "costly, inconsistent, inefficient, labor intensive, and of uncertain effectiveness".34
Ask fewer questions, standardize them, and compare each claim with the record.34
Public trial registries
Who is recruiting, what population, where.
On ClinicalTrials.gov a responsible party has 30 days to update recruitment status, and other fields can wait up to 12 months.6 Only a study in the same population competes.
Record the date read. Mark each study same or different population, with the reason.
Licensed patient counts
How many people meet each criterion, country by country, from claims or health records.
Criteria that records cannot see, such as an endoscopic score, are estimated. Very small counts can identify people; US Medicare data rules bar reporting table cells of 1 to 10.35
Use counts only, show the data cut (the date the counts were taken), and list the criteria that could not be applied.
Longer entry criteria shrink every country's patient pool at once
Eligibility is the input every other number inherits. In 1,197 National Cancer Institute (NCI)-affiliated Phase II and III trials started from 2008 to 2018, trials with the shortest criteria failed on accrual 11.8% of the time, and those with the longest failed 29.4% of the time. Median criteria grew from 214 unique content words in 2008 to 417 in 2018.4
These are cancer trials, so do not carry the rate across. The direction is useful anywhere. At one specialist referral center in another study, only 31.1% of patients with inflammatory bowel disease would have qualified for any of eight major trials.36
Trials with the wordiest entry criteria failed on accrual two and a half times as often
Share of NCI-affiliated Phase II and III trials that failed on low accrual
Longest criteria, top tenth (445 to 750 words)29.4%
All 1,197 trials19.3%
Shortest criteria, bottom tenth (12 to 112 words)11.8%
Why a country's patient funnel beats one big number
A country's eligible pool should read as a funnel, so that a reader can see where the patients go. In the fictional example, Brazil starts with 98,900 people living with Crohn's disease and ends with 11,500 a year who meet the endoscopic score. Each row is a criterion from the protocol, applied in protocol order.
Brazil's pool narrows from 98,900 people to 11,500 eligible a year
Real-world counts a year, criteria applied in protocol order
Living with Crohn's disease98,900
Moderate to severe36,800
Failed an advanced therapy19,550
Meets the endoscopic score11,500
Fictional example from this guide
Show the numbers
Criterion
People
Living with Crohn's disease
98,900
Moderate to severe
36,800
Failed an advanced therapy
19,550
Meets the endoscopic score
11,500
The eligible pool is a ceiling. Few of these people will hear about the study, live near a site, agree and pass screening.
06 · The arithmetic, worked
Four feasibility calculations worked by hand: claim check, site score, site rate and forecast range
In shortFour small calculations carry most of a feasibility decision. Compare a site's claim with its record. Combine weighted factors into a score, and keep the weights visible. Turn history into a monthly rate. Add up sites from the date each one opens, and report a range. All numbers in this section come from the fictional example.
1. Checking a questionnaire claim against what the site screened
claim ratio = patients claimed a year ÷ patients screened a year · 80 ÷ 14 = 5.7 times
The Duisburg site claims about 80 eligible patients a year and screened 14 in a year on an earlier study. One planning rule counts a claim at no more than twice history until the site confirms it, here 2 × 14 = 28. The cap is a sponsor's choice, and no regulation sets it. It stops an unchecked number driving a plan. Where a site has no history, the same rule set counts the claim at 60% and scores the site as neutral.
2. Building a weighted site score that a reader can argue with
A score turns six judgments into one number. The weights below are one sponsor's defaults: past enrollment 30, patient pool 20, start-up speed 15, competition 15, questionnaire quality 10, representation 10. Representation means how well a site reaches the communities the study needs. Each factor is scored from 0 to 100, multiplied by its weight, and added.
Factor
Weight
Duisburg site
Points
Warsaw site
Points
Past enrollment
30%
40
12.0
100
30.0
Patient pool
20%
56
11.2
92
18.4
Start-up speed
15%
21
3.1
96
14.4
Competition
15%
12
1.8
78
11.7
Questionnaire quality
10%
57
5.7
100
10.0
Representation
10%
31
3.1
9
0.9
Score
100%
37
85
The Warsaw site wins on five of six factors and loses on representation
Factor scores from 0 to 100 for two fictional sites
Duisburg, score 37Warsaw, score 85
Past enrollment40100
Patient pool5692
Start-up speed2196
Competition1278
Questionnaire quality57100
Representation319
Fictional example from this guide
Show the numbers
Duisburg, score 37
Warsaw, score 85
Past enrollment
40
100
Patient pool
56
92
Start-up speed
21
96
Competition
12
78
Questionnaire quality
57
100
Representation
31
9
Notice the last row. A score of 85 hides a representation factor of 9, and a study team with a commitment to reach underrepresented groups would want to see it. That is the argument for showing factors beside any total.
3. Turning a site's history into a monthly rate
site rate = participants enrolled ÷ months recruiting · 31 ÷ 12 = 2.6 a month · 3 ÷ 12 = 0.25 a month
Compare with plan too. The Belo Horizonte site enrolled 31 against a plan of 12, and the Duisburg site enrolled 3 against a plan of 10. A careful forecast then discounts the rate for competition around the site, which is why a planning rate usually reads lower than the raw history.
4. Adding sites up from the date each one opens
enrolled by a date = sum, across open sites, of (rate × months open)
A forecast then repeats this many times with rates and opening dates varied, and reads off the dates by which 10%, 50% and 90% of the runs finished. The published statistical method treats patients as arriving at each site at random around that site's average (a Poisson process), with averages that differ between sites following a gamma distribution. Researchers have found that simple ranges from that model can be too narrow, that adding more sites does not fix this, and that improved ranges exist.37 Ask how any tool builds its range.
One plan gives three finish dates, February, May and September 2028
Participants enrolled by date, against a target of 480 in June 2028
Optimistic (P10)Most likely (P50)Cautious (P90)
0200400600480480480
Oct 2026Apr 2027Oct 2027Apr 2028Oct 2028
Fictional example from this guide · The fictional plan before any change. The target falls inside the range, and the cautious date is three months past it.
Show the numbers
Optimistic (P10)
Most likely (P50)
Cautious (P90)
Oct 2026
0
0
0
Jan 2027
1
1
1
Apr 2027
56
46
37
Jul 2027
172
141
113
Oct 2027
292
239
191
Jan 2028
412
337
270
Apr 2028
480
436
349
Jul 2028
480
480
427
Oct 2028
480
480
480
The width is the finding. A steering group told only "May 2028" does not know the study could plausibly run a quarter late. A range lets you ask what would pull the cautious end forward.
07 · How often enrollment misses
Clinical trial enrollment statistics: zero-enrolling sites, under-enrollment and where the 80% comes from
In shortThe best-known numbers are older or softer than they sound. A 2012 Tufts report has 48% of sites falling short of target, including the 11% of ready sites that enrolled nobody. The 80% figure traces to a trade article. Peer-reviewed accrual failure, about one in five, comes from publicly funded cancer trials and measures a harder failure than lateness.
About 11 in 100 ready sites enrolled no one
11 in 100
ready sites failed to enroll a single patient, in 151 Phase II and III trials from 2008 to 2010
ready sites failed to enroll a single patient, in 151 Phase II and III trials from 2008 to 2010
11 of 100
Latin American sites were the likeliest to enroll nobody, in 2012 data
Share of ready sites that enrolled no patients, by region
Latin America20%
North America13%
Asia Pacific9%
Eastern Europe8%
Western Europe7%
Source2 · Data from 2008 to 2010. A region's average says nothing about any one site, and Brazil's law has since changed.
Show the numbers
Region
Enrolled no one
Latin America
20%
North America
13%
Asia Pacific
9%
Eastern Europe
8%
Western Europe
7%
Figure often quoted
What it is
How to use it
11% of sites enroll no one
Tufts CSDD report, 151 trials from 2008 to 2010, nearly 16,000 sites.2
A dated benchmark. Replace with your own share.
48% of sites under-enroll
The same study. The article describes these as sites that "fail to enroll a single patient or under-enroll", so the 48% includes the 11%.2
Never add the two. By subtraction, about 37% enrolled some patients and too few: the bigger group, and often ignored beside the zeros.
80% of trials miss enrollment timelines
Repeated by the Association of Clinical Research Professionals (ACRP) beside 70% with start-up delays and 45% missing completion targets, with a trade article as its footnote.1
Say "widely cited". Avoid it in a board paper.
19.3% of trials fail on accrual
231 of 1,197 NCI-affiliated Phase II and III trials started from 2008 to 2018.4
Peer reviewed and specific to cancer. Carries over only as a direction.
We found no public figure for how often sites overstate patient numbers, how far they overstate them, or how many questionnaires come back unusable. Your own last three studies can answer all three.
08 · Crowded diseases
What competing trials do to site enrollment: Crohn's disease at 0.1 patients per site per month
In shortIn a crowded disease the rate decides everything. Published Crohn's recruitment fell to about 0.1 patients per site per month by 2018, while active inflammatory bowel disease trials more than doubled. At that rate a 480-participant study on 64 sites would take about six years. Our fictional example runs much faster than that, and you should read it for the method.
Recruitment per site fell by more than five times in Crohn's disease over 20 years
Average patients per site per month, moderate-to-severe disease
19982018
Crohn's disease0.650.1
Ulcerative colitis0.320.13
Source5 · Reported in a letter to Gastroenterology, citing Harris et al.
Show the numbers
1998
2018
Crohn's disease
0.65
0.1
Ulcerative colitis
0.32
0.13
Active inflammatory bowel disease trials rose from 32 to 79 in seven years
Active Phase 2 and 3 industry-funded trials in the US-based study
32June 2011
79June 2018
Source36 · Over the same years, trial participation in that patient cohort fell from 1.1% to 0.7%.
Show the numbers
Date
Active trials
June 2011
32
June 2018
79
More trials, fewer willing patients per trial. New approved drugs reduce the appeal of a study with a placebo arm, and colonoscopies and frequent visits add burden.36 The same paper reports that most US sites enroll only one or two patients per trial in these diseases.36 One CRO's review of 34 Phase II and III ulcerative colitis studies found a median of 94 sites, some with as many active sites as target patients, and a median ratio of one site to 2.4 patients.38
The sum a Crohn's feasibility lead should run first
months to enroll ≈ participants ÷ (sites × rate per site per month) · 480 ÷ (64 × 0.1) = 75 months
At the published Crohn's rate, 64 sites would need about six years to enroll 480
Months to enroll 480 participants on 64 sites, ignoring staggered openings
At 0.65 a month, the 1998 average11.5 months
At 0.5 a month, about the fictional plan's average15 months
At 0.1 a month, the 2018 average75 months
Our reading of the sources5 · Our arithmetic. Every site opening on day one is generous, so real timelines run longer.
Show the numbers
Rate
Months
At 0.65 a month, the 1998 average
11.5 months
At 0.5 a month, about the fictional plan's average
15 months
At 0.1 a month, the 2018 average
75 months
Read the example for its method. The fictional VLT-401 plan averages about 0.5 participants per site per month, and its best sites have histories above 2. Those rates are several times the published Crohn's average and keep the example easy to follow. A real plan in this disease would have many more sites, more time, or both. Use your own history.
Why a competing study has to be the same population to count
Six Crohn's studies recruiting in a country sounds like crowding. If four of them take children, or people who have never had an advanced therapy, or people after surgery, they may not touch your patients at all.
Good competition analysis matches condition, phase, line of therapy (how many treatments a patient has already tried) and age, and counts only same-population studies against a site, within a set distance. It also checks the site's own answer, because a questionnaire can name fewer rivals than the registry shows: in the example at the top of this page, two named against four found.
09 · What goes wrong
Why feasibility goes wrong: optimistic claims, stale registries, lost reasons and protocols that move
In shortMost failures are ordinary. A claim goes unchecked, a registry check is months old, a rate gets averaged across sites, the protocol changes and nobody re-runs the numbers, or a site gets chosen for its famous investigator. The most expensive failure comes later, when nobody can say why a decision was made.
The error
Why it happens
What it costs
The check
Taking a claim at face value
Sites want the study. Reading 130 forms against history takes weeks.
A forecast built on patients who do not exist.
Claim divided by screened, for every site.
Choosing by reputation
A known name reassures a steering group.
Start-up costs on a site that may under-deliver.
Show the record beside the request, and write the reason.
One average rate for all sites
Spreadsheets make it easy.
Hides that a few sites carry most of the study.
Forecast from each site's own rate and opening date.
A single forecast date
Leaders ask for one.
No view of the late tail, and nothing to size a fallback against.
Report P10, P50 and P90, and what moves each.
Counting every study as competition
A registry search by disease is quick.
Good sites marked down for studies that do not touch their patients.
Same or different population, with a reason per study.
Stale registry data
Checked once at the start.
A rival that opened last month goes unseen. US records can lag up to 30 days on status.6
Date every read, and refresh on a schedule.
Ignoring contract and budget time
Teams plan to the regulatory clock.
Budgeting and contract problems were the main reason cited for sites never activated.39
Split each site's start-up into contract, ethics and activation.
Not re-running after an amendment
The plan looks finished.
A plan that adds up, built on a population that has changed.
Recount pools, re-score sites, show the differences.
Losing the reason
It lived in a meeting or a cell comment.
No answer when an inspector, a successor or a country manager asks why.
File the reason with its sources beside the list.
Protocol amendments arrive after the site list is built
In 2016 Tufts found nearly 60% of protocols had a substantial amendment, a formal change to the study plan, and sponsors judged nearly half of those avoidable. Median direct cost per substantial amendment was $141,000 in Phase II and $535,000 in Phase III.40 Amended protocols also ran about three months longer and screened and enrolled substantially fewer patients against plan.40 A 2024 Tufts study updates the picture, and in it 77% of amendments were deemed unavoidable.41
76%
of protocols had at least one amendment, up from 57% since 2015.41
Tufts CSDD, 2024
260 days
on average from identifying the need to last oversight approval.41
Tufts CSDD, 2024
215 days
mean time that sites worked on different protocol versions.41
Tufts CSDD, 2024
A substantial Phase III amendment costs nearly four times a Phase II one
Median direct cost to implement one substantial amendment
What an inspector or auditor can reasonably ask about site selection
We found no public statistic isolating site selection in inspection findings. FDA publishes bioresearch monitoring metrics in general, and a selection decision is not one of its categories. The clauses still suggest the questions. Who selected this investigator, under what agreement? On what data was recruiting potential demonstrated? Was the claim checked? Can the record behind the decision still be reached?3 A list without reasons answers only the first.
10 · What delay costs
The cost of a day of clinical trial delay: $55,716 of Phase III trial cost, plus lost sales if the drug launches
In shortTufts CSDD published two kinds of number in 2024. A day of Phase II or III direct trial cost is about $40,000 on average and $55,716 in Phase III. A day of lost sales is about $500,000 in the journal article and about $800,000 in the later white paper, from one dataset. Keep them apart: one is money spent, the other is money that may be earned.
$55,716
mean direct cost of one Phase III trial day, across 447 protocol budgets in 2023 dollars.42
Tufts CSDD, 2024
$500K–$800K
a day in lost sales: about $500,000 in the journal article, about $800,000 in the white paper, both from 645 marketed drugs.43,42
Tufts CSDD, 2024
31 weeks
on average from site identification to site initiation.7
Tufts CSDD, 2017
A Phase III trial day costs more than twice a Phase II day
Two cautions travel with these. The sales figure is an average over a wide spread and has been falling by about $80,000 to $100,000 a year, and a product in a narrow indication should use its own forecast.42 And the trial-cost figure excludes a sponsor's indirect people and infrastructure, per the authors' method, so your own budget divided by your planned duration is the better input.43
Trial-cost days and lost-sales days do not add into one number
Trial cost is being spent for certain, on a study that is running. Sales are earned only if the medicine reaches the market. Weeks saved in feasibility count against either only if feasibility sits on the study's critical path, the chain of tasks that sets its start date. Often the protocol, drug supply or the first regulatory filing sets the first-patient date regardless. So any claim of savings is conditional, and a finance partner will test it first.
Feasibility software is sold three ways, and its market has no reliable public size
We found no reliable public figure for this market's size. Buyers can compare data vendors who sell site performance and registry data, CROs who run feasibility as a service, and clinical trial software suites. Most published claims about AI in feasibility come from those vendors. We found no independent test comparing tools on a sponsor's own finished studies, which is why Part C asks you to run one.
11 · Automation and AI
AI in clinical trial site selection: what it reads well, what regulators expect and where people stay
In shortSoftware reads forms, registries and exports quickly and tirelessly. It cannot tell you what a principal investigator's new referral clinic will do. FDA's January 2025 AI draft does not address tools for operational efficiency with no effect on patient safety, drug quality or study reliability, and it asks sponsors who are unsure to engage early. Either way, the sponsor stays responsible for the choice.
Reading and checking are the safest place to start; deciding stays with people
Where software fits in feasibility work
Judgment still needed →
People decide
People decide, software prepares
Leave as is
Automate first
Comparing claims with historyReading returned questionnairesMatching registry studiesWriting cited rationalesRanking and forecastingSigning the list
Reading effort saved →
Our reading of the sources3,44 · Our judgment, offered as a starting point.
Show the numbers
Item
Reading effort saved (0–1)
Judgment still needed (0–1)
Comparing claims with history
0.78
0.10
Reading returned questionnaires
0.72
0.22
Matching registry studies
0.76
0.34
Writing cited rationales
0.70
0.60
Ranking and forecasting
0.76
0.72
Signing the list
0.14
0.78
Text
Status
What it means for feasibility
FDA AI draft guidance
Draft, January 2025, docket FDA-2024-D-4689. "Not for implementation."
Covers AI that produces information to support regulatory decisions. It does not address "operational efficiencies (e.g., internal workflows, resource allocation...)" that do not affect patient safety, drug quality or study reliability, and encourages sponsors to engage FDA if unsure.44 Feasibility often looks operational; your quality unit makes that call.
Industry guidance on AI-enabled computerized systems in regulated areas, used with GAMP 5.
21 CFR Part 11
In force.
A signed electronic record shows the printed name, the date and time, and the meaning of the signature.48 A product supplies controls that support your compliance; none can be certified for it.
EU Annex 11 and draft Annex 22
Good manufacturing practice (GMP) texts. On November 3, 2026, the EU's EudraLex rules collection lists Annex 11 at January 2011 and no Annex 22.49 Annex 22 is a draft that says large language models (LLMs, the technology behind chatbots) "should not be used" in critical GMP applications.50
They govern manufacturing, and feasibility is good clinical practice (GCP) work. Some quality teams read them for direction when assessing any AI supplier.
Written for device production and quality system software. It does not cover this work. Do not accept it as a vendor's validation story here.
What record integrity asks of a machine-written rationale
E6(R3) wants source records attributable, legible, contemporaneous, original, accurate and complete, and wants processes that keep traceability so information can be verified.3 Source records are a trial's original data, and feasibility records are planning documents. The same habits still suit them. Each sentence in a rationale should open to what it came from, as it stood on that date. The study list should separate what software proposed from what a named person decided.
Four limits of AI feasibility tools, from favored sites to invented sentences
History favors sites already chosen
A ranking learns from history, and history can favor sites that have already been chosen. New sites and underserved communities need a stated rule, or they stay invisible.
A narrow range can still be wrong
A forecast's precision is no better than its rates. A narrow range on bad history is still wrong.
No peer-reviewed proof for any vendor's ranking
We found no peer-reviewed evidence that any vendor's ranking beats a sponsor's own feasibility team on that team's studies. Replaying a finished study is the test, and it is available to you.
Text-reading software can invent a sentence
It can write a confident line with nothing behind it. Citations reduce that risk only if someone samples them and opens them.
12 · How teams do it today
How feasibility teams work today: questionnaires, a CTMS export and a spreadsheet
In shortA feasibility lead sends questionnaires, pulls an export from the trial management system, checks registries by hand, buys patient counts and builds a spreadsheet. Country managers argue for their sites. A study lead approves allocation. The final list usually gets filed, and the reasoning usually stays in email and memory.
From the feasibility lead to the country manager: who shapes a site list
FL
Feasibility lead
Runs the round, reads the evidence, proposes countries and sites, and signs off the list.
Cares about: the reason, and where it came from.
SL
Study lead, clinical operations
Owns the timeline and budget, and approves country allocation.
Cares about: what a change does to last patient in.
CM
Country manager
Knows local sites and approval paths. Argues for the investigators they trust.
Cares about: having a written reason for each decision on their sites.
ML
Medical lead
Confirms the criteria and the patient-pool logic.
Cares about: thresholds copied exactly.
SU
Site start-up and contracts
Takes the list forward into contract, ethics and activation.
Cares about: how long each site's legal review takes.
CR
CRO partner
Often sends the questionnaires and runs the country work. Responsibility stays with the sponsor.3
Cares about: clear scope in the agreement.
Six steps and five roles between a protocol synopsis and a signed site list
A site list passes through at least five roles before it is signed
1Synopsis to shortlist
Read the criteria, list candidate countries and sites.
Feasibility lead, medical leadDays
2Questionnaires out and back
Send, chase, wait. The example's window ran three weeks.
Feasibility lead, CROAbout 3 weeks
3Evidence gathered
Read forms, export history, search registries, get counts.
Feasibility leadAbout 3 weeks
4Scored in a spreadsheet
Weights, rationale, first forecast.
Feasibility leadAbout 1 week
5Country review
Managers argue for sites; swaps agreed.
Country managersDays
6Allocation approved and list signed
Study lead approves, feasibility lead signs, file.
Study lead, feasibility leadDays
Illustrative · replace with your own numbers · Times are illustrative. Nobody publishes them.
Show the numbers
Step
What happens
Who
Time
Synopsis to shortlist
Read the criteria, list candidate countries and sites.
Feasibility lead, medical lead
Days
Questionnaires out and back
Send, chase, wait. The example's window ran three weeks.
Feasibility lead, CRO
About 3 weeks
Evidence gathered
Read forms, export history, search registries, get counts.
Feasibility lead
About 3 weeks
Scored in a spreadsheet
Weights, rationale, first forecast.
Feasibility lead
About 1 week
Country review
Managers argue for sites; swaps agreed.
Country managers
Days
Allocation approved and list signed
Study lead approves, feasibility lead signs, file.
Study lead, feasibility lead
Days
Reading questionnaires takes the largest share of a spreadsheet round
Estimated working days, questionnaires back to an approved list, about 130 returned
Reading questionnaires and chasing answers8 days
Scoring sites and writing the rationale6 days
Pulling history and checking claims5 days
Checking registries for competing trials4 days
Estimating eligible patients by country4 days
Forecast, country review, approval and filing3 days
Illustrative · replace with your own numbers · An estimate; we found no public figure. Time your own next round.
Show the numbers
Task
Working days
Reading questionnaires and chasing answers
8 days
Scoring sites and writing the rationale
6 days
Pulling history and checking claims
5 days
Checking registries for competing trials
4 days
Estimating eligible patients by country
4 days
Forecast, country review, approval and filing
3 days
Spreadsheet, CRO service or feasibility software
In house
Spreadsheet and CTMS export
Flexible, and it uses your own history. It leans on a few people, its reasons rarely survive, and "what if we open Brazil?" waits for the next meeting.
Outsourced
CRO feasibility service
Brings country knowledge and capacity. In one survey CROs reported shorter start-up cycle times than sponsors.39 You still need to see the evidence, because the selection stays your responsibility.3
Software
Data platforms and AI feasibility tools
These sell site performance benchmarks, registry data and forecasts. They differ most on whether your own history counts, whether each ranking can be traced to its source, and who can change the weights.
Part B · See it working
Botminds Clinical Trial Feasibility on one Crohn's study, from questionnaires back to a signed site list
Part A described the work without naming a product. This part shows how Botminds does it at a fictional biotech, Northwind Bio. The agents named below are pieces of software that each do one job; section 15 lists them. Every company, site, investigator, competing study, person and number in the screens is sample data.
13 · One study, start to finish
VLT-401 in nine steps: Brazil moves to core, Rheinhafen stays a back-up, and the list is signed
In shortLena Ortiz, the feasibility lead, opens the study as a world map. She reads why Brazil is only a back-up, moves it to core, and watches last patient in move from May to March 2028. She sends that to the study lead. She answers a country manager's request with a written reason, signs the list and files it. When the protocol changes, the agents re-run everything before anything moves.
1
The plan opens as a map of 14 countries
VLT-401 is a Phase 3 study of Veltrimab in moderate-to-severe Crohn's disease: 480 participants, target last patient in June 2028. Questionnaires went out on September 12 and closed on October 2. Countries appear as bubbles sized by participants allocated, with the United States at 140 and Poland at 78 as lead countries, and France and Brazil held back. Other measures swap in at the top: score, eligible patients, competing trials, start-up weeks.
The plan as a map. Blue is lead, green is core, amber is back-up. The note says one EU application covers the seven EU countries, and the UK goes through its own combined review.
2
Why Brazil is only a back-up, with each reason's source
Lena clicks Brazil. It ranks 13th of 14 with a score of 60. Five factors appear, each with a value and a link to its source: past enrollment of 1.70 a site a month from site history, 11,500 eligible a year from real-world counts, one same-population trial of six recruiting, a 27-week start-up with 150 days of approval, and four questionnaires with consistent claims. Beside them sits the forecast: most likely May 2028, 7 weeks before target, with a range of February to September 2028 on 64 primary sites.
Why this tier. The sample plan adds about 90 days for Anvisa and about 60 for ethics, one after the other, to reach 150. The real rule: Brazil's law gives Anvisa 90 business days, about 126 calendar days, and ethics committees 10 working days to check the documents, then 30 business days. The two may run in parallel, and a drug trial starts only with both approvals.24,11 Use the real clocks in your own plan.
3
She moves Brazil to core, and the forecast follows
The switch reads Lead, Core, Back-up. Lena picks Core. Brazil's three ready sites open as primary and take 36 participants: 20 from the United States, 10 from Canada and 6 from Italy. The forecast is recalculated from each site's own history. Most likely last patient in becomes March 2028, two months earlier, with a range of January to July on 67 primary sites. Nothing has happened yet. It is a proposal, and it can be undone.
Move a country, see the date. The two-month move is the example's own estimate, shown before anyone commits. It rests on the sample's 150 approval days, which differ from Brazil's law (see the step above).
4
The change goes to the study lead with its evidence
One click sends it to Sam Patel, who owns the timeline and approves country allocation. It lands on the audit trail. Country manager Elena Duarte can point to Brazil's whole case: the patient funnel, the single same-population competitor among six Crohn's studies recruiting, the approval path and the sites.
One country's case. Studies in other populations stay on the page and are not counted against sites. The funnel runs from 98,900 people living with Crohn's disease to 11,500 a year. The approval path on this screen is the sample plan's: about 90 days, then about 60, in sequence. Brazil's law gives Anvisa 90 business days and ethics committees 10 working days to check documents, then 30 business days, and the two may run in parallel.24,11
5
Ninety sites, ranked on what they did
Every site with a usable questionnaire is scored on six weighted factors. Each row shows the rate a month, start-up weeks, competing trials within 25 km and the claim against history. The filter along the top finds 23 sites claiming more than three times what they screened, each counted at twice its history until it confirms. Move a weight and the agents re-propose inside each country's allocation. Decisions made by people stay.
The ranking board. "A month" is the forecast rate after a discount for nearby competing trials, so Centro Mineiro de DII reads 1.57 where its history says 31 in 12 months. These sample rates run well above the published Crohn's average; see section 8.
6
A country manager pushes for a site, and the reason answers him
Tom Becker asks to make Universitätsklinikum Rheinhafen, the Duisburg hospital from the quick example, a primary site. The rationale says why it ranks 85th of 90. In VLT-208 it enrolled 3 against a plan of 10 in 12 months. Start-up took 29 weeks. Its questionnaire claims about 80 eligible a year where it screened 14. Four same-population trials recruit within 25 km, one at the hospital itself, and the questionnaire names only two. Each numbered citation opens its source in the panel on the right.
Every sentence cited. The agents propose. Lena decides, and her reason goes to Tom and onto the list.
7
The site's own words, highlighted where the claim came from
Lena opens citation 3. The questionnaire appears at question 7 in the site's own words. Other tabs hold its history, its four competing trials with distances, and its investigator. She keeps Rheinhafen as a back-up that opens if a German primary site falls behind after month 6. Tom reads the reason and signs Germany, the UK and France.
The questionnaire. The site left question 12 blank.
Competing, with distances. A fifth study is shown as not counted, with the reason.
8
She signs the list with the meaning of her signature
The site list shows each approval: the agents' proposal, five of five country managers, the study lead's allocation. Lena signs VLT-401 site list v3 with her password and chooses the meaning: "I approve this site list and the rationale for each site" or "I have reviewed this site list". The list, the allocation, the P10 to P90 forecast and the approval record go to the trial master file under site selection, with a rationale for each of the 76 primary and back-up sites.
Signature with meaning. Name, time and meaning are recorded: controls that support your compliance with 21 CFR Part 11.48
9
When the protocol changes, everything re-runs before anything moves
Amendment 1 lowers the endoscopic entry score, the Simple Endoscopic Score for Crohn's Disease (SES-CD), to 4 or more (3 or more in isolated ileal disease) and allows up to four prior advanced therapies. In 3 minutes 12 seconds on this sample, the agents re-read the criteria, recount the pool (up 14% overall) and re-score all 90 sites. Three proposals change, each with its reason. Lena applies or discards them. Nothing reaches the plan until she does.
What changes, before it changes. Each country's eligible pool moves by its own amount, from 11% to 17% in this panel.
14 · Every other screen
Seventeen more screens, from the country table to how well past rankings predicted enrollment
In shortThe walk above is the story. These screens show the rest: a lead country's evidence, the country table, a country's sites, drafted follow-ups, weight presets, the site's history and investigator, the decision, the list and its approvals, the filing preview, the signed state, the dashboard, and your own rules.
A lead country. Poland ranks first with a score of 88, and the evidence also says Warsaw is getting crowded.
Countries side by side. This is the plan after the Brazil move. The approval days are the sample plan's own allowances, and two differ from the law. The UK's 60: since April 28, 2026, the rule is 7 days to validate, then all reasonable steps to a combined decision within 30.20,10 Brazil's 150: the law gives Anvisa 90 business days, about 126 calendar days, and ethics committees 10 working days to check documents, then 30 business days, and the two may run in parallel.24,11 Real clocks for each country are in section 4.
A country's sites. Three of Brazil's four sites go primary. The fourth, ranked 81st, is not selected.
Follow-ups, drafted. Nothing leaves until a person presses Send.
Change the weights. The Fast start-up preset moves four proposals and costs a week in this sample.
What the record says. Start-up splits into contract, ethics and activation.
The investigator. Training, studies, inspections and staff, on one page.
The person's decision. A written reason goes to the country manager and onto the list.
The site list. Allocation by country, what each can enroll by the target date, and the forecast fan.
Approvals and changes. People's moves stay on the record, each with its reason.
The rationale document. What will go to the trial master file, citations included.
Change sent. On the audit trail, waiting for the study lead.
Signed and filed. Every step done.
Did the ranking predict anything? Sample figures throughout, and no customer result. The 11 days and 3% on these tiles are the solution's design targets, shown here as results only to explain the screen; measure them in your own use. "About 6 weeks" is an estimate, and "about 11%" is the Tufts figure from 2008 to 2010 trials.2
Countries by factor. One glance shows that Brazil's weakness is start-up speed.
Your rules. Weights, the 2× claim cap, the radius and the follow-up threshold; every change is on the audit trail.
Approvers and sources. Who signs what, and what the agents may read.
Select any screen to open it larger. The companies, people, sites and figures are fictional. Site rates in this sample were set to keep the example easy to follow and run well above the published Crohn's average.
What the sample dashboard says about ranking and enrollment
In the sample data, top-quarter sites enrolled 5.8 times as fast as the bottom quarter
Participants per site a month on finished studies, by rank band
1.38Top quarter
0.79Second
0.48Third
0.24Bottom quarter
Fictional example from this guide · Fictional sample data. This is the test to run on your own finished studies.
Show the numbers
Rank band
Per site a month
Top quarter
1.38
Second
0.79
Third
0.48
Bottom quarter
0.24
Competing trials and slow start-up explain over half of the sample's not-selected sites
118 sites not selected, last 12 months, sample data
118not selected
Competing trials nearby30%
Slow start-up23%
Claim far above history19%
No in-house endoscopy12%
Incomplete questionnaire10%
Other6%
Fictional example from this guide
Show the numbers
Part
Value
Competing trials nearby
30%
Slow start-up
23%
Claim far above history
19%
No in-house endoscopy
12%
Incomplete questionnaire
10%
Other
6%
15 · Agents, and who signs
Six agents read, count, check and rank; country managers, the study lead and the feasibility lead decide
In shortEach agent has one job and limits it does not cross. None of them decides. Country managers review their sites and can swap one with a written reason. The study lead approves country allocation and every tier change. The feasibility lead decides each site and signs the final list. Every step goes on the audit trail.
From protocol reader to rationale writer: the six feasibility agents
Protocol reader
Extracts the population, each inclusion and exclusion criterion as a structured rule, procedures that need site equipment, visit burden and target size, citing the protocol section for each.
Never paraphrases a threshold. It flags any criterion it cannot structure.
Patient-pool estimator
Applies the criteria, in protocol order, to licensed real-world counts per country, and keeps the funnel down to eligible patients a year.
Never uses patient-level data: counts only, minimum cell size 11. Every number shows its data cut.
Competing-trial scanner
Reads public registries for recruiting studies, matches on condition, phase, line of therapy and age, and marks each as same or different population, per country and within 25 km of each site.
Never counts a different-population study against a site. It cites the registry entry for every match.
Site history analyst
Reads the trial management system: enrolled against planned, months recruiting, screen failure, start-up split into contract, ethics and activation, data quality and inspections.
Never infers what the record does not hold. No history means neutral, never zero. Read-only access.
Questionnaire reader
Reads each returned questionnaire, from a portal, PDF or email, with its question numbers. It checks completeness, compares claims with what the site screened and drafts plain follow-up questions.
Never sends a follow-up itself. It quotes the site's own words.
Ranker and rationale writer
Scores six factors, combines them with the study's weights, writes a rationale where every sentence cites its source, proposes primary, back-up or not selected, and forecasts last patient in from 2,000 simulations.
Never decides, and writes no uncited sentence. Explains every move of more than 5 places.
Country managers review, the study lead approves, the feasibility lead signs
Reviews and arguesCountry managerReviews their sites and can swap or add one with a written reason, then signs their countries.
Approves allocationStudy leadApproves the country allocation and every tier change, with the forecast each one produces.
Decides and signsFeasibility leadDecides each site and signs the final list, which is filed to the trial master file.
Each signature records name, date, time and meaning. These are controls that support your compliance with 21 CFR Part 11 and EU Annex 11; no product can be certified against them. Botminds' own credentials are SOC 2 Type II audited and information security managed to ISO 27001. Roles, separation of who proposes from who approves, and a full audit trail come as standard; registries and new answers refresh every Monday, and any site that moves more than 5 places is explained.
Lena, Sam, Elena, Tom and Maya: the people in the VLT-401 screens
Fictional, from the sample data
LO
Lena Ortiz · feasibility lead, Northwind Bio
Runs feasibility for three studies and signs the final list.
"Give me the reason, and where it came from."
SP
Sam Patel · study lead, clinical operations
Owns the timeline and approves country allocation.
"Tell me what moving a country does to last patient in."
ED
Elena Duarte · country manager, Spain, Italy, Brazil
Knows her sites and pushes for Brazil.
"Brazil's sites are the fastest we have. The approval is the only problem."
TB
Tom Becker · country manager, Germany, UK, France
Wants Rheinhafen as a primary site.
"Prof. Albers leads the national IBD society and other sites follow his lead."
MC
Dr. Maya Chen · medical lead
Confirms the criteria and the patient-pool logic.
"Thresholds copied exactly, or not at all."
16 · What goes in and out
Protocol, site history, questionnaires and registries in; a ranked, cited list and a live forecast out
In shortBotminds reads the protocol, your own site history, each returned questionnaire, public registries and licensed patient counts. It leaves behind a ranked list where each reason is cited, a forecast with a range, a map of competing trials, and a signed list in your trial master file. Your trial management system and questionnaire portal stay where they are.
From your study team
Protocol synopsis and amendments
Returned questionnaires, from a portal, PDF or email
Your weights, rules and approvers
From your systems and partners
Site history from the clinical trial management system
Public registries of recruiting studies
Licensed real-world patient counts, counts only
Agents read, check, rank and forecastEvery country, site and claim, under your rules
People decide every site
Every sentence cites its source
Outputs
Ranked country and site list, with reasons
Live enrollment forecast, P10 to P90
Competing-trial map
Drafted follow-ups for you to send
Signed list and rationales in the trial master file
Questionnaire portal and emailReturned forms and follow-ups
Public trial registriesRecruiting studies, refreshed weekly
Licensed patient countsCounts from your data partner
Electronic trial master fileThe signed list, rationales and approvals
Single sign-onYour roles and people
The design targets behind the 11 days and the 3%
The design target cuts questionnaires-to-list from about six weeks to 11 days
Calendar days, including waits for sites and approvers
By spreadsheet (estimate)Design target
Questionnaires back to an approved site list42 days11 days
Illustrative · replace with your own numbers · Six weeks is an estimate. Eleven days is a design target, with no customer result behind it yet. Time your own round to compare.
Show the numbers
By spreadsheet (estimate)
Design target
Questionnaires back to an approved site list
42 days
11 days
One more design target: 3% of chosen sites enrolling nobody, against 11% in the 2012 Tufts data.2 Neither target is a result from a customer. The two-month move on Brazil is the fictional example's estimate.
Part C · Are you ready to automate?
Clinical trial feasibility software: what empty sites and late site lists cost, what automation returns and how to test it
You run feasibility, or run clinical operations, or pay for sites that may never enroll. This part is written for you: what errors and delays cost today, what automating the reading and checking could return, whether your team is ready, and what to ask any vendor, including us.
17 · What errors and delays cost
What a zero-enrolling site, an under-enrolling site and a slow feasibility round cost your study
In shortStart from your own budget. Published figures frame the problem: how many sites enrolled nobody, what a Phase III day costs, and how long start-up takes. The share of your sites that under-enrolled, and what each one cost to open, are numbers only your own finished studies can give you.
48%
of nearly 16,000 sites fell short of target in Tufts' 2012 report, including the 11% that enrolled no one.2
Tufts CSDD, 2008 to 2010 trials
$55,716
mean direct cost of a Phase III trial day, 2023 dollars.42
Tufts CSDD, 2024
260 days
on average from needing a protocol amendment to last oversight approval: your plan has to survive that.41
Tufts CSDD, 2024
Reading and checking shrink; country argument and approval barely move
Working days of effort, questionnaires back to an approved list, about 130 returned
By spreadsheet (estimate)With the solution (estimate)
Reading questionnaires, chasing answers8 days2 days
Scoring sites, writing the rationale6 days1 day
Pulling history, checking claims5 days0.5 days
Checking registries for competing trials4 days0.5 days
Estimating eligible patients by country4 days0.5 days
Forecast, country review, approval, filing3 days2 days
Illustrative · replace with your own numbers · Estimates, with people still reviewing, approving and signing. Replace them with a timed round of your own.
Show the numbers
By spreadsheet (estimate)
With the solution (estimate)
Reading questionnaires, chasing answers
8 days
2 days
Scoring sites, writing the rationale
6 days
1 day
Pulling history, checking claims
5 days
0.5 days
Checking registries for competing trials
4 days
0.5 days
Estimating eligible patients by country
4 days
0.5 days
Forecast, country review, approval, filing
3 days
2 days
What nobody publishes. We found no public figure for the cost of opening a site that never enrolls, how often sites overstate patient numbers, or hours per feasibility round. Vendor figures for these rarely come with a dataset. Measure your own.
Counting your own zero-enrolling sites and missed claims
Cost
Where it hides
How to find your number in a week
Sites that enrolled nobody
Spread across contracts, ethics, activation and monitoring lines
From your CTMS: activated sites with zero enrolled, last five studies. Ask finance what one costs to open and close.
Sites far under plan
Extra sites added late (rescue sites) and extended timelines, booked as "enrollment"
Enrolled divided by planned, per site. Count the share under half.
Overstated claims
In the forecast, never named
Claim divided by screened on one finished round. How many were above 2 and above 3?
Feasibility hours
One lead, three studies, no time code
Ask the lead to estimate the last round by task, then time the next one.
Forecast error
Plans reset midway (re-baselined)
Last patient in as first forecast, against the actual date, last five studies.
Re-work after amendments
An unplanned week, or a plan left unchanged
Amended studies: did anyone recount pools? How long did it take?
Investigators who stop answering, and reasons nobody can find
Site goodwillSites answer long forms, often unpaid. Sponsors who ask less, and answer why a site was not chosen, get better answers next time.
The study you never had time to planA lead with three rounds at once reads the third badly.
Knowledge that walks outWhen a feasibility lead leaves, so do the reasons behind every list.
Patients you did not reachA list built purely for speed can meet its total and miss communities the study needs.
Questions from an auditorA signed list with no recoverable reason takes days to defend.
18 · Your return
What better site selection returns: feasibility hours, fewer empty sites and trial days on the critical path
In shortPut in your own numbers. The calculator counts the hours a round takes and the sites you avoid opening, against what the tool costs. It shows trial days separately, because they count only if feasibility sits on your study's critical path. Every default marked illustrative is an assumption to replace.
Hours, empty sites, days and reasons: where feasibility saves
Team time
Reading replaced by reviewing
Questionnaires, exports and registries arrive read and compared, and the lead reviews.
rounds × hours saved per round × hourly cost
Empty sites
Fewer sites that enroll nobody
A claim that fails against the record stops a site becoming primary, unless a person decides otherwise.
rounds × sites × drop in zero-enrolling share × cost per site
Trial days
A faster list, if it is on the critical path
Only days that move first patient in count. Most teams should discount hard.
rounds × days saved × share on the critical path × daily trial cost
Plan quality
A better network
Testing a country move before anyone commits can move last patient in, as the fictional Brazil case shows.
forecast date, with and without the change, tracked against the actual
Amendments
Re-runs that happen
An amendment recounts pools and re-scores sites in minutes in the example, where a spreadsheet often goes unchanged.
amended studies re-run; hours per re-run
Audit
Reasons you can find
Each decision with its sources, signer and history, ready for a successor or an inspector.
hours spent assembling support for a site selection question
Rounds a year, sites per round and your cost of an empty site
Few published benchmarks exist for these inputs. Every default marked illustrative is an assumption; use your own.
Your volumeHoursSites that enroll nobodyTrial days, shown separatelyYour cost
Illustrative yearly value
Team hours released, valued$0
Empty sites avoided, valued$0
Empty sites avoided a year0
After your yearly cost$0
Not in that total: trial days on the critical path, valued$0
Formulas, per year: Team hours = rounds × (hours today − hours after) × hourly cost Empty sites = rounds × sites × (share today − share after) ÷ 100 × cost per site After your cost = team hours + empty sites − yearly cost Trial days = rounds × (days today − days after) × share on the critical path ÷ 100 × daily cost
Not counted: lost sales, the value of a better network, audit hours, or fewer unusable questionnaires. Released hours are value only when you decide what they are for. If feasibility is not on your critical path, set the share to 0.
The cost of an empty site, more than hours, decides whether the tool pays
Yearly value of hours and empty sites at the defaults, by cost to open and close one site
At $80,000 a site$1.3M
At $40,000 a site$694.8K
At $20,000 a site$406.8K
At $0, hours alone$118.8K
Illustrative · replace with your own numbers · 6 rounds, 60 sites a round, 11% falling to 7%, 180 hours saved at $110. Your own numbers will differ.
Show the numbers
Cost per empty site
Yearly value before tool cost
At $80,000 a site
$1.3M
At $40,000 a site
$694.8K
At $20,000 a site
$406.8K
At $0, hours alone
$118.8K
A sponsor running one or two studies a year probably cannot justify software on hours alone. For that sponsor, a CRO service or a disciplined spreadsheet with claims checked by hand may be the right answer.
Start here19 · Readiness check
How ready your feasibility team is: studies a year, site history, rules and who signs
In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Feasibility rounds a year
How many country and site feasibility rounds do you run in a year?
Why it mattersVolume turns hours per round into team capacity.
A strong answer"About eight, across three therapeutic areas."
2
Your site history
Can you export enrolled against planned, months recruiting, screened and start-up weeks, by site and study?
Why it mattersYour own record is the strongest evidence you hold, and E6(R3) points to retrospective data.3
A strong answer"All of it, from our CTMS, for the last eight years."
3
Your baseline
Do you know your zero-enrolling share, your forecast error and the hours a round takes?
Why it mattersPublished benchmarks are old or thin. Your baseline is the only way to prove an improvement.
A strong answer"9% zero-enrolling, about three months' forecast error at first patient in."
4
Returned questionnaires
Are past questionnaires findable, by study and site, in a form software can read?
Why it mattersA claim check needs the original answers, including the PDFs and emails.
A strong answer"In one portal since 2022, with PDFs for the rest."
5
Patient counts
Do you license real-world counts, by country and criterion, that you can use for this?
Why it mattersA pool estimate needs a source and a data cut. Check your license allows this use.
A strong answer"Licensed for 12 of our usual countries, refreshed quarterly."
6
Written selection rules
Are your site selection weights and approvers written down, or held in habit?
Why it mattersWritten rules become settings. Unwritten ones become arguments.
A strong answer"A one-page rule, by study type, with named approvers."
7
Owner and budget
Is there a named owner of feasibility, with a budget to change how it is done?
Why it mattersThe work crosses feasibility, clinical operations, country teams, CROs and IT. Without one owner it stalls.
A strong answer"Our head of clinical operations sponsors it, and CRO budget can move."
8
Quality and AI approval
Do you have a way to approve AI in clinical operations: supplier assessment, a view on FDA's draft, human sign-off and an audit trail?
Why it mattersFDA's draft does not address operational uses with no effect on safety, quality or study reliability, and your quality unit decides how you show that.44
A strong answer"Quality and IT have a path, and every list needs a named signer."
9
The next hard question · for reflection
If your study lead asked in a meeting tomorrow what opening one more country would do to last patient in, what would have to be true for you to answer before the meeting ended?
Why it mattersYour answer lists the gaps. Each gap is a candidate job for software, or for a better spreadsheet.
A strong answerA short, specific list, for example: "each site's rate and open date in one place, and approval days by country that someone keeps current."
A low score means starting with a claim check by hand
0–6
Explore
Build the baseline first: count your zero-enrolling sites, compare claims with history on one finished round, and write down your weights. Start narrow, by hand if you need to.
7–11
Ready to pilot
Replay a finished study: give a tool the protocol, the questionnaires as returned and the history as it stood. Compare its ranking with what those sites did. Then run alongside a live round, with your people signing as usual.
12–16
Ready to implement
Plan the portfolio: your weights and rules as settings, your history and questionnaires loaded, links to your trial management system and trial master file, and the evidence your quality unit will ask for.
The total can flatter. A 0 on owner and budget, or on quality and AI approval, holds you at a pilot whatever else you scored, because either one can stop a rollout alone.
20 · Questions for any vendor
What to ask feasibility software or a CRO about rankings, citations, claims and forecasts
In shortAsk every vendor the same questions, us included. The answers show whose data decides the ranking, how each reason traces back, how a claim gets checked, how a forecast range is built, who decides, and how you could measure all of it on your own finished studies.
Ask
A good answer
A warning sign
Your data and theirs
Does my own site history drive the ranking, or a benchmark pool?
Your history first, benchmarks shown separately and labeled
A score from a pool you cannot inspect
What happens with a site that has no history with us?
A stated rule: neutral, with the claim discounted, and marked
Scored zero, or scored silently
Is patient-level data used anywhere?
Counts only, a minimum cell size, and the data cut shown
"We have access to records"
Reasons
Can every sentence in a rationale be opened at its source?
Question number, CTMS row or registry entry, one click away
A confidence score in place of a source
Can we change the weights, and see what that does?
Yes, on screen, with changes on an audit trail
"The model decides"
How does it treat a study in a different population?
Shown and not counted, with the reason
Competition counted by disease name
Forecast
How is the range built, and what is simulated?
Named method, each site's rate and open date, and how the range was checked on finished studies
A single date, or a range from an unnamed model
Does it use real approval clocks by country?
Yes, dated and editable, including contract and ethics time
One global start-up assumption
People and record
Who decides each site, and is that recorded separately from the software's proposal?
Named people, both on the record
Any user can accept a list
Which controls support our Part 11 and Annex 11 obligations, and what validation evidence will you share?
A control-by-control answer, and clarity that compliance is yours
"Certified Part 11 compliant"
AI and proof
Which AI models do you use, where do they run, and does our data train them?
Named models, a region you choose, no training on your data, in writing
"Proprietary AI", no more detail
Can we replay a finished study of ours before we sign?
Yes, using evidence as it stood at the time
Demo data only
What will you report from that test?
Enrollment by rank band, claims caught, citation accuracy on a sample, forecast range against actual
One accuracy percentage
We found no published independent test of any feasibility vendor's rankings, as of November 2026. A replay on your own finished study is the fairest comparison, and the same test measures your current process.
21 · How to start
Replay a finished study first, then run beside a live feasibility round and decide on three numbers
In shortMeasure first, then give the tool a finished study with the evidence as it stood, then run alongside a live round. Decide with three numbers: how well the ranking predicted enrollment, how many claims were caught, and team hours to a signed list. None of these steps commits you to a vendor.
Check claims by hand on one finished round: claim divided by screened, for every site. You will learn something whichever way you go.
Count your baseline from the last five studies: zero-enrolling share, share under half of plan, forecast error.
Choose two finished studies with their protocols, returned questionnaires and history as it stood before the study started, and an approval path to share them.
Run alongside a live round for one full cycle, with your country managers reviewing and your lead signing as usual.
Decide with three numbers: enrollment by rank band, claims caught against claims missed, and team hours to a signed list.
A twelve-week pilot ends with a decision on three numbers
Your teamVendor
Check claims on one round; count the baseline
Choose two finished studies; agree access
Load history, questionnaires and rules
Replay the finished studies
Score against what the sites did
Run alongside a live round
Decide
Week 036912
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Check claims on one round; count the baseline
0
2
Choose two finished studies; agree access
1
3
Load history, questionnaires and rules
2
4
Replay the finished studies
3
6
Score against what the sites did
5
7
Run alongside a live round
6
11
Decide
11
12
Rank-band enrollment, claims caught and citation accuracy on your studies
Measure
How
Why
Enrollment by rank band
Rank a finished study from evidence as it stood; compare actual enrollment per site across the four quarters
The only test of judgment. A flat result means the ranking adds nothing
Match with the list you signed
Share of your signed primary sites the tool also proposed, then study the disagreements
Near 100% means it copies you. The disagreements are the value
Claims caught
Build a labeled set by hand once; count what was flagged, and what was flagged and explainable
Decides whether the team keeps reading flags
Citation accuracy
300 random sentences opened against their sources
If none of 300 is wrong, the true error rate is very likely below about 1%
Forecast range coverage
Did actual enrollment stay inside the P10 to P90 range, month by month?
A range that misses is worse than none
Team hours to a signed list
Timer on the live round, against your baseline. The design target is 11 calendar days
The cost case rests on it
The working-session questions: 15 questions in five groups
Bring feasibility, clinical operations, country managers, the medical lead, CRO partners, quality and IT into one room. Each question says why it matters, what a strong answer looks like, and the warning sign.
A
Rounds, sites and countries a year
A1
How many rounds did we run last year, with how many sites asked and how many returned?
Why it mattersIt sizes everything else.
Strong answer · warning sign
Counts by study.
"The CRO would know."
A2
Which disease areas are most crowded for us?
Why it mattersRates and competition vary widely between areas.
Strong answer · warning sign
Named, with our rates.
One global rate.
A3
What is out of scope at first?
Why it mattersRare diseases or first-in-human work may wait.
Strong answer · warning sign
A clear exclusion list.
"Everything, day one."
B
Site history, questionnaires and counts on file
B1
Who holds our site history, including studies run by CROs?
Why it mattersA partner's study can be your best evidence.
Strong answer · warning sign
Named, with export rights in the contract.
"They own it."
B2
How much history is usable, and how far back should it count?
Why it mattersA site's staff change, and old rates mislead.
Strong answer · warning sign
A stated window, by study type.
All of it, equally.
B3
Does our patient-count license allow this use?
Why it mattersA late answer here stalls a pilot.
Strong answer · warning sign
Confirmed in writing.
Nobody has read it.
C
Weights, tiers and what a person always decides
C1
What are our default weights, and who may change them for a study?
Why it mattersWeights are a policy decision.
Strong answer · warning sign
Written, with a named owner.
Each lead's own spreadsheet.
C2
How do we treat new sites and underserved communities?
Why it mattersA history-led ranking favors sites you already know.
Strong answer · warning sign
A stated rule and a share reserved.
"The score handles it."
C3
Which steps would we never let software do without a person?
Why it mattersIt tells you where the signatures belong.
Quality unit, supplier assessment and an AI position
D1
Does our quality unit consider this tool GxP-relevant (covered by regulated good-practice rules), and what evidence will it need?
Why it mattersEvidence takes time to gather, so ask before the pilot is dated.
Strong answer · warning sign
A risk assessment under way.
First time anyone has asked.
D2
What is our position on FDA's AI draft?
Why it mattersIt may change; a written position lets you update it.44
Strong answer · warning sign
A short memo with an owner.
None.
D3
Where does the signed list live, and for how long?
Why it mattersSite selection records are essential records under E6(R3).3
Strong answer · warning sign
A named trial master file zone.
"On the shared drive."
E
A forecast in the meeting, every reason on file
E1
What would change if a country move could be tested in the meeting?
Why it mattersIt tests the appetite for live planning.
Strong answer · warning sign
"We would stop arguing from memory."
"We'd still decide offline."
E2
What could we tell sites who were not selected?
Why it mattersA reason helps a site improve, and builds goodwill.
Strong answer · warning sign
A short, honest reason.
Silence.
E3
Who hears first when the forecast slips past its target?
Why it mattersEscalation rules are decisions, and they become settings.
Strong answer · warning sign
The study lead, automatically.
"They'd find out."
22 · Frequently asked questions
Clinical trial feasibility questions answered: site selection, questionnaires, forecasts and AI
In shortThe questions clinical operations teams and buyers search for most, each answered on its own.
What is clinical trial feasibility?
Clinical trial feasibility is the work of deciding whether a study can be run as designed, and where. The company running the trial (the sponsor), or a contract research organization (CRO) it hires, estimates eligible patients by country, checks approval timelines and competing studies, assesses sites, and forecasts when enrollment will finish. The output is a list of countries and sites, a number of participants at each, and a date range.
What is the difference between country feasibility and site feasibility?
Country feasibility asks which countries can supply eligible patients in time, given their approval paths and standard of care. Site feasibility asks which investigators within those countries can recruit and run the study well. Teams usually do country work first, then site work, and go back when a site list reveals a country is weaker than it looked.
What is a feasibility questionnaire in clinical research?
A feasibility questionnaire is a form a trial's sponsor or its contract research organization sends to a potential site, asking about its patients, staff, equipment, timelines and competing studies. These forms can run from 10 to 40 pages, and sites often answer without pay. The American Society of Clinical Oncology has recommended fewer, standard questions and a shared portal, because current assessments are costly and of uncertain effectiveness.
What are the criteria for clinical trial site selection?
No rule sets a list. Teams commonly weigh past enrollment on similar studies, eligible patients, start-up speed, nearby competing trials, questionnaire quality, equipment, staff and the communities a site serves. ICH E6(R3) asks that each investigator be qualified, demonstrate adequate resources, and show recruiting potential from retrospective or currently available data.
What does ICH E6(R3) say about selecting investigators?
Section 3.7.1 of ICH E6(R3), the international good clinical practice guideline, makes the sponsor responsible for selecting investigators and institutions, each of whom should be qualified and demonstrate adequate resources and facilities. Section 2.2.1 asks the investigator to demonstrate recruiting potential, for example from retrospective or currently available data. E6(R3) took effect in the EU on July 23, 2025, and FDA published it as final guidance in September 2025.
How many clinical trial sites never enroll a patient?
A Tufts CSDD report published in 2012, covering 151 Phase II and III trials and nearly 16,000 sites, found 48% of sites fell short of target, including the 11% of ready sites that enrolled no one. The share of non-enrolling sites ranged from 7% in Western Europe to 20% in Latin America. It is an older figure, so count your own from your trial management system.
Is it true that 80% of clinical trials miss their enrollment timeline?
The 80% figure is widely repeated, including by the Association of Clinical Research Professionals, whose footnote points to a trade article. We found no study behind it, so treat it as the field's view of itself. A peer-reviewed figure measures something narrower: 19.3% of 1,197 National Cancer Institute-affiliated trials failed on low accrual.
How much does a day of clinical trial delay cost?
The Tufts Center for the Study of Drug Development (Tufts CSDD) puts direct trial cost at about $40,000 a day across Phase II and III, and $55,716 in Phase III. Lost sales are about $500,000 a day in its journal article and about $800,000 in its later white paper, both from 645 marketed drugs. Keep the two apart: one is being spent, and the other depends on reaching the market.
How do you forecast clinical trial enrollment?
Add each site's expected rate from the date it opens, then simulate the uncertainty and report a range, such as P10, P50 and P90 for last patient in. The published statistical method is a Poisson-gamma model of arrivals at each center. A single date hides the late tail, so ask what would pull the cautious end forward.
How do competing trials affect site enrollment?
They share a limited group of willing, eligible patients. In inflammatory bowel disease, active Phase 2 and 3 industry trials rose from 32 to 79 between 2011 and 2018, and average Crohn's recruitment fell to about 0.1 patients per site per month by 2018. Count only studies in the same population, within a distance you set, and date each registry read.
How long does clinical trial approval take in Brazil?
Law 14,874/2024 gives Anvisa, Brazil's health regulator, 90 business days on primary petitions, and development may begin if it has not answered, provided ethics approval is in place. Ethics committees have 10 working days to check the documents, then 30 business days from accepting them, and applications may go in parallel. The country is moving to a new national ethics system under Decree 12,651 of October 2025, so check current practice.
Can AI choose clinical trial sites?
AI can read questionnaires, compare claims with history, match registry studies, draft cited rationales and propose a ranking quickly. The sponsor stays responsible for the choice under ICH E6(R3), so a named person should decide and sign. We found no independent test of any vendor's rankings, so replay a finished study of your own before relying on one.
Does FDA's AI guidance apply to feasibility software?
FDA's January 2025 draft does not address AI used for operational efficiencies, such as internal workflows and resource allocation, when that use does not affect patient safety, drug quality or the reliability of study results. It is a draft, and FDA encourages sponsors who are unsure to engage early. Your quality unit should write down its own view.
Is feasibility software Part 11 compliant?
No software can be certified as compliant with 21 CFR Part 11 or EU Annex 11, because compliance depends on how a company validates and uses the system. Look for controls that support your compliance: signatures recording name, date, time and meaning, audit trails, and validation evidence you can review. If a vendor says "certified compliant", ask what it means.
23 · One-page summary
Choosing countries and sites on one page: the method, the November 2026 rules, readiness and terms
Print this page
In shortThe whole guide on one screen: the method, the rules as of November 2026, the readiness scale and the terms.
The method
Copy the entry criteria word for word, with their sections.
Build each country's pool as a funnel, and show the data cut.
Date each registry read; count only same-population studies.
Compare each claim with what the site screened.
Score on weights you can see and argue with.
Forecast from each site's own rate and open date, as a range.
A named person decides; write the reason; sign; file.
Re-run when the protocol changes, before anything moves.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of November 2026: E6(R3) in effect in the EU since July 23, 2025; FDA final September 2025; Annex 2 in the EU January 15, 2027 · UK rules since April 28, 2026: 7 days, then 30 · Brazil: Anvisa 90 business days · EU Biotech Act still a proposal · FDA Diversity Action Plans and AI guidance still drafts · Annex 22 still a draft, and a GMP text.
14 terms
Sponsor
The company responsible for a trial.
CRO
Contract research organization, hired to run parts of a trial.
Site · investigator
The hospital or clinic, and the doctor responsible for the trial there.
Protocol synopsis
A short version of the study plan, with its entry criteria.
CTMS
Clinical trial management system: a sponsor's record of sites and enrollment.
Feasibility questionnaire
The form a sponsor sends to a site about its patients and capacity.
Screen failure
Someone assessed for a study who turns out not to qualify.
Zero-enrolling site
A site opened for a study that enrolls nobody.
Lead · core · back-up
Tiers for how much of a study a country carries.
First and last patient in
When the first and final participants join.
P10 · P50 · P90
Dates by which 10%, 50% and 90% of simulated futures finished enrolling.
Trial master file
The set of essential records for a trial.
Competing trial
A study recruiting the same population nearby.
Signature with meaning
A signed record showing name, date, time and what the signature means.
24 · Sources
Sources
Accessed November 2026. Regulatory status statements are as of November 2026.
Association of Clinical Research Professionals, "Fixing Feasibility: Collaborative Approaches for Redefining and Improving Site Selection", March 21, 2024 (its 70%, 80% and 45% footnote a trade article in Clinical Leader). acrpnet.org
Ken Getz, "Enrollment Performance: Weighing the Facts", Applied Clinical Trials, May 1, 2012, on the Tufts CSDD study of 151 global Phase II and III trials, 2008 to 2010, and nearly 16,000 sites. appliedclinicaltrialsonline.com
ICH, E6(R3) Guideline for Good Clinical Practice, Step 4, January 6, 2025: sections 2.2, 3.6, 3.7, 3.9.5, principles 9.4 and 9.5, Appendix C. database.ich.org
"Growth in eligibility criteria content and failure to accrue among National Cancer Institute (NCI)-affiliated clinical trials", Cancer Medicine 12(4):4715-4724, 2023. pmc.ncbi.nlm.nih.gov
Bouhnik, Louis, Peyrin-Biroulet, letter in Gastroenterology 158(8), 2020, reporting Harris et al. (Gastroenterology 158(1)) on recruitment rates 1998 to 2018; reproduced under CC BY 4.0. reproduction, PDF
42 CFR 11.64, When must clinical trial registration and results information be updated. law.cornell.edu
Ed Miseta, "Why Is Study Start-Up Still So Inefficient?", Clinical Leader, May 30, 2017, on the Tufts CSDD follow-up study. clinicalleader.com
European Medicines Agency, ICH E6 good clinical practice scientific guideline page: principles and Annex 1 in effect July 23, 2025; Annex 2 adopted June 3 and June 25, 2026, in effect January 15, 2027. ema.europa.eu
FDA, E6(R3) Good Clinical Practice, final guidance, September 2025, docket FDA-2023-D-1955. fda.gov
Jones Day, "UK Clinical Trials Enter a New Regulatory Era", May 2026. jonesday.com
NIAID ClinRegs, Brazil country profile: Law 14,874, Decree 12,651, RDC 945, ethics timelines, parallel submission. clinregs.niaid.nih.gov
European Medicines Agency, Clinical trials in human medicines: every ongoing trial under the Regulation as of January 31, 2025. ema.europa.eu
European Medicines Agency, ICH M11 guideline, Step 5: ICH adoption November 19, 2025; CHMP December 11, 2025; in effect June 11, 2026. ema.europa.eu
21 CFR 312.53, Selecting investigators and monitors (Legal Information Institute copy; we did not read the eCFR itself). law.cornell.edu
AEMPS (Spanish Agency of Medicines), Information on CTIS and Clinical Trials Regulation (EU) 536/2014: Part I and Part II, 60 to 106 days (stated in its note on transition). aemps.gob.es
FDA, draft guidance, Diversity Action Plans to Improve Enrollment of Participants from Underrepresented Populations in Clinical Studies, June 2024, docket FDA-2021-D-0789; page carries a court-ordered restoration notice. fda.gov
IntuitionLabs, "Clinical trial diversity statistics", updated August 1, 2026 (analyst report; states final guidance not issued as of July 2026). intuitionlabs.ai
21 CFR 312.40, General requirements for use of an investigational new drug in a clinical investigation. law.cornell.edu
Health Canada, Guidance Document for Clinical Trial Sponsors: Clinical Trial Applications, revised March 17, 2016. canada.ca
The Medicines for Human Use (Clinical Trials) (Amendment) Regulations 2025, SI 2025/538, regulations 16(8) and 18(4), made April 28, 2025, in force April 28, 2026; a consulted committee can add 90 days (18(7)). legislation.gov.uk
Health Research Authority, "The way we measure and report on Combined Review is changing", updated April 30, 2026: 107-day maximum, 7-day validation, 60-day response to a request for information. hra.nhs.uk
PMDA, "Check List for 30-day-Clinical Trial Notification Review on an Initial Clinical Trial Notification (Oncology Drugs)", December 10, 2024 (pmda.go.jp); Article 80-2(3) of Japan's law as set out in a PMDA reviewer's slides, "Clinical trial notifications and scientific consultation system in Japan" (presenter's views). pmda.go.jp
Freyr, "South Korea IND Application: A Step-by-Step Overview", August 19, 2025 (consultancy summary of the MFDS review period; the same page says complex dossiers may take 2 to 3 months). freyrsolutions.com
Agência Senado, "Sancionadas regras para pesquisa clínica em ser humano", June 3, 2024, on Law 14,874/2024 (we did not read the law itself on the federal law site). senado.leg.br
TGA, presentation on the Australian clinical trial framework, published October 2026: 5 to 7 working days for CTN acknowledgement, no data evaluated at submission, 50 working days for CTA (we read excerpts, not the full presentation, because tga.gov.au would not open). tga.gov.au
IQVIA, "The EU Biotech Act, part 2", June 29, 2026: proposal summary and status. iqvia.com
ECRIN, "FAST-EU pilot initiative", February 10, 2026: Heads of Medicines Agencies, Clinical Trial Coordination Group and MedEthics EU; voluntary; 70 calendar days. ecrin.org
AGES (Austrian Agency for Health and Food Safety), FAST-EU update, May 20, 2026: 15 trials in progress, three procedures completed, 26 countries. ages.at
European Parliament, Legislative Observatory, procedure 2025/0406(COD), European Biotech Act, read November 3, 2026. oeil.europarl.europa.eu
Korea Economic Daily (Hankyung), March 14, 2025: newspaper survey of 112 listed biotech companies, Phase 1 to 3 applications, January 2023 to February 2025. hankyung.com
Money Today (Korea), July 2, 2026, on the Korean regulator MFDS's announcement: statutory period from 30 to 10 days for applications with a prior-review notice, planned for June the next year. mt.co.kr
European Commission, DG SANTE, "Update on Clinical trials/Biotech Act", June 2026, citing the Commission staff working document of May 26, 2026. accelerating-clinical-trials.europa.eu
Clifford Chance, "FAST-EU and French fast track: Europe's new 2026 strategy for accelerated clinical trial authorisations", February 2026. cliffordchance.com
The ASCO Post, "New Research Statement Recommends Streamlining and Standardizing Clinical Trial Site Feasibility Assessments", March 10, 2021, on the ASCO statement in JCO Oncology Practice 17:41-51. ascopost.com
Johnson, Barnes, Zhang, Long, "Trends and Characteristics of Clinical Trials Participation for Inflammatory Bowel Disease in the United States: A Report From IBD Partners", Crohn's & Colitis 360, 2020. pmc.ncbi.nlm.nih.gov
Mountain and Sherlock, "Recruitment prediction for multi-centre clinical trials based on a hierarchical Poisson-gamma model: asymptotic analysis and improved intervals", arXiv:1912.09790, revised February 12, 2021. arxiv.org
Labcorp, "Addressing challenges in ulcerative colitis clinical study recruitment", January 10, 2022 (CRO analysis of 34 Phase II and III industry studies). labcorp.com
Craig Morgan, "Molasses: Study Start-Up Efficiencies", Applied Clinical Trials, February 15, 2018, on a survey of 403 organizations with Tufts CSDD (the author worked at a software vendor). appliedclinicaltrialsonline.com
Tufts CSDD, "Protocol amendments improve elements of clinical trial feasibility but at high economic and cycle time cost", January 14, 2016 (Impact Report, January/February 2016). biospace.com
Getz, Smith, Botto, Murphy, Dauchy, "New Benchmarks on Protocol Amendment Practices, Trends and their Impact on Clinical Trial Performance", Therapeutic Innovation & Regulatory Science 58(3):539-548, 2024 (abstract). pubmed.ncbi.nlm.nih.gov
Smith, DiMasi, Getz, Tufts CSDD white paper, "Quantifying the Value of a Day of Delay in Drug Development", August 2024. csdd.tufts.edu
Smith, DiMasi, Getz, "New Estimates on the Cost of a Delay Day in Drug Development", Therapeutic Innovation & Regulatory Science 58(5):855-862, 2024 (abstract, pubmed.ncbi.nlm.nih.gov); Ken Getz, "How Much Does a Day of Delay in a Clinical Trial Really Cost?", Applied Clinical Trials, June 2024. appliedclinicaltrialsonline.com
FDA, draft guidance, "Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products", January 2025, docket FDA-2024-D-4689. fda.gov
European Medicines Agency, Artificial intelligence page: reflection paper adopted September 2024; joint FDA and EMA guiding principles published January 14, 2026. ema.europa.eu
National Law Review, "EU Digital Omnibus on AI Enters Into Force", on Regulation (EU) 2026/1744, published July 24, 2026, in force July 27, 2026 (we did not read the regulation itself on EUR-Lex). natlawreview.com
ISPE, GAMP Guide: Artificial Intelligence, July 2025. ispe.org
European Commission, EudraLex Volume 4, read November 3, 2026: Annex 11 at January 2011, no Annex 22. health.ec.europa.eu
PIC/S and European Commission, draft Annex 22: Artificial Intelligence, consultation July 7 to October 7, 2025. picscheme.org
FDA, Computer Software Assurance for Production and Quality Management System Software, final guidance, February 2026, superseding the version of September 24, 2025. fda.gov
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