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The clinical study partners should be partners= beneficiaries whenever possible, this is right; but in PHC12 only SME are eligible for funding. So you either can identify a for-profit CRO that is willing to act as beneficiary (as it is 100% funding rate this is not too bad), or they act as subcontractor. If you are or prefer working with non-profit CROs or with academic partners (university hospitals), they must be subcontracted for this topic. The commission is aware of the dilemma, but confident that the amount of subcontracting will not be a major hurdle for the applicants respectively the evaluation result. Note that in PHC12 like in any other SME instrument topic, the “impact” is even more important than in research & innovation actions, compared to “excellence”. This is: plan and write your project proposal in the best way for your company so that you will be able to become a champion in your market.