Guidelines for Participation of RFUMS Employees on SBIR and STTR Programs

A number of federal agencies are required by congress to set-aside funding to support research and development activities under the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Programs. These funds can be awarded only to small business as defined by federal regulation. See the following link for more information on the difference between the two programs: https://seed.nih.gov/small-business-funding

In some cases, RFUMS faculty and other employees may be approached by Small Business Concern (SBC) for scientific collaboration on SBIR or STTR-supported projects to advance the company’s development aims. In other instances, faculty, postdoctoral scholars, students or staff want to start companies and view SBIR and STTR grants as a good way to fund further research and development of intellectual property that they developed at RFUMS. Under both scenarios, RFUMS employees may be able to collaborate with a SBC on SBIR or STTR-supported projects. However, in order to manage Individual and Institutional Conflict of Interest as well as to protect the institution non profit tax exempt status, RFUMS requires that the following guidelines be observed before any involvement on STTR-SBIR projects:

1. RFUMS employee should not be the Principal Investigator for the SBC applicant without an exception from the Vice President for Research. This policy satisfies the SBIR eligibility requirements in that the PI of an SBIR award must be a >50% employee of the SBC, which means that a full-time regular RFUMS faculty is not eligible to be PI on a SBIR award. Even if a full time regular RFUMS faculty is permitted to serve as a PI under federal regulations (i.e. STTR) and with an exception from the VPR, the same individual may not simultaneously serve as the PI for the SBC and as the PI for work subcontracted to RFUMS
2. An RFUMS employee who has an ownership interest in an SBC, regardless of the monetary value, may not conduct or supervise research activities in his/her RFUMS laboratory through subcontracts on SBIR or STTR projects awarded to the SBC 
3. Plans for the subcontract proposed research to be conducted at RFUMS under SBIR or STTR programs must be reviewed by the appropriate Department Chair and School Dean before subcontract proposal materials are sent to OSR for processing and submission. See also instructions. Information needed for Subcontracts as part of another Institution’s Proposal. This will insure that:
   1. The proposed work has scientific merit
   2. The work constitutes a good use of RFUMS research facilities
   3. The subcontract is for a unique and specific scope of work distinct from research conducted at the SBC
   4. Budgets reflect full cost recovery (direct and indirect) for the portion of the research project to be conducted at RFUMS, including the subcontract PI’s time
   5. As required by the federal government an Intellectual Property Agreement must be executed by the SBC and RFUMS before the Just In Time Information process