Guidelines for SBIR/STTR
Common Conflict of Interest Issues When Participating in the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Program
The Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs are similar in that both programs seek to increase the participation of small businesses in Federal Research & Development (R&D) and to increase private sector commercialization of technology developed through Federal R&D. Under the SBIR and STTR programs, the federal government is an investor seeking to help a small business convert innovative technology into a marketable product.
While there are standard federal-wide requirements for the SBIR and STTR programs, each agency issues its own implementation guidelines and separate calls for proposals. The Office of Research Integrity works with investigators to ensure that the relevant agency’s COI requirements are met.
- 1. Who is the Principal Investigator (PI) for the start-up? Who is the GW PI?
A GW faculty member may not simultaneously serve as PI on behalf of GW and as a PI on the SBIR/STTR project for the start-up. The PI must also disclose whether any collaborators or key personnel also have an interest in the start-up.
- 2. If the GW PI (or his/her immediate family) has an ownership interest in the start-up has it been disclosed?
Disclosure to the Department Chair and the GW Annual COI Disclosure process is required if the faculty member is to receive sponsored support for research from a business for which the faculty member is a consultant, or in which the faculty member has a significant financial interest (GW Policy on Conflicts of Interest).
- 3. Research Staff/Students: Will students or post-docs participate in this research?
If the faculty member has an ownership interest in the start-up, any involvement of students or post-docs in this research should be approved in advance by the Department Chair and the student must acknowledge an understanding of the issues involved.
- 4. Facilities: What GW facilities will be used?
Ideally, GW facilities should not function as the start-up’s only facilities. Commonly, the start-up needs to use university facilities to work. There must be a facilities and resources agreement in place for the startup to conduct work using GW facilities and other resources. The company must take inventory. Does it have the research team it needs? Does it have the facilities, the equipment, the infrastructure? What gaps exist? Can they be filled to meet the requirements of an SBIR or STTR with university-based researchers or facilities? If so, then there should be a transparent process for proposing, approving, and using university staff and resources to benefit the company.