Small Business and SBIR/STTR Research Engagement Policy
Unit: Research and Economic Development
Contact: Russell Mumper, Ph.D.
Title: Vice President for Research and Economic Development
Effective Date: 06/01/2021
Revision Date: 02/22/2023
Purpose
The Office for Research & Economic Development (ORED) facilitates and cultivates research collaborations with The University of Alabama (UA) and private entities, which includes working directly with small businesses or Small Business Concerns (SBC). There are several mechanisms by which SBCs and UA engage to conduct research projects, including the use of federal funds, state funds, private funds, and philanthropic funds. This policy pertains to all funding mechanisms by which UA may engage with an SBC.The Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs supported by various federal agencies are intended to stimulate technical innovation and private sector commercialization of technology developed through federally-supported research and development. STTR programs are focused on the transfer of technology from the non-profit research institution to the small business and ultimately to the marketplace. This has been expanded over time to include situations where the innovation belongs to the small business, but the firm desires to include important resources from a nonprofit research institution in the technology’s development. ORED supports collaboration between private entities and UA while being responsive to both private interests and the need for federal, state and other compliance requirements. While SBIR and STTR activities are encouraged, collaboration by UA faculty with a Small Business Concern (SBC) can create potential conflicts of interest and/or conflicts of commitment. This policy provides members of the UA research community with ORED’s requirements to engage with SBCs through any funding mechanism.
Policy
- Prior to engaging in formal proposal preparation with an SBC, the Lead Principal Investigator (PI) at UA must receive approval from their Dean and Associate Dean for Research (ADR) to proceed with engagement with the SBC leading to a research agreement to be funded by any funding mechanism.
- With respect to the SBIR and STTR mechanism, and as defined by federal regulations, SBIR and STTR proposals can only be submitted by and awarded to an SBC. STTR projects require the small business to formally collaborate with a non-profit research institution or Federal Laboratory.
- Plans for proposed research to be conducted at UA by an SBC, or under SBIR or STTR programs, must be reviewed and approved in accordance with the Proposal Routing, Review and Approval Policy for Externally Sponsored Grants & Contracts. The SBC shall provide the PI and the Office for Sponsored Programs (OSP) at UA with a copy of the full proposal or other appropriate information for the Dean, ADR and OSP to evaluate the following criteria as part of the internal review:
- The proposed scope of work has scientific merit and there is no inappropriate overlap with the UA employee’s other research efforts.
- The work constitutes reasonable use of UA research personnel and facilities, which are solely dedicated for UA’s portion of the project. Personnel and facilities, including office and lab space cannot be used by the SBC without approval from the Department Chair/Head (if applicable), College Dean, and Vice President for Research, and only after entering into appropriate contractual agreements, such as a facilities use agreement, with UA. Approval will be influenced by factors such as whether the request diverts resources to the SBC at the expense of UA, students, staff, or faculty.
- The work does not compromise the UA employee’s primary responsibilities.
- Budgets shall include full recovery of direct and indirect costs for the portion of the research project to be conducted at UA.
- The SBC is responsible for all grant administration related to the prime award.
- Participation with an SBC or in SBIR or STTR programs must observe the following principles:
- Any employee seeking to serve as the PI for the SBC must be eligible according to the requirements under the federal agencies’ SBIR and STTR programs. Eligibility requirements vary by program and agency (e.g., some do not allow full time UA employees to serve as PI). Please review all eligibility rules carefully.
- All work performed for, or in connection with, any small business using UA facilities, equipment, materials, employees or students must be under an approved subcontract or other binding agreement.
- As with any externally sponsored project, all personnel listed on the UA portion of the proposal must comply with the Conflict of Interest/Financial Disclosure in Research and Other Sponsored Programs Policy and consult with the Office for Research Compliance to determine if any perceived, potential or actual conflicts with the SBC exist.
- In most cases, the PI for a small business and the UA PI must be separate individuals; direct employment or academic reporting relationships within UA may be subject to review by the University Conflict of Interest Committee (e.g., no UA student or staff member may perform research related to UA’s portion of a small business’ SBIR/STTR award, and concurrently serve as an employee or intern of that small business).
- Intellectual Property – SBC and SBIR/STTR proposals may require that the SBC and UA agree to terms on ownership and licensing of intellectual property before the sponsor issues its award to the SBC. If so, the UA Lead PI must contact OSP as soon as possible to begin that process, as the negotiation may take time and requires input from the Office for Innovation and Commercialization.