SBIR and STTR: Federal Small Business Awards

Conflict of Interest Guidance for SBIR/STTR Projects

The Small Business Technology Transfer (STTR) and Small Business Innovation Research (SBIR) programs are both U.S. Federal government initiatives that provide funding to start-up and small companies to conduct research and development (R&D) using a three-phase approach. The information on this page provides a high level overview of the U.S Federal requirements and corresponding Penn State policies that govern participation by University personnel in the SBIR program (RA06) and the STTR program (RA07).

IMPORTANT: You must disclose your financial interest in the small business in COINS per the University’s Conflict of Interest Policy prior to applying for an SBIR or STTR.

Key Differences

Note: “Immediate family member” is defined as a spouse, domestic partner, or dependent children.

  Small Business Innovation Research (SBIR) Small Business Technology Transfer (STTR)

Principal Investigator (PI)

Small Business Prime Award

 

You cannot serve as PI and be employed full-time at the University.

SBIR regulations require PIs to be primarily employed by the small business at the time of the award and cannot be employed anywhere else during the project period.

 

You cannot serve as PI and be employed full-time at the University.

Penn State policy RA07 says that a full-time (at least 51%) employee of the University cannot be a PI for the small business.

Principal Investigator (PI) or Co-Principal Investigator (Co-PI)

University Sub-Contract

If you own or have ownership in the small business, or your immediate family has ownership interest, you cannot participate in the research subcontract at the University per Penn State policy RA06.*

In addition, you cannot serve as PI on the research sub-contract if your immediate family member is PI on the small business prime award.

*Contact COI program staff at coinsadmin@psu.edu to discuss your specific situation.

If you own or have ownership in the small business, or your immediate family has ownership interest, it is possible to participate in the research subcontract at the University per Penn State policy RA07 as long as you have:

  • A Co-PI who does not have a financial interest in the small business and who does not report to you
  • An approved management plan prior to participation

Be sure to contact COI program staff at coinsadmin@psu.edu prior to applying for the STTR.

NOTE: If your immediate family member is PI on the small business prime award, you cannot serve as PI on the University sub-contract.

 

Involvement of Penn State Personnel and Resources on a Penn State Sub-Contract funded by the Small Business

  • Position Limitations: University Personnel must seek prior approval per policy AC80 before holding any management or officer positions, positions on the Board of Directors, or undertaking responsibilities with the small business receiving the SBIR/STTR grant.
  • Use of University Resources: All work performed for or in connection with any small business using University facilities, equipment, materials, employees, and/or students related to an SBIR must be performed under a fully negotiated and executed sponsored research agreement or another approved agreement.
  • Compensation: University Personnel compensated under an SBIR/STTR subcontract cannot receive compensation for the same SBIR/STTR-funded research from the small business.
  • Student and Staff Restrictions: Students, staff, or Visiting Scholars cannot work on the University subcontract and be employed or be an intern at the small business.