University of Iowa

SBIR-STTR Frequently Asked Questions about Conflict of Interest and Commitment

Best Practice FAQs

Below is a list of frequently asked questions our office receives when investigators and start-ups are preparing SBIR or STTR applications. Please contact our office if you have additional questions.

The University of Iowa community is committed to the principle of free, open, and objective inquiry in the conduct of its teaching, research, and service missions. Further, The University of Iowa encourages its employees to engage in external activities that promote the University's mission, contribute to their professional fields, enhance their professional skills, and/or enhance the public good. However, the University also expects its employees to fulfill their University obligations first and foremost commensurate with their appointment requirements. To ensure that external activities are conducted in a manner consistent with institutional and public values, the following policy conveys expectations and procedures to ensure that University employees avoid improper conflicts whenever possible, or otherwise disclose activities for review and management.

Chapter 18, Section II of the University Operations Manual addresses conflicts of interest in research, conflict of commitment (effort), and other pertinent conflicts of interest policies. Other policies may also be applicable, such as Use of University Name, Nepotism, and Purchasing. These other potentially relevant policies are listed at the bottom on Chapter 18.

Although STTRS/SBIRs are indeed collaborations, the respective funding agencies’ STTR/SBIR policies, instructions, and project percentage requirements/effort make clear that establishing a separation of entities and roles is important.  The company and collaborating research institution are referred to as separate parties. Having the same person on both sides of the collaboration blurs the respective parties’ project % and effort % requirements/commitments.

Use of University of Iowa resources is prohibited except as specified in an approved sponsored research agreement (subcontract).

Although the company can conduct research at the University under an approved sponsored research agreement in which UI is a subaward recipient from the company, the company may not use University facilities for the conduct of the company’s business or activities on the primary award or any other company-related activities (e.g., employee benefits, payroll, facilities, equipment, etc.).

Yes, so long as it falls within the scope of the executed subcontract. The associated expenses should be factored into the original budget submitted by the company to the funding agency.

Several UI units are available to assist only with the UI subcontract portion of an SBIR/STTR application. These units cannot, however, assist the company with the overall process. UI Ventures is available to provide guidance to the small business concern’s global application process.

As with the PI scenario, students and trainees may only work in one role or the other for the research. If they are working for the company, it should be disclosed in the eCOI system. As an employee of the company, they would not be allowed to participate in research under the same grant that is subcontracted to the University.