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

What University of Iowa policies are the basis of these FAQs?

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.

Can a UI employee serve as the principal investigator (PI) on behalf of a small business SBIR/STTR applicant?

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.

Can a UI employee serve simultaneously as the principal investigator (PI) on behalf of a small business SBIR/STTR applicant and on the subcontract to the University?

No. SBIR and STTR funding mechanisms involve a primary grant to the small business concern and a sub-contract to the university. Thus there are two PIs; one is PI for the company; one is PI for the university. The University advises that the same individual may not serve as PI on both. For example, if you will serve as the company PI, then you may serve as a co-investigator on the University research, but you may not serve as the PI on the University research.

Having “co-PIs” is also problematic for some granting agencies. Listing a PI and a co-Investigator on the application is preferred.

Can I use University of Iowa resources to conduct SBIR-STTR research?

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

Can the small business percentage of the research be conducted at the University of Iowa?

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.).

As the UI PI for the subcontract, can I lead UI animal or human studies for the SBIR/STTR?

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.

Can University of Iowa units assist with the small business application process?

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.

Can my grad students or post docs work on my lab’s sub-contract, or on the company’s portion?

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.