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SBIR/STTR Implementation

Purpose

Faculty participation in the Small Business Innovation Research (SBIR) or Small Business Technology Transfer (STTR) programs can create potential conflicts of interest - particularly when that faculty member, their spouse, or dependent children are founders or hold equity in the small business concern (SBC). 

This procedure is intended to guide faculty, as well as Deans & Chairs (or their designees), in evaluating these relationships and ensuring compliance with federal regulations and University policies related to conflicts of interest and conflicts of commitment.  

Applicability

  • Principal Investigators (PIs) involved in SBIR/STTR proposals or awards
  • Units responsible for reviewing and approving SBIR/STTR submissions

Instructions

1. Required Documentation for University Subrecipient Proposals
When the University will serve as a subrecipient to an SBC receiving SBIR/STTR funding, the PI or department must provide OSP with:

  • The complete University proposal and budget
  • The full proposal submitted by the SBC to the prime sponsor
  • Documentation confirming the SBC has a primary operating space outside the University of Utah
  • A completed SBIR/STTR Intake Form.

If any of the above items are not available at the proposal stage, OSP will require them before a subcontract with the SBC can be finalized. 

2. Conflict of Interest Requirements

  • Personal COI
    If any University project personnel (faculty, staff, students, fellows, contractors, consultants, etc.) have a financial interest in the SBC - such as equity, stock options, compensation arrangements, or intellectual property licensed to the SBC - they must consult with the COI office to determine whether a perceived, potential, or actual conflict exists.
  • Institutional COI
    Consult the COI office if the University holds a financial interest in the SBC (e.g., equity, royalties, or licensing payments).

3. Intellectual Property

Some SBIR/STTR solicitations require an agreement between the  SBC and the  University regarding intellectual property (IP) ownership and licensing prior to award.

If this applies:

4. Unit-Level Review for SBIR/STTR

Department Chairs, Institute Directors, or Center Directors (or designees) must review SBIR/STTR proposals to ensure:

  • University research facilities and resources are used only for the University's portion of the scope of work
  • Approval has been granted for any necessary use of University facilities 
  • Budgets reflect full cost recovery, including appropriate direct and indirect costs

5. Contracting

Once the SBC's proposal is awarded:

  • The SBC and OSP must negotiate and execute a subcontract to the University.
  • All SBIR/STTR proposals and subcontracts are reviewed and negotiated by OSP's industry contract team.

 

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Last Updated: 2/9/26