Hi Collette –
You may want to check out
NIH Policy Statement 18.5.2.4 which deals in who the PI may/must be and what affiliation they must have with the SBC, depending on whether the application relates to an SBIR or STTR.
There’s also the COI question. The FCOI obligation does not apply to Phase I SBIR/STTR applicants (See
Source here), but does apply to Phase II and III, and institutions certainly may apply their own COI policies even to Phase I submissions to make it difficult, if not impossible for the PI to
wear both the hat of PI at the SBC and PI at the institution.
Also, some institutions may have internal policies that preclude faculty from serving as PI/key personnel on awards to parties other than their institution, at least to the extent such awards overlap with their institutional
research.
In my experience, it’s been difficult, if not impossible for the faculty member to wear both hats. We have had situations in which a faculty member has had a start-up and has received an SBIR, but a partner at the start-up
serves as the Project Director (or “SBC PI”) and any COI with regard to the subcontracting to Yale is then managed. Not easy, but do-able.
Cheers,
James
James Cresswell, JD
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From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
On Behalf Of Collette L. Ryder
Sent: Friday, August 19, 2022 10:08 AM
To: Research Administration Discussion List <xxxxxx@lists.healthresearch.org>
Subject: [RESADM-L] PI at SBIR/PI at university
Good morning, all.
Can anyone point us to a regulation/rule for NIH SBIRs which points to whether the PI at a spun off company is or is not able to subaward part of their own SBIR award to themselves at their University?
In other words, can the individual be PI on both segments?
Thanks.
Collette
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