NSF SBIR/STTR Oddities

Courtesy of SBIR Insider

First a disclaimer:  I like many of the people involved with the NSF SBIR/STTR programs, and I know they work hard and want to do a good job.  On the other hand, the agency itself has some rules of its own that seem to fly in the face of what the programs are supposed to, and how they are supposed to help.  Let’s investigate.

Oddity 1: Limit on Number of Proposals per Organization: 1

 

NSF only allows a small business to submit 1 proposal per solicitation, even though their solicitations are moderately large and contain very open topics.  Don’t take my word for it, here is the actual verbiage from their current solicitation:

 

An organization may submit no more than ONE Phase I proposal to this SBIR/STTR cycle (where SBIR/STTR cycle is defined to include the SBIR Phase I solicitation and the STTR Phase I solicitation with a December 5, 2016 deadline). This eligibility constraint will be strictly enforced. In the event that an organization exceeds this limit, the first proposal received will be accepted based on earliest date and time of proposal, and the remainder will be returned without review. No exceptions will be made.

 

On the other hand, NSF in their Q&A page at https://www.nsf.gov/pubs/2015/nsf15125/nsf15125.jsp#q11 their guidance (as of 10-19-16) is:

  1. May a small business submit two different Phase I proposals during the same submission cycle?
  2. While a small business may submit two Phase I proposals to the same deadline, applicants are encouraged to contact the appropriate NSF SBIR/STTR Program Director(s) before doing so. In general, it is preferred that proposing small businesses, especially those with limited resources, focus on submitting one strong proposal that best aligns with the commercial goals of their business and the NSF SBIR/STTR program goals.

 

Here’s where I will respectfully disagree (bordering on disrespectfully).  Why did NSF put a limit of TWO proposals per company (considered ridiculous by most of the SBIR community) THEN compound that with reducing it to ONE?  That’s unprecedented in SBIR/STTR, and congress is being told by some agencies that SBIR/STTR allocations should actually be reduced due to falling numbers of submissions!  Duh!!!!

 

Oddity 2:  Limit on Number of Proposals per PI or Co-PI: 1

 

NSF again is the only SBIR/STTR program that restricts a person functioning as a Principal Investigator (PI) to only ONE proposal per solicitation.  Let me know if you think I’m mistaken here, but this is an outrage!

 

For your consideration I present evidence in NSF’s own verbiage from their solicitation (see https://www.nsf.gov/pubs/2016/nsf16599/nsf16599.htm ):  “No person may be listed as the principal investigator for more than one proposal submitted to this solicitation.

 

Now let’s look at what NSF considers task loading for the PI: “A PI must devote a minimum of one calendar month per six months of performance to an SBIR or STTR Phase I project.”  Even if we double that, it still leaves plenty of time for the PI to do other projects (such as other SBIR/STTRs), which happens frequently in other agency SBIR/STTR programs.  Is the small business being forced to keep the PI on overhead, because the PI must be primarily employed by the small business (meaning at least 51%)?

 

Oddity 3: In STTR the PI Must be Primarily Employed by the Small Business

 

In STTR, four out of the five agencies allow (but not require) the PI to be from the Research Institution (RI).  In fact, the RI must have a minimum of 40% to a maximum of 60% of the research effort, but unlike the other agencies, NSF does not allow the PI to be primarily employed by the RI, they must be primarily employed by the small business.

 

This seems to be without merit, and further restricts flexibility for the small business to partner with the RI.  SBA had to amend their STTR Policy Directive to accommodate this NSF oddity.

 

In light of these and other NSF oddities, I’ve heard multiple third party assistance organizations advise their clients to bypass the NSF SBIR/STTR programs for other SBIR opportunities.  This is a shame because the NSF has some excellent people and resources to run a fine program.

 

Submissions are due by Dec 6, 2016.

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