Guidelines for LSU Employee Participation in SBIR & STTR Grant Programs

The federal Small Business Innovation Research (SBIR) and Small Business Technology Transfer Research (STTR) grant programs encourage the engagement of Small Business Concerns (SBC) in federal research and development. LSU is not eligible to directly receive SBIR/STTR funding, but because collaborations between SBCs and research institutions are encouraged by the SBIR program and required by the STTR program, SBCs regularly seek LSU researchers to participate in their projects as a subcontractor. LSU researchers may also want to start or grow their own SBC and consider SBIR/STTR funding for the establishment and/or future development of their SBC.

Compliance with University Regulations

In all cases, LSU researchers may collaborate with SBCs on SBIR/STTR funded projects. However, all activities undertaken by LSU employees associated with the SBIR or STTR funding programs must comply with LSU Bylaws and Regulations, Permanent Memoranda, and internal policies, including (but not limited to):

• PM-11 – “Outside Employment of University Employees”
• PM-67 – “Contracts between the University and its Faculty Members”
• PS-98 – “Disclosure of Financial Interests” 

General Requirements

In general, the LSU Principal Investigator on any subcontract from an SBC and the SBC’s Principal Investigator cannot be the same individual due to the conflict of interest that would result from such an arrangement. A clear distinction must be made between the work performed by the LSU Personnel conducting the research under the subcontract and the work performed by the SBC employees without LSU Personnel involvement. .

SBCs may not use any LSU resources (for example, space, facilities, instruments or equipment, or human resources) to carry out their portion of the work unless:

• The SBC utilizes a LSU recharge facility or service; and/or
• The SBC leases space in a LSU-owned/operated incubator (such as Louisiana Business and Technology Center or the Louisiana Emerging Technology Center).

Engagement, Approval, and Submission of SBIR & STTR Proposals

When an SBC initiates contact with an LSU Principal Investigator to discuss the potential for a proposal, it may be necessary to establish a confidentiality agreement, which is handled by LSU’s Office of Innovation & Technology Commercialization (ITC). Once the SBC and the LSU Principal Investigator finalize the scope of work, the LSU Principal Investigators routes his/her subcontract proposal to LSU’s Office of Sponsored Programs (OSP) for review and approval using the electronic proposal routing and approval system. LSU’s OSP will provide institutional review and endorsement by LSU’s Authorized Representative, allowing the proposal to be submitted.  Should the award be funded, LSU and SBC would need to enter into an agreement that incorporates terms substantially similar to the STTR Model Agreement.

If the LSU Principal Investigator, any other Project Personnel, or other department personnel (including immediate family members) have a financial interest in the SBC, including consulting contracts, the PM-67 question on the electronic proposal routing cover sheet must be marked “Yes” at time of proposal submission. This will require that any contract with the SBC (i.e. a sub award or a license) must go through the PM-67 review process. These documents are not required for submission of the SBIR/STTR proposal, but will be required if the award is received by the SBC. If the LSU Principal Investigator or any other LSU Personnel has a role with the SBC that would rise to the level of providing an economic benefit as identified in PM-11, the LSU personnel are responsible for complying with PM-11 prior to any submission.

Sample SBIR/STTR Cover Letter

Negotiation and Acceptance of SBIR & STTR Subcontracts

OSP is responsible for negotiating a subcontract between the SBC and LSU. LSU Personnel with an interest in the SBC (including immediate family members) may not be involved in negotiation or decision making on behalf of LSU with respect to the subcontract.

Prior to LSU’s acceptance of a subcontract from an SBC that involves LSU employees with an interest in the SBC (including immediate family members) and the performance of LSU’s portion of the SBIR/STTR-funded work, a current PM-11 must be in place and PM-67 approval must be obtained.

Use of LSU Technology

The SBC may not use LSU technology without first negotiating a license with LSU through LSU’s Innovation & Technology Commercialization office. LSU Personnel with an interest in the SBC (including immediate family members) may not be involved with the negotiation or decision making on behalf of LSU. Before the license can be signed the LSU faculty inventors/company founders must obtain PM-11 and PM-67 approval.