COI Guidance for SBIR/STTR Awards

In SBIR/STTR awards, federal funds are awarded to small businesses, which may collaborate with research institutions such as MIT on the award. If the PI has a significant financial interest (SFI) in the small business, it may pose a real or perceived conflict of interest (COI), and affect their participation in different phases of the award.

Image
SBIR-STTR Flowchart

Phase I SBIR/STTR Awards and COI

  • Every Investigator needs to file a disclosure (e.g. be named as key people on the proposal). An Investigator is anyone responsible for the design, conduct or reporting of the research.
  • If the company is the MIT investigator’s Related Entity, MIT can only accept funding for the Phase I award. We cannot be involved in later phases with a Related Entity. 
  • Department must be willing to manage the oversight of any potential conflict of interest (COI).
  • MIT PI cannot also be the PI on the company's proposal. It needs to be a full time employee of the company.
  • Company personnel cannot be appointed at MIT.
  • The SFI and relationships need to be disclosed in the proposal to the sponsor.

Phase II SBIR/STTR Awards and COI

SBIR/STTR Phase II awards are allowed only if the company is not a Related Entity of the MIT investigator. If the company is the MIT investigator’s Related Entity:

  • Faculty often opt to create new relations with other researchers at other institutions so that the work can continue there.
  • Faculty may request an exemption (Touchstone required) to COI policy.

Additional Information on SBIR/STTR Awards

SBIR/STTR Purpose and Eligibility

Award Type

Purpose

Eligible Applicants

SBIR/STTR Phase I

Initiate research and development for new potential technology; establish technical merit, feasibility, and commercial potential of proposed R&D efforts to determine whether the awardee’s research merits Phase II funding.

Small business concerns

SBIR/STTR Phase II

Continue R&D initiated in Phase I by testing the functional viability of the prototype according to scientific methods and potential for commercial development.

Recipients of an SBIR/STTR Phase I award who demonstrate the scientific and technical merit and commercial potential of the project proposed in Phase II.

SBIR Direct to Phase II
(NIH only)

Provide research and development funding for US small businesses that have already built a technology prototype and tested its feasibility. Not available for STTR program. For NIH SBIR proposals only.

Non-recipients of an SBIR Phase I award who have completed Phase I-type research through other funding sources. Not available to STTR program.

SBIR/STTR Phase IIB
(NIH only)

Supplemental award for Phase II awardees whose projects require extraordinary time and effort (e.g. FDA approval).

Recipients of SBIR/STTR Phase II award

SBIR/STTR Fast Track
(NIH only)

Mechanism for submitting a Phase I and Phase II award as one application to minimize potential funding gaps between Phase I and Phase II

Small business concerns

PFI-AIR-TT
(NSF only)

Award for NSF awardees with a research result that has commercial potential or graduates of NSF-funded I-Corps program.

See your RAS Contract Administrator for more information

SBIR/STTR Phase III

Phase III work is typically oriented towards commercialization of SBIR/STTR research or technology. Phase III work may be for products, production, services, research and development, or any such combination. The following activities are examples of types Phase III work:

  • Commercial application of SBIR/STTR funded R/R&D financed by non-federal sources of capital.
  • SBIR/STTR-derived products or services intended for use by the federal government, funded by non-SBIR/STTR sources of funding.
  • Continuation of SBIR/STTR work, funded by non-SBIR/STTR sources of federal funding including R/R&D.

Recipients of SBIR/STTR Phase I and Phase II agreements that could be commercialized, extended, and/or logically concluded by further efforts. Phase III may also follow-on non-SBIR/STTR funded contracts with components of granting agency.

Updated July 2, 2025