A number of federal agencies have programs supporting the research and development activities of small businesses that foster collaboration with university research. ORS is seeing increasing numbers of Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) collaborations, both, where UH faculty, staff and students are subcontractors of small businesses and where UH faculty, staff and students are themselves the proprietors of start-up companies. UH recognizes the importance of the SBIR and STTR program goals such as stimulating technological innovation and encouraging technology commercialization, both of which, increase productivity and economic growth. However, some of these types of activities and the relationships fostered between small businesses and UH faculty, staff and students may give rise to conflicts of interest and/or conflict of commitment issues.
The Vice President for Research and Innovation (VPRI), the Office Technology Transfer (OTT) and ORS have created these guidelines to address issues of SBIR and STTR funded projects.
- The Principal Investigator (PI) on subcontracts/subawards to UH and the PI on the SBIR/STTR award to the small business must not be the same individual.
- UH employees should not be the PI on SBIR awards (SBIR program requires the PI to be primarily employed, >50%, by the small business), without an exception/approval from the Deciding Official (Vice President for Research and Innovation).
- The proposed research to be performed at and by the small business must be clearly delineated and distinct from the research to be performed at UH. Additionally, the small business must provide evidence of adequate facilities (laboratory, office…) to perform the work. The small business may not utilize any UH resources for any of their activities.
- UH employees (including members of their immediate family) who have ownership interest in the small business receiving a SBIR/STTR award may not conduct or direct research in his/her own laboratory through subcontracts/subawards from that small business.
- All licensing and intellectual property issues must be reviewed by OTT and agreements must be in place before any UH subcontract/subaward is executed.
- The implementation of a COI management plan may be required when these guidelines are inadequate, and will be determined on a case by case basis.