As many of our Blog subscribers know, I recently had an opportunity to attend the 2015 NIH SBIR/STTR conference in Seattle. It offered unique insights into many of the processes that go in to submitting proposals and managing projects under the SBIR/STTR programs. These are insights that may not be emphasized or express themselves fully in the funding opportunity announcements.
For those of you who were not able to attend, the conference is a great opportunity to take advantage of one-on-one sessions with researchers within NIH looking to leverage small business innovation. Don’t forget that many conferences also provide one-on-one meetings with other programmatic experts. For example, the NIH DFAS has a one-on-one table available to discuss indirect rate cost issues.
For NIH SBIR/STTR participants, I found the DFAS Indirect Cost session very well organized and as thorough as it could be in the 50 minutes allotted for the session. Some “aha” moments include:
- IRD&D labor and non-labor costs reflected as direct costs in the NIH indirect rate calculation example (per HHS policy 45 CFR 74.27).
- There is no regulatory or policy basis for excluding direct equipment and subcontracts costs over $25,000 (per subcontract) from the G&A base other than the concept of allocability found in the CFR and FAR Part 31. The G&A base exclusion is an NIH practice that suggests there is minimal causal relationship between G&A costs and managing the purchase of equipment and subcontractors. However, the NIH stated to the group it recognizes that the allocation of G&A depends on the operations of the grantee or contractor, and is willing to accept a reasonable allocation approach.
- Indirect cost submissions (IDCs) are initiated by the small business. Two submittals are due six months after each fiscal year, one calculating prior year rates, one for the current year rates. This is significant since if you don’t submit a proposal, no one from NIH is going to prompt you, and you may not have an opportunity to increase indirect rates..
- IDCs take between six weeks to a year to review and approve.
- The NIH presenter suggested you hire an expert to help figure this stuff out.
Also fascinating was a mock peer review of a Phase I proposal. This plus the sessions on Phase I and II proposal development explained many nuances and hints to make your proposal stand out.
The next NIH SBIR/STTR submittal is January 5, 2016, but participants were warned at the conference to submit by January 1, as a new NIH system for uploading and checking proposals, called ASSIST, is now deployed
If you are planning on submitting a Phase I proposal, now would be a good time to start. The following link contains presentation material from many of the conference sessions. Good Luck!contact ReliAscent today, to learn more and have your voice heard.