Navigating SBIR Awards as a Principal Investigator: Time Commitment and Overlap

The SBIR (Small Business Innovation Research) program is a valuable resource for small businesses seeking funding for research and development. However, it's important for Principal Investigators (PIs) to understand the guidelines surrounding time commitments and overlapping projects. This article provides clarity on when and how a PI can manage multiple SBIR awards.

General Guidelines and Constraints

No typically, a PI cannot be the principal investigator on two overlapping Small Business Innovation Research (SBIR) awards. The SBIR program generally requires that a PI be fully committed to a single project to ensure focus and avoid conflicts of interest. This means that the PI should be available and fully devoted to the research being conducted under the award.

It's crucial to check the specific guidelines of the funding agency you are applying to, as rules may vary slightly between agencies. For instance, Air Force SBIR and Small Business Administration’s (SBA) SBIR may have different requirements. Additionally, if there are unique circumstances or if one project is a follow-on to another, you might be able to discuss your situation with the agency's program officer for guidance.

Multiple SBIR Awards for the Same Company

The same company and PI can undertake multiple SBIRs at the same time, provided that you are honest and follow the FAR (Federal Acquisition Regulation) guidelines on time and expenses. However, it is imperative not to charge for the same work twice. In some cases, one may work on two SBIR projects that are similar, especially if they fall within the same area of expertise. This can happen naturally, as a PI's research focus is often in a particular domain, leading to overlap in technology and methodologies.

In such scenarios, complete transparency is key. It's essential to communicate clearly with all relevant project managers (PMs) and document how the projects are similar but not identical. This is particularly easier when you have one Phase 1 and one Phase 2 award since Phase 1 is more exploratory in nature. It's also crucial never to work one hour and bill one hour each to both projects to avoid ethical and legal issues.

Time Commitment and Independent Work

As a PI, you can be involved in multiple projects as long as you are not committed more than 100% of your time based on a 40-hour work week. However, a given company cannot take overlapping awards where the work done on two separate projects overlaps. The work must be totally distinct for each project, and you can never do one hour of work and bill it to two projects. If these two awards are to the same company, the company would be committing fraud if there is any overlapping of work.

To summarize, while it's generally difficult to be the PI on two overlapping SBIR awards, flexibility and transparency are key in managing multiple projects. Always adhere to the guidelines set by the funding agency and maintain clear communication with all stakeholders involved in the projects.