The Small Business Technology Council submitted its comments to the Small Business Administration for their SBIR/STTR Policy Directives on January 6, 2015.

The Small Business Administration posted a request for comments last month in the National Register, asking small businesses and organizations to weigh in and help them answer a few specific questions pertaining to SBIR data rights and Phase III policy, to help them better instruct the agencies on how they can be in compliance with the changes in the SBIR law that were made during the last reauthorization in 2011.  We provided our answers based on our conversations with our member companies, as well as from the data we received from the general survey sent to all SBIR winners.

One of the biggest obstacles related to data rights and Phase III policy is simply the lack of training and education of Contracting Officers and their offices regarding the agencies’ responsibilities and mandates under the law.  Our survey showed that 65% of contracting officers simply didn’t know that agencies are required by the law to show preference to the SBIR company that developed the technology when awarding Phase III grants.  updating the Policy Directive and FAR is important, but there needs to be a comprehensive training system for Contracting Officers enacted in order to make sure the changes in the law are fully implemented.

SBTC Comments on SBIR Policy Directives