The SBIR/STTR Extension Act of 2022 and the Small Business Administration SBIR/STTR Policy directive included some important revisions as part of reauthorization. Most notably, all proposals now require that a “Disclosures of Foreign Affiliations or Relationships to Foreign Countries” document be submitted with every proposal. Proposals that do not include this disclosure form will be deemed non-compliant and will not be reviewed.
Applicants may not include individuals in their proposals who are deemed as “Covered Individuals” affiliated with a Foreign Country of Concern. This includes anyone who contributes in a substantive, meaningful way to the scientific development or execution of an R&D project proposed to be carried out with a Federally funded award from DOD. DOD has further designated “covered individuals” as including all proposed key personnel. Foreign affiliation means “a funded or unfunded academic, professional or institutional appointment or position with a foreign government or government-owned entity. This includes appointments or positions deemed adjunct, visiting or honorary with research institutions located in a foreign country of concern.”
Foreign countries of concern are defined in 15 U.S.C. § 638(e)(17) as the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State. An up-to-date list of countries determined to be countries of concern will be maintained and accessible on SBIR.gov.
Plan your project staffing accordingly and be sure to include the required documentation. Contact BBCetc if you have any questions or need help developing a fully compliant SBIR/STTR proposal.
