SUPPORTING STATEMENT FOR PAPERWORK REDUCTION SUBMISSION
Pre-Award Reporting Requirements for the National Science Foundation (NSF)
Small Business Innovation Research (SBIR)/ Small Business Technology Transfer Research (STTR) Program
This request is to seek approval in renewing pre-award reporting requirements for the NSF Small Business Innovation Research (SBIR)/Small Business Technology Transfer Research (STTR) programs. Minor changes were made to the data collection, and the public burden estimates have been slightly revised to reflect that change.
The NSF SBIR/STTR programs focus on transforming scientific discovery into products and services with commercial potential and/or societal benefit. Unlike fundamental or basic research activities that focus on scientific and engineering discoveries, the NSF SBIR/STTR programs support the creation of opportunities to move fundamental science and engineering out of the lab and into the market at scale, through startups and small businesses representing deep technology ventures.
The NSF SBIR/STTR programs have two phases: Phase I and Phase II. Phase I is a 6-12 month experimental or theoretical investigation that allows the awardees to determine the scientific and technical feasibility, as well as the commercial merit of the idea or concept. Phase II further develops the proposed concept, with a goal of working toward the commercial launch of the new product, process, or service being developed.
The NSF SBIR/STTR programs request the Office of Management and Budget (OMB) renew its approval of this clearance that will allow the SBIR/STTR programs to collect information from a selected group of Phase I and Phase II applicants—those that have been reviewed by independent experts and that NSF Program Directors are considering recommending for funding—for the purpose of making a funding decision. This information includes, but is not exclusive to, a list of company officers and the corresponding ownership status of each company officer within the startup, whether the startup is associated or affiliated with other companies, whether there exist any relationships (personal, financial, and/or professional) between project personnel, and the locations of all the facilities where significant research will be performed for the proposed project. Such data will enable the NSF Program Directors to evaluate a given company’s business structure, ascertain the level of commitment of the Principal Investigator (PI) and co-PIs to the startup venture, and identify conflicts of interests (if any), as part of the due diligence process that the programs undertake to verify there are no fraudulent or inappropriate business practices prior to recommending the small business for an award.
The primary reason for this data collection is to fulfill the NSF SBIR/STTR programs’ monitoring and management responsibilities, and to answer queries from OMB, SBA, and Congress. This is especially important given the heightened national security concerns from Congress that emerging technologies—including those funded by the government-wide SBIR/STTR programs—are being transferred to adversary nations.
Owing to this, NSF SBIR/STTR programs need to collect current and standardized information as part of the due diligence process that the programs undertake to verify there are no fraudulent or inappropriate business practices prior to recommending small businesses for an award. This information specifically supports compliance checking, auditing, and/or legal purposes, and is needed for effective pre-award management, administration, and/or program monitoring.
This level of oversight is needed given that most NSF SBIR/STTR awardees are early-stage start-up companies that are both small and new to government funding. The reporting requirements listed above are in addition to the proposal data submitted by these small businesses.
As mentioned, only minor changes were made to the data collection—specifically questions pertaining to cybersecurity and foreign influence. Collecting this information aligns and is in support of the Government Accounting Office (GAO) due diligence engagement findings.
The SBIR/STTR Pre-Award Reporting Requirements have been designed primarily for due diligence, compliance checking, and pre-award management purposes.
In
addition, the collection of these data serves several purposes,
including:
Responding to requests from Congress, NSF's Office of the Inspector General, and the general public; and
Providing evidence for litigations, auditing, and other legal investigations
All components in the collection will utilize electronic forms and electronic submissions to minimize data errors and respondent burden. In some cases, NSF Program Directors, NSF staff, and/or NSF authorized contractors may contact the respondents for clarifications or follow-up questions to ascertain data veracity and robustness, as well as quality assurance.
The SBIR/STTR Pre-Award Reporting Requirements do not duplicate other efforts undertaken by NSF, other federal agencies, or other data collection agents.
Not applicable.
If the information was not collected, NSF would be unable to conduct its compliance checking and perform the necessary due diligence to assess whether small businesses are suitable for funding pursuant to the NSF SBIR/STTR programs. The absence of this information would also preclude NSF from reporting adequately and suitably to Congress when asked.
Data collected for the SBIR/STTR Pre-Award Reporting Requirements will comply with 5 CFR 1320.6. First, a valid OMB control number will be displayed at the beginning of the electronic form. Second, as the reporting requirement is mandatory, the NSF SBIR/STTR programs will communicate clearly, through proposal solicitations, that collection of this information is required.
Selected applicants will be asked to submit one set of responses on behalf of a given small business, for Phase I and Phase II (if applicable) applications.
The agency’s notice, as required by 5 CFR 1320.8(d), was published in the Federal Register Bulletin on 2 July 2025, at 90 FR 29050. No comments from the public were received.
Not applicable.
Respondents will be informed that any information on specific individuals will be maintained in accordance with the Privacy Act of 1974. Every data collection instrument will display both OMB and Privacy Act notices.
Respondents will be told that data collected are available to NSF officials and staff, as well as authorized contractors and/or grantees who manage the data and data collection software. Data will be processed according to federal and state privacy statutes. The data collection system will limit access to personally identifiable information to authorized users. Data submitted will be used in accordance with criteria established by NSF for monitoring research and education grants and in response to Public Law 99-383 and 42 USC 1885c.
In the SBIR/STTR Pre-Award Reporting Requirements, personal information, including name, job title, and ownership status are being requested.
Respondents: PIs listed on the NSF SBIR/STTR proposals
Estimated Number of Annual Respondents: 1000
Frequency: Once
Average Time: 0.25 hours
Estimated Total Burden Hours: 250 hours per year
Respondent Type |
No. of Respondents |
Burden Hours Per Respondent |
Average Hourly Rate |
Estimated Annual Cost |
PIs |
1000 |
0.25 |
$53 |
$13,500 |
Total |
1000 |
250 hours |
|
$13,500 |
Not applicable.
The number of respondents is larger; however, the time to respond has not changed.
Not applicable.
Not applicable.
No exceptions apply.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Griswold, Shannon |
| File Modified | 0000-00-00 |
| File Created | 2025-11-25 |