In December 2015, the following terms were identified in the NSF (National Science Foundation) SBIR (Small Business Invention Research) Program Phase I instructions:
“No person who is an equity holder, employee, or officer of the proposing small business may be paid through a subaward budget unless an exception is recommended by the Program Director and approved by the Division Director for the Division of Industrial Innovation and Partnerships.”
This term is a substantial difference from the PHS (Public Health Service) regulations on conflicts of interest. To be compliant with the current requirement for exception approval, the institution applying for the grant (i.e. the small business) must contact the NSF Program Director to determine what would be required to document the exception approval.