SBIR PD 2002
SUMMARY - Summary of General Comments

Summary of General Comments

SBA received several comments that were general in nature. One commenter noted that the Directive does not diminish the independence of participating agencies. SBA concurs. Section 9(j) of the Small Business Act (Act) requires that SBA issue an SBIR Program Policy Directive to provide guidance to the Federal agencies participating in the SBIR Program for the general conduct and operation of the Program. While the SBIR agencies are obligated to follow the guidance contained in the Policy Directive, each agency determines, in consultation with SBA, such items as the categories of research projects to be included in its SBIR Program, the number of solicitations issued during a fiscal year, the dates for receipt of proposals, and the evaluation and selection procedures employed in making SBIR awards. Thus, the Policy Directive is designed to guide the SBIR agencies in the operation of their program.

Another commenter noted that this Directive might result in an increase in administrative costs in order to comply with all of the requirements and that its administrative money might come from outreach activities. In response to this comment, SBA reminds agencies that the Act prohibits SBIR agencies from using any of their SBIR allocated- funds for financing the administrative costs associated with the operation of the SBIR Program. The Act also requires that agencies increase their outreach efforts to increase the participation of socially and economically disadvantaged small business concerns and women-owned small business concerns in the SBIR Program, including in the commercialization phase (Phase III) of the Program. SBA is not permitted to offer any relief to the SBIR agencies regarding these provisions.

One commenter stated that there is a need to maximize topics, subtopics and descriptions. SBA believes that the Policy Directive addresses this concern when it states that each SBIR agency must ``issue a program solicitation that sets forth a substantial number of R/R&D topics and subtopic areas consistent with stated agency needs or missions.'' Further, ``each topic and subtopic must describe the needs in sufficient detail to assist in providing on-target responses, but cannot involve detailed specifications to prescribed solutions of the problems.''

Another commenter noted that it is a good idea to make solicitations as uniform as possible. SBA notes that Appendix I of the Policy Directive contains instructions to the SBIR agencies designed to produce solicitations that are prepared in a standardized, easy-to- read, and easy-to-understand format.

Other commenters requested that SBA be consistent with using ``Phase I,'' etc. as opposed to ``phase one.'' SBA concurs that it is easier to read and has changed the Policy Directive to read ``Phase I,'' Phase II,'' and ``Phase III,'' as appropriate throughout the document.

One comment letter questioned what happens to the 1993 Policy Directive when this one becomes final. SBA would like to make it clear that this is the final SBIR Program Policy Directive and upon its effective date it supersedes any previously issued SBA Policy Directive, including the 1993 Directive.

SBA received several comments to the different sections of the Directive. In addition, SBA makes some clarifications and changes. The following is a section-by-section analysis of the final Directive, including comments received for each section and changes made.