SBIR Gateway
News and Comment
Comments on Pending SBA Policy Directive
Updated August 6, 2002

A proposed Policy Directive (PD) from the SBA limiting SBIR subcontracting with federal facilities is currently being reviewed by the Office of Management and Budget (OMB) and will soon be sent back to SBA for implementation. The current draft of this policy directive states:
(1)   An agency shall not issue an SBIR funding agreement that includes a provision for subcontracting any portion of that agreement back to the issuing agency, to any other Federal Government agency, or to other units of the Federal Government. SBA may issue a case-by-case waiver to this provision after review of an agency's written justification that includes the following information:
(a)   An explanation of why the SBIR research project requires the use of the Federal facility or personnel, including data that verifies the absence of non-federal facilities or personnel capable of supporting the research effort.
(b)   Why the Agency will not and can not fund the use of the federal facility or personnel for the SBIR project with non-SBIR money.
(c)   The concurrence of the SBC's chief business official to use the federal facility or personnel.
Although this directive applies to all agencies, the DOE is perhaps the most affected because many of their government owned/contractor operated (GOCO) laboratories and other Federally Funded Research and Development Centers (FFRDC) were involved in such practices. Although many small companies have been greatly helped by these partnerships, some have cited potential for abuses and/or conflicts of interest.

In order to try and present a fair picture of both sides of this issue, we have solicited opinions from top SBIR experts with opposing views.

Statement in Opposition of the PD - by Mr. Jim Greenwood and Ms. Gail Greenwood
Mr. Greenwood and his wife Gail, founded the Greenwood Consulting Group and have spent many years doing SBIR training workshops and consulting. Their SBIR workshops are among the most popular in this field. The Greenwoods have also managed a Small Business Development Center (SBDC), in which they counseled and trained literally hundreds of prospective entrepreneurs and small business owners and managers. Mr. and Ms. Greenwood have also worked with several Federal Laboratories in their technology transfer programs, particularly as those efforts apply to small business and Federal Lab employees seeking to spin off new firms around technology.
Rebuttal to C. Busch letter of July 10 - July 11, 2002
Letter to OMB requesting examples of abuse - July 31, 2002

Statement in Support of the PD - by Dr. Chris Busch
Dr. Busch founded Spectron Development Laboratories, Inc and was instrumental in winning many SBIR awards. After selling his company and semi-retiring, Dr. Busch became a leading consultant to small businesses interested in the SBIR program. He has also served as an advisor to various federal agencies for their SBIR programs. Dr. Busch has spent a considerable amount of time helping the SBIR programs in under-served states and has the distinction of having a state SBIR Award named after him by the State of Wyoming.

Statement from the Center of the Issue - by Mr. John Davis
Mr. Davis is currently the general manager for the SBIR Resource Center, a private, for profit entity with a mission to support state SBIR outreach programs and aid individual applicants for SBIR and STTR programs. Mr. Davis has been providing service to the SBIR community for 10 years and his seminars on SBIR business development are in high demand. Mr. Davis has developed and is actively supporting, more than twenty SBIR Outreach Centers™ in six states that in turn touch many hundreds of potential applicants annually.

SBIR Gateway participants are similarly split in their views. Here are some of their thoughts:
Views in Opposition of the PD
Letter From: Name Withheld - 7/8/02

Views in Support of the PD

Letter From: Larry Farrar - 7/17/02
Comments From: Names Withheld - 7/12/02
Straw Poll
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It is possible that your comments may have some impact if you respond quickly. You can address your comments to:

  • DOE Program Manager: Dr. Robert Berger -
  • SBA Assistant Administrator: Mr.Maurice Swinton -
  • Office of Management and Budget: Ms. Yvette Dennis -

    Also, don't forget your Senators ( and Congressmen (

    We are interested in your opinions. Feel free to participate in our anonymous Straw Poll on the right. (Please, just one vote per person.) Address your comments to

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