Preparing to submit a proposal to the SBIR program requires several different registrations that are each critical to the process and work interconnectedly to enable the application process. Understanding what each registration is for and how each registration influences the next step in the process is critical.
Understanding what the registrations do and do not do, as well as what entities and team members need each type of credentialing, is another critical aspect of understanding your registrations. Some clients have conflated their understanding of registrations and how they work. This can be an error of omission – thinking a subawardee institution or consultant does not need certain registrations. It can also be an error in the estimation of what the system is capable of and what it is not. For example, research.gov is required to submit proposals for NSF and NIH, but it is not connected to the reporting and payment systems in place for SBIR.
The first place to start is with System for Awards Management, SAM. The Unique Entity Identifier (UEI) number has replaced DUNS as the universal identification method for small businesses. It is impossible to create a grants.gov, research.gov, or eRA Commons account without an active and valid SAM. It is also impossible to be added to a grant as a subawardee without a valid UEI number. Only the organization (the small business concern) and any subaward organizations must obtain SAM – not each individual within the organization(s).
Once SAM is approved, the next step is to sign up for grants.gov. This will require two accounts – an organizational account and an individual account for the Signing Official/Principal Investigator. For this registration, only the organization and the person preparing and submitting the grant (which is usually one individual but could potentially be two) are required to have an account.
SBIR.gov has a required Small Business Association (SBA) registration. A certificate is sent to organizations upon confirmation of registration. This is required for all SBIR applicants, but only the organization (the small business – not any individuals) is required to register.
The individual accounts that each agency offering SBIR uses can vary in terms of registration requirements. Research.gov for example, does not require anyone but the organization and a PI/SO to be registered. Other portals, such as NIH’s eRACommons require that the organization and each senior personnel have an individual account to be on the grant. Despite this requirement, there is no connection to having an eRACommons – or any other grant portal – username and receiving grant payments. Similarly, within NIH while senior personnel need an eRACommons username and subawardees need a valid SAM account, there are no requirements for 1099 consultants.
It is important to learn the individual registration requirements of the agency releasing the solicitation to which you are applying. This will enable you to properly complete all required registrations and stay in the know about how each is important individually and collectively for a successful application.
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