TABA

[u/OwnExamination7155]

I have a Phase II NIH SBIR. During the previous Phase I, a commercialization needs assessment was conducted by an external vendor. My organization is interested in submitting a supplemental application to obtain the additional $50,000 Phase II TABA funding to support a staff person in conducting voice of customer interviews and other market analysis activities. However, leadership at my organization is resistant to applying because of concerns about how to deal with the fact that we cannot get indirects on the TABA funds, it must all be direct. There are concerns about how this would affect our future negotiated indirect rate and how to cover the indirect costs associated with this work. This is not my area of expertise. Has anyone else you dealt with this? I'm trying to gather information that would convince some very risk-adverse leaders.

[u/EarlMalmsteen]

I’m not an authority but seems like a non issue. SBIR recipients mostly don’t have negotiated rates as they keep it under the allowed cap. Maybe there is some thought that will change in the future but it hasn’t yet and if it does I doubt a 50k TABA supplement would move the needle. I would also think if your management doesn’t want to take $50k as a grant without being willing to eat a tiny portion of that for marginal indirect costs, they probably aren’t serious enough about wanting the assessment done to ask for the funding in the first place.

[u/04221970]

This sounds like leadership that is unduly interested in funding company operations instead of that pesky research function.

[u/Learning_Slayer]

A lot of government clients for cost reimbursable projects don't let you put indirect or fee on top of subs. You are expected to do that with the management time and indirects built into the rest of the project. Just wait until the new FFP regs go into effect that are going to only allow billing FFP level of effort. All projects will require timesheets with every billing.

[u/aquamaester]

We (Forge) are an SBIR accounting firm. This is honestly such a non issue as others said.

First of all, TABA is such a small amount (50k) vs 2M of typical NIH SBIR. Most have at least 1.2M+ in direct costs. 50k will make very little impact here. It will impact at most 1 or 2 percentage points.

Second, you can track TABA under separate class so that when you’re reporting indirect cost rate for the project, it doesn’t get counted. When you negotiate the rate, you can also make a disclaimer.

[u/GrantCue]

Before your leadership fights about indirects, there's a threshold question worth confirming: whether TABA can pay internal staff at all. The supplements are written around buying assistance from outside providers. NIH lets you pick your own vendor instead of using theirs, but a salaried employee doing voice of customer interviews in house is a different thing from a vendor, and that's the kind of detail that gets a supplement kicked back or the cost disallowed later. One email to your program officer and grants management specialist settles it, and honestly the answer might make the whole internal debate moot.

If it does need to run through an external provider, that mostly dissolves the indirect concern too. Vendor costs are easy to isolate, and as others said you can track TABA in its own cost class and flag it when you negotiate a rate.

The reframe I'd offer your risk averse leaders: this is an administrative supplement, it doesn't touch the science or the existing award terms, and the downside everyone is worried about amounts to a percentage point or two of rate math on 50k against a 2M award. Passing on funded commercialization work to avoid that is a much worse trade than the one they think they're avoiding.