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Export of Research Materials Abroad

Posted on December 23, 2019December 23, 2019 by Jessica McBride

To the UConn/UConn Health research community:

The Council on Government Relations (COGR) has issued an alert regarding recent situations where researchers have attempted to export research materials abroad. The FBI and other federal law enforcement agencies have increased their surveillance efforts to identify transport of research materials and verify that those exports comply with federal laws. These efforts are believed to be part of a nation-wide enforcement action to control the transport of biological materials that may present a threat to our national security and/or reduce the theft of intellectual property developed in the US, much of it with federal funds.

Transporting certain materials may require import/export permits or other documentation from federal agencies, including US Customs and Border Protection (CBP), the FDA, USDA, Fish and Wildlife, and the CDC.

Anyone with questions should contact the applicable federal agency or the UConn Export Control Office (exportcontrol@uconn.edu) for assistance.

Related news:
– https://www.universalhub.com/2019/chinese-cancer-researcher-not-allowed-leave
– https://www.universalhub.com/2019/chinese-researcher-nabbed-liquid-filled-vials

Wesley G. Byerly, Pharm.D.
Associate Vice President

NIH Asks For Your Feedback

Posted on December 3, 2019December 3, 2019 by Ellen Ciesielski

The Office of the Vice President for Research would like to share some information regarding data sharing with researchers who may be affected.

The National Institutes of Health (NIH) is requesting comments on the draft NIH Policy for Data Management and Sharing and Supplemental Draft Guidance.

NIH will be hosting an informational webinar on the draft NIH policy and guidance on Monday, December 16^th from 12:30-2:00 PM ET. The purpose of the webinar is to provide information on the draft policy and answer questions about the public comment process.

Submit your comments to NIH by January 10, 2020. Additional information can be found in this NIH blog post. Questions about the draft may be sent to the NIH Office of Science Policy at SciencePolicy@od.nih.gov.

For questions, please contact Research Compliance Monitor, Ellen Ciesielski at 860.679.6004.

Research Involving Cannabis, Hemp, and Marijuana

Cannabis-related research – including research involving marijuana and hemp – must conform to federal and state laws as well as University of Connecticut (“UConn”) policies.

Under the Federal 2018 Agricultural Improvement Act (Farm Bill), hemp is no longer a controlled substance. Hemp is legally defined as Cannabis sativa L. that contains not more than 0.3% delta-9 tetrahydrocannabinol (“THC”) content on a dry-weight basis. The Farm Bill currently restricts the growing of hemp to states that have established a Hemp Research Pilot Program.

Connecticut recently established such a program with the passing of Public Act 19-3: “An Act Concerning a Pilot Program for Hemp Production.” This act established the state of Connecticut Hemp Research Pilot Program (HRPP) to support research that advances the Department of Agriculture's understanding of hemp agriculture at national, regional, and local levels. This legislation sets the state requirements for hemp growers, processors, and manufacturers to obtain a license, and establishes requirements for licensing, testing, and inspection. State requirements apply to the cultivation, processing, and manufacturing of hemp. State requirements also apply to academic and scientific research, teaching, and testing involving hemp.

UConn researchers who wish to participate in the Connecticut’s HRPP must register through the University and follow University guidelines related to growing, processing, and manufacturing hemp. For more information on registering through the University, email contact information to HempProgram@uconn.edu.

Marijuana, including Cannabis sativa L. that contains more than 0.3% delta-9 THC, remains a Schedule I controlled substance, the most restrictive status, under the Controlled Substances Act. The possession, production, processing, sale, or growth of marijuana remains illegal under Federal law, except under special licensing requirements established by the Drug Enforcement Agency (“DEA”). Research with marijuana requires the researcher to have both a Federal Schedule I and a Connecticut Schedule II controlled substance license, and s/he may only receive marijuana from other DEA registrants or from the National Institute on Drug Abuse (“NIDA”) approved sources. UConn researchers must also follow the University’s Controlled Substances Policy or the UConn Health Controlled Substances Policy. For more information regarding marijuana research, contact HempProgram@uconn.edu.

FAQs

Once issued a license, you must comply with the provisions of Public Act 19-3 (the “Public Act”), the federal act (as defined in the Public Act), and the Connecticut Department of Agriculture (“DOAG”) Compliance Policy. As a condition of being granted a grower license, you, as the principle investigator and on-site manager listed on the license, and the University agree to the requirements listed below. Note that submissions and notifications must be made through the University:
1. Comply with instructions from the DOAG and law enforcement agencies;
2. Agree to pay DOAG applicable licensing and inspection fees;
3. Consent to entry onto, and inspection of all buildings, equipment, supplies, vehicles, and records located on this real property where hemp or plants or materials are located, or licensed to be located, by the commissioner, and law enforcement agencies, at any time, with or without cause, and with or without advance notice;
4. Comply with DOAG’s criminal history records check requirements; and
5. Consent to forfeit and destroy, without compensation:
a. Material found to have a THC content in excess of three-tenths percent (0.3%) on a dry weight basis;
b. Hemp plants located in an area that is not licensed by the department; and
c. Hemp plants not accounted for in required reports for the department.
6. Notify the DOAG of all hemp growing, handling, and storage locations, including legal description and GPS coordinates in decimal degrees to the ten-thousandth place, and receive department approval for those locations prior to having hemp on those premises.
7. Submit a Site Modification Request Form, the appropriate fees based on the requested changes, and obtain prior written approval from the commissioner before implementing any change to the plot(s) stated in the grower license application.
8. Not grow, handle, or store hemp in any location(s) other than the location(s) listed in the grower license application.
9. Not interplant hemp with any other crop without express written permission from the DOAG.
10. Not apply and not allow anyone else to apply pesticide to hemp except by person(s) who hold a valid permit or certificate, if required, to apply pesticides in accordance with section 22a-54 of the Connecticut general statutes.
11. Comply with all legal requirements regarding minimum distances from certain structures, and outdoor recreational facilities.
12. Acknowledges that the risk of financial or other loss shall be borne solely by the License Holder.
13. Use a record keeping and product coding system for hemp to facilitate the effective tracking of hemp and hemp products. Such plot system shall be capable of tracing hemp placed into the wholesale or retail distribution chain back to the producing plot. Such records shall be maintained for a period of time that exceeds the expected shelf life of the hemp or five (5) years, whichever is longer. Records of hemp product coding and distribution shall be made available immediately upon request of the department or any law enforcement agency.
14. Ensure that any time hemp is in transit within Connecticut, a copy of the grower license, and certificate of analysis showing the sample to have a THC concentration at or below three-tenths (0.3) percent on a dry weight basis, shall be available for inspection upon the request of the commissioner or any law enforcement agency. In the event the hemp being transported is a hemp sample being transported to a laboratory, then the sample shall be contained in a sealed tamper evident sample package and accompanied by the department approved completed chain of custody form for hemp samples. The hemp sample label shall contain, at a minimum, the date and time the sample was collected, licensee name, licensee number, location where the sample originated, identification of the lot the sample represents and a sample identification number or laboratory accession number.
15. Upon request from the commissioner or a law enforcement agency, immediately produce a copy of his or her grower license for inspection.
16. Submit Planting Reports, Harvest/Destruction Reports, Production Reports, and other reports required by the commissioner, on or before the deadlines established in these regulations. These records shall be maintained for at least three (3) years after harvest or destruction of the hemp. These records shall be made available immediately upon request of the department or any law enforcement agency.
17. Scout and monitor plots for volunteer hemp plants and to destroy those volunteer hemp plants for three (3) years past the last date of planting reported to the department.
18. Not to rent land to cultivate hemp from any person who has a state or federal felony conviction for a controlled substance within 10 (ten) years of the date of this agreement.
19. Notify the department of any interaction with any law enforcement agency immediately by phone and follow-up in writing within three (3) calendar days of the occurrence.
20. Immediately notify the department and applicable law enforcement agency of any theft of hemp materials, whether growing or not.
21. Immediately notify the department and applicable law enforcement agency of any unauthorized cultivation of any plant, within each plot.
22. To destroy any hemp or cannabis that is obligated to be destroyed, only in accordance with state and federal law, and the department’s established procedures.
23. Acknowledge that failure to comply with terms and conditions established in the department’s Compliance Policy and any regulations shall constitute grounds for appropriate action, up to and including termination of the grower license and expulsion from the department’s program.
24. Acknowledge that a person who has been expelled from the program shall not be eligible to reapply to the program for a period of five (5) years from the date of expulsion.
25. Have read and understood the state and federal statutes and the department’s Compliance Policy and any regulations related to the conditional grower license that is being issued.
26. Understand the Commissioner shall revoke or terminate any conditional grower license, if the applicant’s or conditional licensee’s, (including signing authority and on-site manager) results do not meet the federal and state criminal history records check, or the requirements of the federal act, the Public Act and the Compliance Policy.

Yes. Hemp and marijuana are varieties of the cannabis plant that are differentiated based on selective breeding. Hemp is bred for its fiber and seed oil. By both federal and state law, hemp cannot contain more than 0.3% THC on a dry weight basis. THC is delta-9 tetrahydrocannabinol and is the psychoactive component of marijuana. Marijuana is defined as cannabis that contains greater than 0.3% THC on a dry weight basis. Marijuana remains a Schedule I controlled substance. Schedule I controlled substances are subject to the most intense scrutiny by the DEA. In Connecticut, the Connecticut Department of Agriculture regulates hemp cultivation. Under the U.S. Farm Bill and Connecticut’s Pilot Program, institutions of higher education like UConn have latitude to cultivate and research industrial hemp, including its constituent compounds, without a DEA Schedule I license.

UConn researchers should obtain certified hemp seed only from an agency authorized under the laws of a state, territory, or possession of the United States to officially certify hemp seeds and that has standards and procedures approved by the U.S. Secretary of Agriculture to assure the genetic purity and identity of the hemp seed certified. The seed must have a certificate or other instrument attesting to its genetic purity and identity.

A qualified yes. CBD and other materials derived from Hemp that contain a THC concentration of less than 0.3% on a dry weight basis are not subject to the Controlled Substances Act if the materials are cultivated and processed pursuant to the U.S. Farm Bill and the Pilot Program. In addition, the sourcing party must be properly licensed (for cultivation/processing) with the state’s proper licensing authorities. Please contact HempProgram@uconn.edu before undertaking such research. They can alert researchers to any issues that may exist with sourcing and licensing requirements.

Only hemp, CBD, and other hemp derivatives that can be traced back to lawfully cultivated Industrial Hemp through proper documentation can be used for research. You should only procure hemp and hemp derivatives from vendors that can provide such documentation. A copy of such documentation must be retained by the researcher. CBD or hemp derived from Industrial Hemp does not require a Connecticut State Hemp License or a DEA Controlled Substance License. However, CBD or hemp that is NOT derived from Industrial Hemp or that you DO NOT have documentation as being derived from Industrial Hemp is considered a Schedule 1 Controlled Substance. Possession of a Schedule 1 Controlled Substance is illegal unless you hold the appropriate State and Federal DEA licensure.

A qualified yes. Hemp materials and products (other than viable seeds) that contain a THC concentration of less than 0.3% on a dry weight basis are not subject to the Controlled Substances Act <em>if</em> the materials and products are cultivated pursuant to the U.S. Farm Bill and the Pilot Program. In addition, the third party must be properly licensed with a State Department of Agriculture’s Industrial Hemp Pilot Program, and its activities must have a research purpose. Thus, a researcher is permitted to receive and perform research on such materials and products from parties with which it enters collaborative research-focused agreements.

No. Marijuana research is defined as research that involves the growth, production, procurement, administration, or use of marijuana. It does not refer to observational research for which the researcher does not grow, produce, procure, or administer marijuana. Marijuana has the same meaning as in the definition provided by Connecticut General Statues § 21a-240(29).

Marijuana is categorized as a Schedule I drug by the DEA under the federal Controlled Substances Act. This means that federal regulations do not permit the use, production, processing, sale, or growth of marijuana, except for medical or research use <strong>conducted under special licensing requirements established by the DEA</strong> and the U.S. Food and Drug Administration (“FDA”) for use with humans or animals. Typically, research conducted under a DEA license also requires sourcing the marijuana from the NIDA. The U.S. Department of Justice’s (“DoJ”) previous guidance indicating that it will not focus its prosecutorial resources on the sale or use of marijuana in states where a well-regulated legal framework has been established was rescinded in 2018. To date, no exemption from the federal regulations has been granted to any state.

UConn is the recipient of considerable federal funding for research, education, capital projects, and healthcare. Accepting this funding obligates UConn to comply with the Drug-Free Schools and Communities Act and the Drug-Free Workplace Act. These federal regulations together prohibit UConn from unlawful manufacture, distribution, dispensing, possession, or use of any controlled substance at the University. Unlike the DoJ’s stance on enforcement of DEA regulations, there has been no statement suggesting that enforcement of the Drug-Free Schools and Communities Act or the Drug-Free Workplace Act has been, or will be, relaxed.

Consequently, despite the state of Connecticut’s legalization of medical marijuana, there is no provision that allows for the legal research of medical marijuana except as already established and involving compliance with DEA, FDA, and NIDA policies and regulations.

The UConn Center for Environmental Sciences and Engineering conducts testing as part of the Hemp Research Pilot Program. Additional information can be found on the <a href="https://cese.uconn.edu/hemp-initiative/" rel="noopener" target="_blank">Center for Environmental Sciences and Engineering web site</a> or by contacting the Center for Environmental Sciences and Engineering Laboratory Director, Christopher Perkins by either email (christopher.perkins@uconn.edu) or phone (860.486.2668).

START Preliminary Proof of Concept Fund

Posted on September 13, 2019 by Jessica McBride

Dear Colleagues,

Through a generous grant provided by the CTNext Higher Education Fund last year, the Office of the Vice President for Research (OVPR) has been administering an early stage translational research funding program called the START Preliminary Proof of Concept (PPOC) Fund. Under the grant, funding is provided to investigators at Central Connecticut State University (CCSU), Southern Connecticut State University (SCSU), University of Bridgeport (UB), and UConn on a competitive basis.

The START program aims to support the preliminary validation of innovative early stage technologies that have possible commercial potential and is designed to advance those technologies to be more attractive for additional funding. Proposals for the START PPOC Fund are welcomed from across all disciplines for early stage projects that may one day result in inventions and technologies that address unmet needs and have potential for commercial application.

As we wrap up the first year on funding, I would like to take a moment to recognize recipients from these institutions and ask that you join me in congratulating them on their efforts to commercialize technologies developed in the course of their academic research. For a full list of recipients and project information, visit the OVPR website.

For more information about the competition, visit the program website.

Thank you for helping to foster the culture of excellence in your schools/colleges, departments, and centers that allows UConn faculty to engage in research, scholarship, and creative activities at the highest levels.

Cheers,

Radenka

Celebrating UConn Research, Scholarship, and Creative Activities

Posted on September 9, 2019February 16, 2021 by Jessica McBride

As we begin a new semester at UConn, I would like to reflect on our past academic year and share with you the excitement, successes, and progress we made in that time. As a public research university that engages globally in the creation of new knowledge, we measure our success by the impact of our scholarly and educational outcomes, research, innovation, and the creative work of our students and faculty. In the last few years, we have brought people together around shared goals across campuses and disciplines, an accomplishment that is palpable at UConn and has been critical to the success of our land-grant mission.

Our three consecutive years of growth in total awards have borne out the value of our collective efforts.

Thanks to the tireless work of our faculty, postdocs, students, and staff, our new extramural awards for FY19 reached a three-year high of $266.2M. In FY17, our total new awards were $184.5M and in FY18, they were $258M. UConn Health received over $100M in new awards this past fiscal year reaching an all-time high. Our combined efforts represent a 44% increase over three years. We also saw upward trends in our entrepreneurship and innovation ecosystem, with a record 39 high-potential startup companies joining UConn’s Technology Incubation Program, and a ranking of 93rd worldwide in the number of US patents issued for UConn inventions. It is a matter of great satisfaction for me to have helped position entrepreneurship and innovation as an equal mission for our faculty alongside teaching, scholarship, research and creative work.

Our committed focus on seed funding, proof of concept grants, and awards to support the arts and humanities has contributed to STEM and non-STEM excellence. In FY19, our office contributed $2.3M to internal funding programs and an additional $100K to support grant writing workshops and resources. We are thrilled to see engagement, collaboration, and distinction from all areas of the University, whether it be STEM, non-STEM, or a collaborative hybrid, and that these combined efforts are producing growth in research and extramural awards.

I would like to highlight a few new initiatives launched by the OVPR in FY19 that supported faculty success:

Convergence Awards for Research in Interdisciplinary Centers (CARIC): Support development of collaborative interdisciplinary teams to bid for major (>$5M) federally funded initiatives, such as research centers.
Support of UConn Human Rights Institute with two postdoctoral fellowships in collaboration with the Schools of Engineering and Business.
Program in Accelerated Therapeutics for Healthcare (PATH): In partnership with the Schools of Pharmacy and Medicine, aims to accelerate the translational pathway to convert discoveries into new medical therapeutics. The program seeks to quickly develop novel approaches focusing on well validated molecular targets for a specific disease area with an unmet treatment need in the current commercial marketplace.
Scholarship and Collaboration in Humanities and Arts Research Program (SCHARP): In partnership with the Humanities Institute, SCHARP supports innovative works in scholarship and creative activities in the arts and humanities that have the potential to transform a field of study, impact the common good, or chart a new direction in scholarly, creative, or artistic direction.
STEAM Innovation Grant: In partnership with the School of Fine Arts, STEAM encourages innovative collaborations between the arts and STEM disciplines. Projects funded by this grant may result in publications, exhibitions, performances, academic symposia, or other research outcomes.
Stamford Innovate, a new internship program that connects talented UConn students with opportunities in startups in one of the fastest growing regions of the state.

If you want to learn more, click here for a full list of our internal funding programs.

As educators, we all take great pride in our students’ successes, and I wanted to take a moment to recognize some new student projects that are truly remarkable. In collaboration with the Office of the Provost, the OVPR supported a student-led podcast called In Vivo. With regular interviews about science, the arts, current events, and other topics, In Vivo highlights the amazing faculty, students, and staff that give UConn life. The show is conducted out of UConn’s WHUS studio and is run entirely by UConn students. Check it out and consider subscribing for future episodes to learn more about UConn researchers.

Another new initiative is World Poetry Books to support its mission of publishing and vigorously promoting a minimum of six books of exceptional poetry in translation each year. This support offers our students the opportunity to gain hands-on, professional publishing skills, and establishes UConn as home of a preeminent publisher of exceptional world literature.

While sharing accomplishments is important, we also want to increase transparency and continue to maintain open lines of communication as we push to raise UConn’s research profile. In addition to sharing research and tech transfer metrics on the recently revamped UConn Research website, we encourage faculty and staff to reach out with suggestions regarding new opportunities and unmet needs. It is only together – as a team – that we will continue to drive the growth of scholarship, research, and creative pursuits at UConn.

I’d like to conclude with a personal note of gratitude. I cannot thank all of you enough for giving me the opportunity to work with so many talented, hardworking, and committed colleagues. To my staff, I am deeply honored to serve as VPR and grateful for your support, continued improvement, and service to our faculty and students. At the end of a hard day, I find great inspiration in the knowledge that UConn’s faculty and staff – whether they be musicians, chemists, or scholars of law or other disciplines – are some of the world’s most innovative and active researchers. Thank you for making UConn a special place with a vibrant community of caring, collaborative people.

We are opening a new chapter for UConn with a new President who is focused on our excellence, strengths, and new opportunities. I look forward to this journey with all of you, and please remember my door is always open!

Cheers,

Dr. Radenka Maric

Vice President for Research, UConn/UConn Health

Faculty Affiliated Companies / External Entities

What is the purpose of this page?

Assistance with identifying University requirements, policies, guidance, and procedures, including State Code of Ethics laws, related to faculty affiliated companies /external entities

Who should review this information?

Faculty, staff, and students who hold a financial interest in, or conduct University activities with, a faculty affiliated company /external entity.

Why is this important?

Perceived or real conflicts may arise between University activities and activities of faculty affiliated companies /external entities. The University of Connecticut, its Regional Campuses and UConn Health (the University) are committed to fostering the entrepreneurial activities of its faculty and staff, in addition to its core missions of teaching, research and service. Consistent with its mission, the University encourages translational research, innovation and entrepreneurial activities. The University also is dedicated to ensuring transparency and compliance with University policy and State and Federal regulations.

Is everything I need to know here?

These pages are not an all-encompassing list of requirements, and members of the University community are expected to know and comply with all applicable University policies, and State and Federal regulations. In some cases, federal law and regulation will be stricter than State ethics laws and UConn policy, and such applicable portions of federal law will take precedence, while other aspects of State or University policy will remain in force. The federal and state regulations that govern these areas are complicated and these pages do not cover every situation that may need to be addressed. Therefore, the University recommends faculty, staff and students seek expert guidance in addition to adhering to the provided guidelines.

Who do I contact for more information?

The information available within these pages is also summarized in a Guidelines for Faculty, Staff, and Students who are affiliated with a Company document. The University strongly encourages any University employee affiliated with a company or acting as a consultant for a faculty affiliated company to seek advice from the Office of the Vice President for Research, the Provost’s Office, the State Ethics Liaison, and the Procurement Services group. The Office of University Compliance is also available to assist with questions relevant to University policies or State and Federal regulations.

Use of University Resources

Requests from faculty affiliated companies / external entities for access to, and/or use of, University research lab space or equipment are addressed within the guidance for Use of Research Space or Equipment by External Entities

This guidance provides consistency to the handling of these requests and ensures that the institution is informed and approves of such access. These steps ensure research space and equipment remains committed to the research mission of the institution.

Questions related to this guidance can be directed to the Associate Deans for Research for School of Medicine or School of Dental Medicine. Questions can also be directed to the Associate Vice President for Research Integrity and Regulatory Affairs or Assistant Vice President for Research Finance in the Office of the Vice President for Research.

SBIR and STTR

Various federal agencies provide funding to small businesses to conduct research and development with the goal of commercializing technology. This federal funding occurs via two different award mechanisms:

Small Business Innovation Research (“SBIR”)
Small Business Technology Transfer (“STTR”)

Both SBIR and STTR awards are made directly to a small business concern (“SBC”). A SBC is a for-profit company that is the applicant for a SBIR/STTR award. In this section of the guidance, we use the terms SBC and company interchangeably.

STTRs require that the SBC collaborate with a research institution (“RI”) for a certain portion of the award. SBIRs do not require RI involvement, but SBCs often collaborate with RIs on SBIRs. A RI is the research institution partner, such as UConn, that collaborates with an SBC for a SBIR/STTR award through a subcontract/subaward under the SBC.

UConn meets the criteria to serve as a RI for SBIRs and STTRs. UConn’s involvement in either a SBIR or a STTR occurs when it is either included in the proposal or the federal sponsor has provided approval to SBC to engage with the university and is awarded via a subcontract/subaward from the SBC to the university. In cases where there is a collaboration/subcontract/subaward between the SBC and the RI, there is an SBC PI and an RI PI (i.e. a PI for each side of the collaboration).

Requirements for SBIRs and STTRs

SBIR

Applicability	Eligibility Requirements
SBC	Must be an American-owned business Must be independently operated Must be a for-profit business Must have five hundred or fewer employees If sub-contract with another party, or with multiple parties: SBC must do at least two-thirds of research during Phase I; SBC must do at least one-half of research during Phase II
SBC PI	Must be primarily employed with SBC
RI	Involvement of RI not required If the SBC subcontracts with RI: RI may conduct up to one-third of research during Phase I; RI may do up to one-half of research during Phase II

STTR

Applicability	Eligibility Requirements
SBC	Must be an American-owned business Must be independently operated Must be a for-profit business Must have five hundred or fewer employees Not less than 40% of the research/research development must be performed by SBC
SBC PI	Must be primarily employed by either the SBC or the collaborating RI
RI	Research Institution collaborator required Must be one of the following: A non-profit college or university; A domestic non-profit research organization; or A federally funded Research and Development Center RI required to conduct at least 30% of research and development but may conduct up to 60% of research and development

SBC Use of University Space

Small businesses certify in their SBIR and STTR applications and award documents to the federal government that the SBC research and development will occur in SBC facilities using company employees unless otherwise indicated in the SBIR or STTR application and approved in the funding agreement. Therefore, performing the SBC portion of such research in University space using University resources — unless specifically approved by the funding agency and allowed by the University – subjects the company to potential criminal, civil, or administrative sanctions.

Consulting for a Faculty Affiliated Company

As a general rule, if the faculty affiliated company is sponsoring research at UConn under an SBIR or STTR, the faculty member should not be paid as a consultant under the award.

The Same Individual Serving as University PI and SBC PI

For SBIR awards, the SBC PI must be primarily employed by the company. Most faculty members are fully employed by UConn and therefore cannot serve as the PI for an SBC. To serve as PI for a SBC, the faculty member cannot have a University position or appointment of greater than 49%.

For STTR awards, the PI named on the award may be primarily employed by either the company or the University. The exception is for NSF STTR awards, in which the PI named on the award must be primarily employed by the SBC.

For the work conducted for both SBIR and STTR awards, the SBC PI and the RI PI may not be the same individual. While not explicitly stated, the STTR/SBIR policy, instructions, and project percentage requirements make clear that establishing a separation of entities and roles is important. Having the same person on both sides of the collaboration blurs the respective parties’ project roles, responsibilities and effort/time commitments.

Specific sponsor policies or requirements may differ and be more restrictive. For example, the NSF guidance states that no person who is an equity holder, employee, or officer of the proposing small business may (1) be paid as a consultant, or (2) be paid through a subaward budget, in either case, unless recommended and approved by the NSF.

Faculty members that have an interest in an SBC must read all sponsor requirements for SBIR/STTR proposals and awards carefully and note what situations may be prohibited or that may require advance sponsor approval. It is strongly recommended that the SBC engage counsel to review and advice on the grant awards, and hire accountants with specific expertise in SBIRs and STTRs.

Management of Faculty Affiliated Company Grants

The faculty affiliated company/external entity is responsible for all grant administration relating to company grants, including SBIR and STTR grants. The faculty affiliated company/external entity should seek professional advice on appropriate grant management and administration.

Federal and Sponsor Specific Guidance

The US Small Business Administration provides guidance to small businesses wishing to pursue SBIR or STTR funding opportunities. Their website includes general information as well as links to individual federal sponsor programs. Sponsors may have additional guidelines or restrictions and those small businesses seeking to pursue a SBIR or STTR project should be careful to thoroughly review guidelines and restrictions.

Purchasing Goods or Services

In general, State ethics laws prohibit faculty affiliated companies from selling goods or services to the University unless the company is awarded a contract through a public competitive procurement process. A UConn employee holding an interest in a faculty affiliated company / external entity should contact Procurement Services and Sponsored Programs Services if the company would like to sell goods or services to UConn. Procurement Services will work with the appropriate departments to determine whether the sale would comply with State ethics laws and, if applicable, purchasing laws and regulations. If public competitive procurement is required, the UConn employee should play no role in the process (such as writing specifications for the good or service) and should not discuss the process with any UConn employee involved.

In addition, some research sponsors require advance notice or disclosure prior to purchasing goods and services from a faculty affiliated company. Sponsored Program Services must be contacted if there is a request or intent to purchase equipment or services from a company in which a faculty member on the award has significant financial interests to determine if prior approval from the sponsor or other steps are required.

Purchase and Use of Goods and Services from a Faculty Affiliated Company

Faculty affiliated companies /external entities (“the Company”) must comply with all state ethics obligations if and when the Company transacts business with the University or State of Connecticut. For University employees who have an interest with a faculty affiliated company/external entity, the following obligations are worthy of particular note:

An individual with an interest in the Company may not participate in any procurement or contracting in which the University may buy products or services made or provided by the Company.
Unless an exception is granted by the Vice President for Research or designee, an individual with an interest in the Company may not participate in any subawarding process in which the University may subaward funds to the Company. For additional information about subawards to/from faculty affiliated companies, please see Subawards and Subcontracts page.
The Company may be barred from a transaction if a University employee with an affiliation with the Company is privy to information that is not available to other companies and that would provide the Company with a competitive advantage over other companies.
The Company is generally only permitted to sell goods or services to the University or the State through an open and public process. For example, the Company is generally not permitted to sell “sole source” goods or services to the University or the State. The Office of University Compliance must be contacted prior to any such sale to determine whether the sale would comply with state law.

Obtaining and Moving Materials to/from a Faculty Affiliated Company

If a University employee obtains materials from the Company for their University research, Sponsored Program Services should be contacted for consideration of whether a Materials Transfer Agreement (MTA) is necessary.
If a University employee plans to move materials from their University laboratory to the Company, Technology Transfer and Venture Development should be contacted for an MTA.

Who is the primary UConn point of contact for external relations issues and requests related to hemp and marijuana?

How do I register through the University in order to participate in the state program?

Can I grow or process hemp, or engage in manufacturing with hemp at UConn without registering?

Can I have a personal hemp plant in my dorm room, office, or other location?

Where can I find information regarding the Connecticut Hemp Research Pilot Program?

Once the state has issued a license, what am I required to do as the project principle investigator?

How should UConn researchers dispose of unwanted industrial hemp materials?

What is the definition of industrial hemp?

Is hemp different from marijuana?

Does hemp include extracts that include cannabidiol or other cannabinoids?

Can UConn researchers do hemp research under a DEA Schedule I registration?

Can UConn researchers grow industrial hemp for research purposes?

Where can UConn researchers obtain certified seed to grow hemp for research purposes?

Can UConn researchers obtain CBD (Cannabidiol) for research purposes?

I only want to purchase CBD (cannabidiol) or hemp for use in my research, not grow or process hemp. Are there any specific requirements?

Can UConn researchers obtain hemp products from third parties for research purposes?

Can UConn researchers perform hemp research funded by third party industries?

Can UConn researchers perform hemp research in a paid or unpaid sabbatical situation in a foreign country whose laws permit industrial hemp research in any capacity?

Can UConn researchers license intellectual property rights resulting from hemp research?

Does the Connecticut Hemp Research Pilot Program allow research with marijuana?

Where can I find information about courses or programs at UConn related to hemp?

Is anyone at UConn involved in testing as part of the state Hemp Research Pilot Program?