- Overview
- CO Checklists
- FAQ
- What is SBIR Phase III?
- Phase I/II required?
- Dollar/time limits?
- What funds?
- Competition required?
- J&A required?
- Synopsis required?
- Collaboration allowed?
- Professional services?
- Sole deliverable?
- Personal services?
- Data rights received?
- Government compete?
- Who owns outputs?
- Form, fit, function?
- Modification limits?
- Extend period?
- Quick Reference Cards
- Contact Information
- Acronym Glossary
Resources & Tools
Quick reference materials including glossary, acronym dictionary, checklists, templates, FAQ, and contact information.
Contracting Officer Checklists
Pre-Award Checklist
Requirements Validation
- PWS complete and approved
- Performance standards defined
- Deliverables clearly specified
- QASP developed
SBIR Phase III Verification
- Contractor received Phase I award (contract number verified)
- Logical connection narrative documented
- Work derives from/extends/completes Phase I
- Administrative record complete
Acquisition Planning
- Acquisition plan (ISTRAP) complete
- IGCE developed and reasonable
- Funding identified and available
- Contract type justified
- Risk assessment complete
Legal/Policy Compliance
- SBIR data rights provisions included (DFARS 252.227-7018)
- Not inherently governmental functions
- Not personal services
- OCI assessed and mitigated
- Small business status verified
- Foreign participation restrictions addressed
Documentation
- Memorandum for file (J&A exception) prepared
- D&F for cost-reimbursement (if applicable)
- All approvals obtained
Award Checklist
- RFP issued or unsolicited proposal received
- Proposal evaluated
- Cost/price analysis complete
- Past performance evaluated
- Negotiations complete (if needed)
- Contract document prepared
- 15 U.S.C. §638(r)(4) cited in contract
- SBIR data rights clauses included (DFARS 252.227-7018)
- Funding certified
- Award approval obtained
- Contract executed
- Contractor notified
- COR designated
Post-Award Checklist
- Post-award orientation conducted
- COR trained and designated
- QASP activated
- Invoice procedures established
- Performance monitoring initiated
- Contractor access to systems granted
- Security training completed
Closeout Checklist
- All deliverables received and accepted
- Final invoice processed
- Cost reconciliation complete (CPFF)
- Final CPARS submitted
- Lessons learned documented
- Contract file archived
- Contract closed in system
Frequently Asked Questions
Q: What is SBIR Phase III?
A: Work that derives from, extends, or completes efforts made under prior SBIR funding agreements. Can include products, services, or any combination thereof.
Q: Is Phase I or II completion required for Phase III?
A: No. Phase III authority exists upon Phase I or II award, not completion. This enables rapid technology transition.
Q: Are there dollar or time limits on Phase III contracts?
A: No. SBA Policy Directive Section 4(c) confirms no dollar limit, duration limit, or contract type restriction.
Q: What funds are used for Phase III?
A: Program funds (e.g., O&M, Procurement, RDT&E), not SBIR set-aside funds.
Q: Is competition required for Phase III?
A: No. 15 U.S.C. §638(r)(4) provides statutory authority for sole-source awards.
Q: Is a formal J&A required?
A: No. SBA Policy Directive Section 4(c)(3) states "Further justification is not needed." Only require memorandum for file documenting SBIR connection.
Q: Is synopsis in SAM.gov required?
A: No. Phase III awards exempt from synopsis per SBA Policy Directive Section 2(j)(4)(iii).
Q: Can we collaborate with the SBIR contractor on requirements?
A: Generally yes. Since awardee is pre-determined by statute, collaboration unlikely to create OCI. Contracting officer retains discretion.
Q: Do professional services qualify for Phase III?
A: Yes. Statute explicitly includes "services" and GAO confirmed in Digital Force Technologies (2025) that SBIR technology can enable service delivery.
Q: Must the SBIR technology be the sole deliverable?
A: No. GAO confirmed "no requirement that the entirety of a phase III solution must be derived from prior SBIR efforts." SBIR component can enable broader solution.
Q: Does this create personal services?
A: Not if properly structured. Contract must be performance-based with deliverable focus, contractor retains control over employees, and no employer-employee relationship exists.
Q: What data rights does government receive?
A: SBIR Data Rights (limited rights) for 20 years, then Government Purpose Rights thereafter.
Q: Can government compete the technology?
A: Not during 20-year protection period without contractor permission. After 20 years, yes with Government Purpose Rights.
Q: Who owns the analytical outputs and reports?
A: Government owns with unlimited rights. SBIR protects the tools, not the data generated using the tools.
Q: What is form, fit, and function data?
A: External interface specifications and functional requirements. Not protected by SBIR - government gets unlimited rights.
Q: Are there limits on modification value?
A: No statutory limits, but must have funding available and be within general contract scope.
Q: Can we extend period of performance?
A: Yes, without limit, subject to funding and contracting officer discretion.
Quick Reference Cards
Phase III Eligibility
✅ Requirements:
- • Contractor received Phase I or II award
- • Work derives from/extends/completes SBIR effort
- • Logical connection documented
✅ No Requirements:
- • Phase I/II completion
- • Formal J&A
- • Synopsis in SAM.gov
- • Dollar or time limits
Data Rights Quick Guide
🔒 20-Year Protection:
- • Technical data
- • Computer software
- • Source code and algorithms
✓ Unlimited Rights:
- • Form, fit, function
- • Work products/reports
- • Non-technical data
- • Government-provided data
Modification Authority
✅ No J&A Needed:
- • Scope changes
- • Ceiling increases
- • Period extensions
- • New capabilities
📋 Still Required:
- • Funding availability
- • Within general scope
- • CO approval
- • Proper documentation
Contact Information
Navaide
Company Information
UEI: HZCDXJV7M8Z9
CAGE Code: 7M3J9
Business Type
Important Notice
This guide provides general information on SBIR Phase III contracting procedures. All contract awards are entirely subject to the discretion and determination of the assigned contracting officer. The contracting officer's decisions, interpretations, and requirements supersede any content in this guide. This document does not create any contractual rights, obligations, or entitlements.
Quick Links by User Type
For Contracting Officers:
For Technical Teams:
For Program Management:
Acronym Dictionary
| Acronym | Definition |
|---|---|
| SBIR | Small Business Innovation Research |
| DASN(P) | Deputy Assistant Secretary of the Navy for Procurement |
| AI-DDSF | AI-Driven Decision Support Framework |
| CDAO | Chief Digital and Artificial Intelligence Office |
| PWS | Performance Work Statement |
| FAR | Federal Acquisition Regulation |
| DFARS | Defense Federal Acquisition Regulation Supplement |
| NMCARS | Navy Marine Corps Acquisition Regulation Supplement |
| GAO | Government Accountability Office |
| SBA | Small Business Administration |
| LOB | Line of Business |
| DITPR-DON | DoD IT Portfolio Repository - Department of the Navy |
| PBIS-IT | Portfolio Business Intelligence System - IT |
| SNaP-IT | System Nomination and Portfolio - IT |
| DITIP | DoD IT Investment Portfolio |
| DBS | Defense Business System |
| OEP | Organizational Execution Plan |
| IRBWG | Investment Review Board Working Group |
| BEA | Business Enterprise Architecture |
| EA | Enterprise Architecture |
| COR | Contracting Officer's Representative |
| KO | Contracting Officer |
| PCO | Procuring Contracting Officer |
| ACO | Administrative Contracting Officer |
| QASP | Quality Assurance Surveillance Plan |
| CPARS | Contract Performance Assessment Reporting System |
| FFP | Firm-Fixed-Price |
| CPFF | Cost-Plus-Fixed-Fee |
| ODC | Other Direct Costs |
| FTR | Federal Travel Regulation |
| IGCE | Independent Government Cost Estimate |
| ISTRAP | Integrated Strategic Acquisition Plan |
| J&A | Justification and Approval |
| OCI | Organizational Conflict of Interest |
| CUI | Controlled Unclassified Information |
| NIST | National Institute of Standards and Technology |
| DCAA | Defense Contract Audit Agency |
| CAS | Cost Accounting Standards |
| FPDS | Federal Procurement Data System |
| eSRS | Electronic Subcontracting Reporting System |
| RPA | Robotic Process Automation |
| ETL | Extract, Transform, Load |
| COTS | Commercial Off-The-Shelf |
| GOTS | Government Off-The-Shelf |
| ATO | Authority to Operate |
| FOIA | Freedom of Information Act |
| WAWF | Wide Area Workflow |
| DoDAF | DoD Architecture Framework |
| PMO | Program Management Office |
| HCA | Head of Contracting Activity |
| ASN(RD&A) | Assistant Secretary of the Navy for Research, Development & Acquisition |
| DON | Department of the Navy |
| DoD | Department of Defense |
| OSD | Office of the Secretary of Defense |
| NDAA | National Defense Authorization Act |