• OMB: Proposed rule would let agencies cancel any grant. Comments close July 13.

• NIH: SBIR reopens with higher ceilings and three new programs. Deadline September 8.

• NSF + ARPA-H: $250M at NSF with a $40M instrumentation carve-out; ARPA-H summaries due July 10.

• NIH policy: A proposed cap on grants per investigator could shift billions toward newer PIs.

• AI for science: Co-Scientist and Claude Science move AI from the chat window into the lab.

• The foreign risk self-audit: The pre-submission check for the screening you can’t appeal.

🗓️ Funding & Connection Opportunities Round-Up

OMB wants authority to cancel any federal grant

What: The Office of Management and Budget (OMB) published a proposed rule (Federal Register, May 29) that would make peer review advisory, let any agency cancel any grant under a “national interest” justification, restrict international collaboration, and require pre-approval for publication costs and conference travel. Proposed effective date: October 1, 2026.

So what: This is a proposal, not policy. But if finalized as written, the cancellation clause changes the risk math for any company built on federal awards.

Do: Comments close July 13. If you hold or plan federal awards, read the rule and file a comment.

Source: Federal Register | Submit a comment

NIH reopens SBIR with higher ceilings and three new programs

What: NIH’s Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) funding opportunities are open with a September 8 deadline. Several institutes raised ceilings to $700K for Phase I and $3M for Phase II. New: a Commercialization Readiness Pilot, a Phase IIB Strategic Breakthrough Award, and a forecasted Transition Grant for New Entrepreneurs.

So what: The strongest NIH SBIR cycle in years. Ceilings vary by institute, so check yours before you budget.

Do: Check your institute’s award levels at seed.nih.gov and start program officer outreach now. If this is your first NIH SBIR, target September, not January: September feedback arrives in time to revise for January. Wait, and your first feedback lands mid-2027.

Source: NIH Seed Fund

NSF returns with $250M, including $40M for scientific instrumentation

What: NSF reopened SBIR/STTR (solicitations 26-510 and 26-511) with $250M. Phase I runs up to $305K, and a Project Pitch is required before a full proposal; the first deadline is July 27. NSF 26-511 sets aside $40M specifically for scientific instrumentation. Separately, the Advanced Research Projects Agency for Health (ARPA-H) runs its own SBIR program (7 healthcare topics, Phase I up to $600K), taking solution summaries through July 10, a tight window if you’re starting now; the BAA is worth knowing for its next cycle either way.

So what: The instrumentation carve-out is the kind of set-aside most founders never hear about. And both programs use low-effort first gates: a pitch or a summary, not a full proposal.

Do: If you build instruments, read 26-511 before July 27. Healthcare tech: get an ARPA-H solution summary in by July 10.

Source: NSF 26-510 | NSF 26-511 | ARPA-H SBIR

NIH proposes a cap on how many grants one investigator can hold

What: Notice NOT-OD-26-086 proposes capping simultaneous research project grants per investigator at 2, 3, or 4. NIH’s own figures: a cap of 2 would free $3.53B, enough to support 5,230 additional investigators. In FY2025, 10.7% of principal investigators (PIs) held three or more.

So what: Redistribution generally favors newer, smaller applicants, which is most of this audience. The open question: whether SBIR awards (R43/R44) count toward the cap.

Do: Comments are due August 3. Newer investigators have a stake worth a comment; multi-award founders should watch the mechanism question.

Source: NIH Notice NOT-OD-26-086

Google and Anthropic ship AI built for the lab, not the chat window

What: Google DeepMind published Co-Scientist in Nature, a multi-agent system for hypothesis generation. Anthropic released Claude Science, a desktop research environment: local Python/R sessions, connections to 60+ scientific databases, and reproducibility built in. Every output keeps the code and environment that made it, and a background agent flags uncited claims.

So what: Two practical angles for grant-funded teams. Reproducibility pays at Phase II, when you extend results you can rerun instead of rebuilding a year-old analysis. And local compute matters when your data is proprietary or your contract says it stays in-house. Disclosure is the open question: NIH’s current AI policy (NOT-OD-25-132) covers writing, not research design.

Do: Trial one tool on a non-critical task, and start a simple log of how you use AI in your research before any agency asks for it.

Source: Co-Scientist (Nature) | Claude Science

Also on your calendar

• NIH “Small Business 101” webinars - Building Your Budget (Jul 14, 1:30pm ET); Managing Foreign Risk (Aug 18, 1:30pm ET). Registration via seed.nih.gov.

• Comment deadlines - OMB rule: Jul 13. NIH grant-cap proposal: Aug 3.

One thread connects the OMB proposal and NIH’s August webinar topic: federal funders are tightening on foreign ties. Which brings us to this week’s checklist.

✅ The foreign risk self-audit: run it before DHHS does.

The situation

A biomedical founder described their case on r/SBIR in June: a Commercialization Readiness Pilot application at NIGMS (NIH’s institute for general medical sciences), following a completed Phase I, II, and IIB on the same technology. Every employee, investor, and vendor is a US person or US company. The proposal scored well. It was rejected on the foreign risk assessment, with no explanation of what triggered the finding and no appeal.

Why this matters

Since FY23, every NIH small-business applicant files a required foreign disclosure (NOT-OD-23-139), on a form developed by the Small Business Administration under a congressional mandate. Most founders treat it as paperwork. But the assessment behind it runs at the Department of Health and Human Services (DHHS) level, not at NIH, and the evaluation criteria are not published.

Founders report that rejections arrive without explanation and can’t be fixed mid-cycle: the only path is resubmitting next round. The reports include companies whose flagged staff are US-trained scientists on green cards.

What’s changed: reports of well-scored proposals failing this screen are accumulating, and not just on founder forums. Wisconsin’s SBIR support center documented the same pattern last August: applications that scored well enough to fund, rejected at the Just-in-Time stage. NIH has since extended the requirements to active awards (NOT-OD-25-102), and the OMB proposal above points in the same direction, toward more scrutiny of foreign ties, not less. NIH has reportedly told grant firms that more specific feedback starts with the September cycle. That would help, but it isn’t confirmed, and it won’t restore a lost cycle.

The framework

One thing to be straight about: DHHS does not publish its criteria. So this audit has two layers. The disclosure requirements come from the official form and NIH’s guidance. The reported triggers are the risk surface founders and grant firms describe from experience: a map drawn from other founders’ rejections, not a regulation. Both layers are worth checking; only the first is official. The statute behind the program (the SBIR and STTR Extension Act of 2022) names what gets assessed: cybersecurity practices, patent analysis, employee analysis, and foreign ownership including financial ties. The steps below turn that scope into checks you can run yourself.

1. Start from the official disclosure requirements

• What to do: Read NIH’s foreign disclosure and risk management page and the required disclosure form before anything else.

• Why it matters: The form defines what you must disclose: covered individuals, foreign talent program affiliations, foreign ownership and support.

• Practical note: Disclosure is mandatory; the categories below are how you find what belongs on it.

2. Audit key personnel and covered individuals

• What to do: List everyone the government counts as key on the project. Confirm no affiliations with foreign talent recruitment programs.

• Why it matters: A covered individual tied to a flagged program is the clearest trigger in the official materials.

• Practical note: Reported: even employees not on the project draw questions about data access. Be ready to describe how project data is fenced.

3. Search publication histories (reported trigger)

• What to do: Search every named person’s co-authorships for institutions in China, Russia, Iran, or North Korea.

• Why it matters: Grant firms report old or incidental co-authorships tripping the screen, including ties applicants didn’t consider relevant.

• Practical note: There is no confirmed lookback window. Treat “it was years ago” as a thing to address, not a reason to skip it.

4. Ask your investors and check your vendors (reported triggers)

• What to do: Ask investors whether foreign money or ownership from countries of concern sits in their fund. Check the ownership of every vendor, subcontractor, and manufacturer on the budget.

• Why it matters: Community reports include flags from a US fund’s foreign backing and from foreign-owned vendors, even ones operating through US facilities.

• Practical note: Ask in writing and keep the answers on file. If a flag ever needs a mitigation plan, documented diligence is your starting point.

5. If anything surfaces, write a mitigation plan before you submit

• What to do: For each tie, document four things: what the relationship was, when and how it ended, the controls now in place (no ongoing contact, no travel to the country of concern, restricted data access), and who in the company verified it.

• Why it matters: Practitioners who work these cases advise getting ahead of the screen; there is no cure after it.

• Practical note: The honest limit of the reports: it isn’t confirmed where this document goes - submitted with the application, held on file, or provided if questions come. That question, plus anything ambiguous in your audit, is what you take to a research-security or compliance professional before you submit.

The checklist

Before your next NIH submission:

• Read the official foreign disclosure page and form (seed.nih.gov)

• List covered individuals; confirm no foreign talent program ties

• Search each person’s co-authorships for countries-of-concern institutions

• Check your patents for foreign co-inventors, assignees, or filings

• Ask each investor about foreign money or ownership in their fund

• Check ownership of every vendor, subcontractor, and manufacturer

• Know who can access project data; be ready to describe the controls

• Any flag found: write a mitigation plan before submitting

• Anything ambiguous: get professional research-security review

The case

A grant-writing firm described its experience on r/SBIR: a client rejected on foreign risk two years ago, with no recourse and no explanation. Their process since: search every contributor, from PI to lab assistant, for co-authorships with institutions in countries of concern before any submission, and write a mitigation plan whenever a tie appears. The lesson: they stopped trying to predict the screen and started assuming every tie needs an answer in writing.

One thing to do this week

Take the proposal you plan to submit September 8 and start with its most-published person. Pull their publication list (CV, ORCID, or Google Scholar profile) and scan the co-author affiliation lines for institutions in China, Russia, Iran, or North Korea. Expect about an hour for a long record. If anything surfaces, you have two months to prepare a mitigation plan, and you’ll have the method down for the rest of the team.

One boundary on all of this: a clean self-audit reduces surprises. It does not guarantee clearance, and none of this is legal advice. For ownership structures, export control, or personnel questions, use a qualified research-security or compliance professional.

If someone forwarded this to you…

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Till next time,

—Lana.

Commercialization Co-Founder

P.S. This edition runs heavy on warnings: cancellations, caps, screenings. So here’s the other half, plainly: these are the best NIH SBIR terms in years, three agencies are open at once, and most applicants will read none of the fine print above. The boring details are the edge.

Know a founder submitting to NIH on September 8? Forward this; the checklist could save them a cycle…

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• DOT: SBIR opens June 3, proposals due July 7.

• NSF: $1.5B X-Labs initiative for independent research teams.

• ARPA-H, Dept. of Ed, NSF pitches: June deadlines and status updates.

• NIH + NSF: New policies on AI use and citation integrity.

• Citation verification workflow: Three categories of reference errors, a step-by-step check, and current agency disclosure requirements.

🗓️ Funding & Connection Opportunities Round-Up

DOT SBIR opens June 3 - proposals due July 7

What: The Department of Transportation opened its FY26 SBIR pre-solicitation period, running through May 29. Full submissions are expected to open June 3, with proposals due July 7.

So what: DOT is one of the smaller SBIR agencies, with fewer applicants per topic and less competition than DoD or NIH. If your technology addresses transportation safety, infrastructure, autonomous vehicles, or mobility, it’s worth checking whether the topics align. The narrower topic set means fewer opportunities, but also a less crowded field.

Do: Review the pre-release topics. If there’s a fit, you have about five weeks from open to deadline. How to apply.

NSF launches $1.5B X-Labs for independent research teams

What: NSF announced X-Labs, a new initiative funding independent research organizations (not universities) with large, multiyear awards. The mechanism is Other Transactions Agreements, not standard grants. First topics: Scientific Instrumentation for Sensing and Imaging, and Quantum Systems (Interconnects and Integrated Photonics). Total commitment: up to $1.5B over the next decade, with additional topics expected in the coming weeks.

So what: This is a different model from SBIR. Bigger awards, longer timelines, milestone-driven, and designed for entrepreneurial teams pursuing platform-level scientific capabilities. If you’ve been building outside the university system and SBIR felt too small or too short for your work, X-Labs may be a better fit. The Sensing and Imaging topic is broad enough to cover a range of instrumentation approaches.

Do: Read the funding opportunity on SAM.gov and register for the introductory webinar at the NSF X-Labs page. Future topic announcements are expected soon.

May funding radar + a citation verification workflow for grant proposals.

Today’s edition: what agencies are saying about AI and citations, plus what’s new across DOT, NSF, NIH, and ARPA-H.

Lana Plotnikova

Read online Estimated Reading Time: 7 minutes

What’s Inside:

• DOT: SBIR opens June 3, proposals due July 7.

• NSF: $1.5B X-Labs initiative for independent research teams.

• ARPA-H, Dept. of Ed, NSF pitches: June deadlines and status updates.

• NIH + NSF: New policies on AI use and citation integrity.

• Citation verification workflow: Three categories of reference errors, a step-by-step check, and current agency disclosure requirements.

🗓️ Funding & Connection Opportunities Round-Up

DOT SBIR opens June 3 - proposals due July 7

What: The Department of Transportation opened its FY26 SBIR pre-solicitation period, running through May 29. Full submissions are expected to open June 3, with proposals due July 7.

So what: DOT is one of the smaller SBIR agencies, with fewer applicants per topic and less competition than DoD or NIH. If your technology addresses transportation safety, infrastructure, autonomous vehicles, or mobility, it’s worth checking whether the topics align. The narrower topic set means fewer opportunities, but also a less crowded field.

Do: Review the pre-release topics. If there’s a fit, you have about five weeks from open to deadline. How to apply.

NSF launches $1.5B X-Labs for independent research teams

What: NSF announced X-Labs, a new initiative funding independent research organizations (not universities) with large, multiyear awards. The mechanism is Other Transactions Agreements, not standard grants. First topics: Scientific Instrumentation for Sensing and Imaging, and Quantum Systems (Interconnects and Integrated Photonics). Total commitment: up to $1.5B over the next decade, with additional topics expected in the coming weeks.

So what: This is a different model from SBIR. Bigger awards, longer timelines, milestone-driven, and designed for entrepreneurial teams pursuing platform-level scientific capabilities. If you’ve been building outside the university system and SBIR felt too small or too short for your work, X-Labs may be a better fit. The Sensing and Imaging topic is broad enough to cover a range of instrumentation approaches.

Do: Read the funding opportunity on SAM.gov and register for the introductory webinar at the NSF X-Labs page. Future topic announcements are expected soon.

Also on your calendar

• ARPA-H has multiple programs with June deadlines. HEARING proposer day is June 8 (register by June 3 for in-person, June 5 for virtual), with solution summaries due June 29. IGoR solution summaries are due June 25. Full list at ARPA-H events and open funding opportunities.

• Dept. of Education SBIR - Phase IA and Phase IB proposals due June 29 (11am ET). Direct to Phase II also due June 29 (2pm ET). Ed-tech and learning science, $250K awards for 9 months. Solicitation info.

• NSF Project Pitches remain paused. As of May 18, NSF is not accepting new pitches. Both the new solicitation and the pitch window are expected “soon,” but no date has been given.

• Pipeline (no current deadlines): USDA Phase II expected fall 2026, Phase I early 2027. DHS new solicitation likely this summer. DOC-NIST Phase II September, Phase I early 2027. DOC-NOAA Phase I this fall. EPA Phase I this summer.

NIH and NSF update policies on AI use and citation integrity

What: NIH published official guidance on AI use in grant applications, with a focus on fabricated references. Their position: citations pointing to nonexistent papers can constitute data fabrication under research misconduct rules. Key statement: “Applications that are either substantially developed by AI or contain sections substantially developed by AI are not considered the original ideas of applicants and will not be considered by NIH.” NSF separately updated its misconduct definition to explicitly include AI tools. A peer-reviewed paper (Resnik & Hosseini, 2026) provides the legal analysis: fabricated citations can meet the federal misconduct standard when the researcher acts with “recklessness”: indifference to a known risk.

So what: If improper AI use is detected after an award, NIH may refer the case to the Office of Research Integrity (ORI). But this is also relevant beyond AI: citation errors affect proposal quality regardless of their source. A 2025 meta-analysis found roughly 17% of citations in peer-reviewed medical publications contain inaccuracies, about half of them major. The error rate in proposals, where no editor verifies references, is likely higher.

Do: Build citation verification into your proposal workflow as a distinct step - the practical approach is below.

✅ Reference verification: a quality gate for your proposal’s citations

New to SBIR? Every abbreviation in this checklist is explained in plain English in our SBIR Glossary.

The situation

A biotech PI is preparing an NIH R43 application. Sixty-plus references across Specific Aims, Research Strategy, and the background section. Assembled from a reference manager, a colleague’s shared library, and a recent literature search. The references were added incrementally as the proposal developed. Some were carried forward from a previous submission. Some were added late in the process to support a reviewer’s likely question.

This is how most proposal reference lists come together: incrementally, from multiple sources, formatted toward the end of the writing period.

Why this matters

Why treat citation verification as a formal quality gate rather than part of the final proofread?

Reviewer credibility. A reviewer who recognizes an incorrect publication year, a misspelled author name, or a citation that doesn’t support the claim you’re making will question the rigor of the rest of your proposal. This has always been true.

Compliance risk. NIH and NSF have published updated policies on fabricated references. Under the current framework, a researcher who submits a proposal containing ghost references and who didn’t verify them could meet the standard for “recklessness”: acting with indifference to a known risk of fabrication. This applies whether the fabrication was intentional or the result of using tools (including AI) without checking the output.

Error baseline. If 17% of citations in peer-reviewed medical papers contain errors (Baethge & Jergas, 2025) - and those are papers that went through editorial review, the rate in proposals, where no editor checks references, is likely higher. Most of these errors are preventable with a systematic pass.

Three categories of citation errors

A useful framework from Resnik & Hosseini (2026) distinguishes three categories:

1. Ghost references - the citation doesn’t exist

A fabricated author, title, journal, or DOI. This is the highest-risk category under the updated NIH and NSF standards, as it can constitute data fabrication. AI tools are known to produce these - plausible-looking citations that combine real author names with invented titles - but they also arise from garbled notes, misremembered papers, or copying citations from secondary sources without verification.

2. Wrong metadata - real paper, incorrect details

The paper exists, but the publication year is wrong, an author name is misspelled, the journal title is incorrect, or the DOI doesn’t resolve. This won’t trigger a misconduct investigation, but it signals a lack of attention to detail. Reviewers who know the field will notice.

3. Misattributed claims - real paper, doesn’t support the assertion

The paper exists and the metadata is correct, but it doesn’t actually say what you’re citing it for. This is the most common category, with or without AI involvement. It typically happens when you cite based on an abstract without reading the relevant section, or when you cite a paper for a claim it mentions in passing rather than as a finding.

Verification workflow step-by-step

Step 1. Export your full reference list.

Pull every citation into a single document. Next to each one, note the specific claim it supports in your proposal. This makes Step 4 (claim alignment) faster. Don’t overlook references in figure captions, table footnotes, and budget justifications.

Step 2. Verify existence.

For each reference, confirm the paper exists. Paste the DOI into doi.org, or search the title in PubMed or Google Scholar. If a DOI doesn’t resolve and the paper doesn’t appear in any database, don’t include it until you can confirm it’s real.

This is the minimum verification step under the updated standards. Ghost references are the primary compliance risk.

Step 3. Verify metadata.

For each confirmed reference: are the author names spelled correctly? Is the publication year right? Is the journal name accurate? Do the volume and page numbers match?

Papers published online ahead of print may show different years across databases. Use the DOI as the canonical identifier when there’s a discrepancy.

Step 4. Verify claim alignment.

For each reference, return to the actual source and re-read the relevant section. Does it support the specific claim you’re making?

Common issues to watch for: citing a review article when you should cite the primary source. Citing a paper based on its abstract when the full text presents a more nuanced conclusion. Citing a paper for a claim it mentions in passing, not as a finding.

Step 5. Check agency disclosure requirements for AI tools.

If AI tools were used for any part of your proposal preparation (formatting, literature search, bibliography management, text polishing), review your agency’s disclosure policy.

• NIH: Disclose AI tool use in your methods. Use of AI for routine editing and polishing is acceptable when aligned with institutional policies. Proposals substantially developed by AI will not be considered.

• NSF: The research misconduct definition now explicitly includes AI tools. Follow institutional and program-specific disclosure policies.

• DoD: No blanket AI policy currently, but individual components may include requirements in their submission instructions. Check your component’s guidance.

If a question arises later, documented disclosure shows good practice. Undisclosed AI use that surfaces after the fact looks like concealment.

Step 6. Archive verification evidence.

Save a PDF or screenshot of each verified source, with the date accessed. If a citation is later questioned, this provides documentation that you verified it at the time of submission. This is standard practice in clinical research and worth adopting for proposals. Watch for preprints that may be retracted or papers that receive corrections after you cite them.

The checklist

Per-reference verification (run on every citation):

• ☐ Exists - DOI resolves, or found in PubMed / Google Scholar

• ☐ Metadata correct - authors, year, journal, volume/pages match

• ☐ Claim aligned - source supports the specific assertion I’m making

• ☐ Evidence archived - PDF or screenshot saved with access date

AI disclosure (run once per proposal):

Did AI tools touch any part of this proposal’s preparation?

• ☐ No AI used → no disclosure needed, still verify all references

• ☐ AI used for formatting / polishing / bibliography → disclose per agency policy, verify all references

• ☐ AI used for literature search or text drafting → disclose per agency policy, verify all references with particular attention to ghost references

• ☐ Unsure whether a tool qualifies → check your agency’s definition, err toward disclosure

Agency-specific:

• ☐ NIH: AI use described in methods section

• ☐ NSF: Institutional and program-specific policies followed

• ☐ DoD: Component submission instructions checked for AI requirements

Common questions

“I only use AI for grammar and formatting. I write my own references from papers I’ve read. Is this relevant to me?”

Yes. Wrong metadata and misattributed claims occur without any AI involvement. A paper you cited two years ago may not say exactly what you remember. The verification workflow catches errors regardless of their source.

“Has NIH actually rejected or rescinded a grant over AI-generated references?”

No public SBIR case as of this writing. The summer 2025 cases were flagged by review administrators. The ORI referral process takes time. But the policy is published, the legal framework is established (Resnik & Hosseini, 2026), and agencies are developing detection methods. Building verification into your workflow now is considerably easier than responding to an inquiry later.

“I apply to DoD, not NIH. Does this matter for me?”

DoD hasn’t published a blanket AI policy, but individual components may include requirements in their submission instructions. Systematic reference verification improves your proposal quality at every agency. A reviewer who checks a citation and finds it doesn’t support your claim will downgrade your score, AI policy or not.

“I have 70 references. This sounds like a full day of work.”

Less than you might expect. DOI resolution checks take seconds per reference. PubMed title searches are fast. The time-intensive step is claim alignment (Step 4), but there you’re scanning the relevant section of the paper, not re-reading the entire publication. For a typical 60-80 reference proposal, a systematic pass takes roughly 2-4 hours. Spreading this across the writing period (verifying each citation as you add it) is more efficient than a batch check at the end.

“Is this just agencies trying to discourage AI use?”

The NIH submission cap (six per PI per year) was partly a response to the volume of AI-assisted applications. But citation integrity is a distinct issue. Inaccurate citations waste reviewer time and undermine the credibility of your technical arguments, however the errors originated.

One thing to do this week

Pick a proposal you’ve submitted in the past year. Pull up the reference list and choose five citations at random. Run them through Steps 1-4: DOI check, metadata check, claim alignment check. If all five are clean, your current process is working. If you find errors, you’ll know what to add to your workflow before the next submission.

If this verification workflow is useful for your team, forward it to a colleague who's preparing a submission.

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Till next time,

—Lana.

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• DoD + Army: Release 1 is open. The Army just restructured how it picks winners

• NIH: Seed Fund is officially back. Start registrations now.

• DARPA: 6 new Microsystems topics opening May 27

• The DoD Phase I pre-submission checklist: from “I found a topic” to “I hit submit.”

🗓️ Funding & Connection Opportunities Round-Up

Army restructures SBIR around FUZE and early soldier feedback

What: The Army launched the FUZE program and a new Pathway for Innovation and Technologies (PIT) office to change how SBIR dollars are invested. Army program manager Zeke Topolosky: “We’re not talking about delivery of low-rate production prototypes. We’re talking about, can we get soldier feedback on this instead of waiting years?” The Army invested $414M in SBIR/STTR in FY2025 to 359 firms. Five new topics were released in April.

What this means for your proposal: The Army now explicitly wants dual-use technologies where the commercial sector is already investing. “If somebody comes to us with technology that only the Army really needs, it’s not a real best use of SBIR.” If you’re applying to Army topics, your commercialization section and your dual-use case need to be specific and supported by evidence of commercial traction.

Do: If you’re targeting an Army topic in Release 1, read the FUZE program page before you write your commercialization section. Frame your proposal around a real end-user need, not just a technology demonstration.

NIH Seed Fund is officially back. Start registrations now.

What: NIH officially announced that SBIR/STTR (the “Seed Fund”) is reauthorized for 5 years. Forecasted funding opportunities are now on Grants.gov. NIH can resume noncompeting continuation (Type 5) awards for existing projects. Key warning from NIH: registrations take 6+ weeks, and late submissions will NOT be accepted (NOT-OD-26-064).

Who should act now: Any biotech, medtech, or health-tech founder targeting NIH. If you don’t have your SAM.gov, eRA Commons, and Grants.gov registrations current, start today. The 6-week lead time means waiting for the NOFO to drop could cost you the deadline.

Do: Review the forecasted opportunities on Grants.gov. If you have an active project, contact your Program Officer about continuation funding. Check NIH’s application prep resources and sample applications.

DARPA Release 2: 6 new Microsystems topics (opens May 27)

What: DARPA dropped 6 new topics under Release 2, all in Microsystems Technology. This is a shift from Release 1’s bio-heavy mix. Topics: nanopore bioelectronics for next-gen proteomics, thermal management for extreme environments (SMART), compact wideband tunable RF filters, temperature-hardened electronics up to 800C (THERMAL), automated radiation-hardening with security codesign, and low-resource computing (reusing existing DoD hardware assets). Opens May 27, closes June 24.

Who should look: Microsystems, RF, thermal management, rad-hard electronics, and single-molecule sensing companies. The nanopore proteomics topic bridges bio and microsystems. The low-resource computing topic is unusual: it’s about reusing existing hardware, not building new.

Do: Topics are on DARPA’s SBIR page. Solicitation instructions are on DSIP.

“From the Source’s Mouth” webinar sessions with SBIR program directors

What: Free monthly sessions connecting you directly with federal SBIR program directors. Upcoming: DARPA (May 13), DOT (May 20), NSF (May 21), NHLBI (June 11). No cost, registration required.

Why this matters: Direct access to the people who evaluate your proposals. For pre-submission prep, this is the most underused resource available. Ask questions about what they’re looking for before you write.

Do: Register now. DARPA - May 13 · DOT - May 20 · NSF - May 21 · NHLBI - June 11

DoD Release 1 is open, and the biggest mistake I see founders make is starting to write before they understand what they’re actually required to submit. The general BAA is not the whole picture. Here’s the step-by-step

✅ The DoD Phase I pre-submission checklist nobody gives you.

New to DoD SBIR? Every abbreviation in this checklist is explained in plain English in our SBIR Glossary.

The scenario

You found a topic on the Army SBIR page that fits your technology. You have six weeks before it closes. You’ve written proposals before, maybe to NIH or NSF, so you feel comfortable with the process. You download the topic description, open a Word document, and start writing the technical approach.

Three weeks later, you discover that DoD has a completely different submission structure than what you’re used to. The budget cap isn’t what you assumed. The format rules are different. There’s a required training module you haven’t completed. And the page limit for the component you’re applying to is different from what the general BAA says.

The mistake

Most first-time DoD applicants start by reading the topic description and the general BAA preface. That’s necessary, but it’s not sufficient. Every DoD component (Army, Navy, Air Force, CBD, DARPA, DHA, SOCOM, etc.) publishes its own submission instructions that override or add to the general BAA. These set the actual budget cap, page limits, format rules, and what’s required in each volume.

The consequence: you write a 25-page technical volume when the component allows 20. The extra 5 pages are not reviewed. You budget $250K when the component cap is $209K. Your proposal is rejected without evaluation. You skip the Fraud, Waste, and Abuse training because nobody told you it was required. Your submission is incomplete.

The general BAA is the floor. The component instructions are the rules.

The framework

Phase 0: Registrations and access (do this first, weeks before the deadline)

1. Verify your company’s SAM.gov registration is active

• What to do: Log into SAM.gov. Check that your registration is active and the legal name and UEI match your DSIP profile. SAM.gov registrations expire annually.

• Why: Expired registration means you can’t submit. Renewal takes 4-6 weeks.

• Watch out for: If your SAM.gov name doesn’t match your DSIP registration exactly, you’ll have issues at submission.

2. Register on DSIP and assign PI role

• What to do: Go to dodsbirsttr.mil. Create accounts for all key personnel. The Firm Admin creates the Firm PIN and completes Firm-level forms. Assign the PI role.

• Why: All key persons must have active DSIP accounts. Firm-level forms must be complete before any proposal can be submitted.

• Watch out for: DSIP uses Login.gov authentication. If you don’t have a Login.gov account, create one first.

Phase 1: Read before you write (the step most people skip)

3. Download and read your component’s specific submission instructions

• What to do: On DSIP, find your topic. Identify the component (Army, Navy, CBD, DARPA, etc.). Download that component’s instructions PDF. Read it fully.

• Why: This document overrides the general BAA for your submission. It sets the budget cap, page limits, font rules, and which volumes are evaluated.

• Watch out for: Budget caps vary significantly. Army topics range $150K-$300K. CBD caps at $209,575. Air Force at $200K. Don’t assume a standard number.

4. Read the topic Q&A on DSIP

• What to do: Go to the DSIP Topic Q&A page for your topic. Read every question and answer, even ones that seem irrelevant.

• Why: The Q&A often contains requirements and clarifications not in the topic description. Production scale targets, cost constraints, material specifications, acceptable surrogates, and scope boundaries are frequently clarified here.

• Watch out for: Q&A closes 2 weeks before the topic close date. If it’s still open, submit your questions early. Answers take about 7 business days.

5. Identify the evaluation criteria and how your component weights them

• What to do: The general BAA (Section 4.2) lists 3 criteria in descending order of importance: (a) technical merit and innovation, (b) team qualifications including ability to commercialize, (c) commercial potential. Check if your component modifies this.

• Why: This is how reviewers score you. Allocate your 20 pages accordingly. Technical approach and SOW should get the most space.

• Watch out for: Reviewers base their conclusions only on what’s in the proposal. Don’t assume they know your company, your PI, or your prior work. Everything must be on the page.

Phase 2: Team and budget (in parallel with writing)

6. Lock in subawards and consultants early

• What to do: Get draft SOW and budget from every subaward partner. Set firm deadlines for delivery.

• Why: Subaward packages are the #1 bottleneck. If a partner is late, your entire submission is at risk.

• Watch out for: The SBC must perform at least 2/3 of Phase I work (measured by direct and indirect costs). Budget your subawards accordingly.

Phase 3: Write the 7 volumes (in the required order)

7. Volume 1: Cover Sheet (DSIP form)

• What to do: Complete in DSIP. Write the brief technical abstract (3,000 chars max) and anticipated benefits/commercial applications (3,000 chars max). Enter the total base cost.

• Watch out for: Do NOT include proprietary or classified information. If you win, the abstract and benefits section may be publicly released. Total cost must match Volume 3 exactly.

8. Volume 2: Technical Volume (PDF, max 20 pages for most components)

• What to do: Write a single PDF following the 12-section order from BAA Appendix A. Use 10-point font minimum. One-inch margins. Header on each page: company name, topic number, DSIP proposal number.

• Why: Pages exceeding the limit are not reviewed. Wrong section order confuses reviewers.

• Watch out for: Check your component’s font and page limit rules. Some components use 10-point minimum (CBD), others 11-point. Some will reject the entire proposal if you exceed the page count. Flatten PDFs. Filenames 50 characters max. No password protection.

9. Volume 3: Cost Volume (DSIP form)

• What to do: Complete in DSIP. Detail all costs: labor (name each key person with hours), equipment, travel, materials, subawards, profit/fee (7% max).

• Watch out for: Every cost must be justified. Cost sharing is permitted but not required and not an evaluation factor. Subaward costs must be detailed at the same level as prime costs.

10. Volume 4: Company Commercialization Report (CCR)

• What to do: Download your CCR PDF from sbir.gov and upload to DSIP Firm Forms. If you have no prior Phase I or Phase II SBIR/STTR awards, select “No” and this section is complete.

• Watch out for: V4 is required but typically NOT considered in evaluation (check your component). Don’t spend time perfecting it at the expense of V2.

11. Volume 5: Supporting Documents

• What to do: Upload letters of support, additional cost information, technical data rights assertions, DD Form 2345 (if ITAR/EAR topic). Combine letters of support into a single PDF.

• Watch out for: V5 is often NOT considered in evaluation (check your component). But letters of support referenced in your Technical Volume should be included here.

12. Volume 6: Fraud, Waste and Abuse training

• What to do: Complete the FWA training module in DSIP. It’s a 3-page PDF tutorial. Must be done once per year. The Proposal Owner must complete this.

• Watch out for: This is required. Your proposal cannot be submitted until V6 is complete. Plan time for it before the deadline.

13. Volume 7: Foreign Affiliations Disclosures (DSIP webform)

• What to do: Complete the webform in DSIP. Answer the 8 disclosure questions about foreign affiliations, ownership, talent recruitment programs, and IP transfers.

• Watch out for: The corporate official cannot certify and submit the full proposal until V7 is complete.

Phase 4: Review and submit

14. Run a Red Team review

• What to do: Have someone who hasn’t written the proposal read it against the topic description and evaluation criteria. Ask: does the technical approach clearly address what the topic asks for? Are the qualifications convincing? Is the commercialization strategy specific?

• Why: You can’t see your own gaps after weeks of writing.

15. Validate, submit, and verify

• What to do: Run “Validate Application” in DSIP until zero errors. Certify electronically. Submit at least 1 day before the deadline. Then verify the final assembled image renders correctly.

• Watch out for: The deadline is typically noon ET, not end of day. If your status is “In Progress” or “Ready to Certify” at the deadline, it is NOT considered submitted. DSIP Support cannot help after a deadline passes.

The checklist

Phase 0: Before you write

• SAM.gov registration active and matching DSIP → Have: active status confirmed, UEI recorded. Renewal takes 4-6 weeks if expired.

• DSIP accounts for all key personnel → Have: all accounts active, Firm Admin PIN created, Firm-level forms complete. Uses Login.gov authentication.

• SBA Company Registry complete → Have: SBC Control ID string recorded. Needed for the SBIR/STTR Information form.

Phase 1: Read first

• Component-specific submission instructions downloaded and read → Have: budget cap, page limit, font rules, PoP, TABA policy noted. This overrides the general BAA.

• Topic description read in full (Phase I, II, and III sections) → Have: clear picture of what Phase I must deliver vs. what’s expected in Phase II.

• All Q&A for the topic on DSIP reviewed → Have: key requirements list extracted. Q&A often has specs not in the topic (cost targets, size constraints, acceptable surrogates).

• Evaluation criteria identified → Have: the 3 criteria and their priority order. Technical merit is weighted highest. Allocate your pages accordingly.

Phase 2: Team

• Subaward SOW and budget received in writing → Have: signed SOW + detailed budget from each partner. This is the #1 bottleneck. Set firm deadlines.

• POW calculation passes → Have: confirmed SBC performs at least 2/3 of Phase I work (direct + indirect costs).

Phase 3: Write

• V1 Cover Sheet → Have: technical abstract (3,000 chars) + benefits (3,000 chars) in DSIP. Public-facing if funded. Total cost matches V3 exactly.

• V2 Technical Volume → Have: single flattened PDF, 12-section order, under page limit, correct font size. Filenames 50 chars max. No password protection. Start with the correct format template.

• V3 Cost Volume → Have: DSIP cost form complete, under budget cap, fee/profit 7% max. Every cost justified. Subaward costs at same detail level as prime.

• V4 CCR → Have: PDF from sbir.gov uploaded to DSIP Firm Forms. N/A if no prior awards. Typically not evaluated. Don’t over-invest time.

• V5 Supporting Docs → Have: letters of support (combined single PDF), data rights assertions, additional cost info. Specificity in letters beats generic praise.

• V6 FWA training → Have: V6 marked complete in DSIP. 3-page tutorial, once per year, completed by the Proposal Owner.

• V7 Foreign Affiliations → Have: 8 disclosure questions answered in DSIP webform. Must be done before corporate official can certify.

Phase 4: Submit

• Red Team review done → Have: candid feedback against topic description + evaluation criteria. Give reviewer the topic, Q&A, and scoring criteria.

• Feedback incorporated, final proof done → Have: terminology, budgets, section references consistent across all volumes.

• DSIP “Validate Application” → Have: zero errors. Resolve ALL errors. Investigate warnings.

• Submitted and certified → Have: status shows “Submitted.” Target: 1+ days before deadline. Deadline is typically noon ET. “In Progress” at deadline = not submitted.

• Final assembled image verified → Have: all sections render correctly in DSIP viewing window.

• Submission receipts archived → Have: local copies of everything submitted.

One thing to do this week

If you’re planning to submit to any DoD Release 1 topic, do one thing before you write a single word: go to DSIP active solicitations, find your component’s submission instructions PDF, and read pages 1-4. That’s where you’ll find the budget cap, the page limit, and the format rules. Everything else builds on that.

Did this checklist save you a mistake? Forward it to a founder who's about to submit their first DoD SBIR. One missed step can mean a non-responsive proposal.

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Till next time,

—Lana.

Share From the Grant Up

• NASA: 92 Phase I topics; due May 21

• DoD: Release 1 in pre-release now; opens May 6; closes June 3-6 depending on component

• DOE: No immediate Phase I deadline; Phase II for eligible Phase I awardees expected spring 2026

• The reauthorization: I read the 14-page bill so you don’t have to.

🗓️ Funding Opportunities Round-Up

What: DoD’s first FY2026 SBIR/STTR solicitation is in pre-release with 90+ topics across Navy, Army, Air Force/Space Force, DARPA, and Defense Health Agency. Five more releases will follow on a rolling schedule through October. This is the first DoD SBIR window after a six-month authorization lapse; an analysis of SBIR.gov award data found DoD award counts fell 11% in FY2025 versus FY2024, while NASA and DOE saw much steeper drops.

What the government is looking for: Each component has different priorities and different award sizes:

• Navy (heaviest contributor - 63 SBIR/STTR/D2P2 topics, plus one open-topic CSO): maritime autonomy, undersea warfare, directed energy, advanced materials for microelectronics, AI for threat intelligence. Topics come from MCSC, NAVAIR, NAVSEA, ONR, and SSP. Phase I typically ~$240K.

• DARPA (5 topics - 4 in Biological Technologies): battlefield blood transfusion (SWiFT), regenerative medicine for extremity trauma, interoperable human/K-9 medical products (BARK), medical swarm robotics. Plus one Microsystems topic (photonic-electronic panel integration). This is unusually bio-heavy for DARPA. Phase I $140K-$250K depending on the topic.

• Army (5+ topics): modular UAS payloads, blockchain in-transit visibility, Li-ion batteries, Ka-band metamaterial radar, xTech pathway. Award size and duration vary by topic - roughly $150K-$300K and 1-6 months depending on the opportunity.

• Air Force/Space Force (AFWERX/SpaceWERX): DAF priorities include collaborative combat aircraft, C3BM (command/control/communications and battle management), contested logistics, counter-UAS, manufacturing/readiness, small UAS, and weapons technology. Phase I up to $200K / 6 months. Note: AFWERX lists DAF Release 1 closing June 6, slightly later than the June 3 date for other components.

• Defense Health Agency (5 topics): military working dog injury treatment, infection detection wearables, antifungal compounds.

Who should look at this:

• Hardware/defense teams with working prototypes (TRL 3+) and prior DoD experience.

• Biotech/MedTech founders - if you’ve never considered DARPA, this release is worth a look. Four of five DARPA topics are biological technologies. DHA adds five more medical topics.

• First-time DoD applicants - Navy’s 63+ topics give you the widest selection to find a fit. But read the topic descriptions carefully: Navy rewards team credentials and prior performance.

Who can probably skip this:

• Software-only companies without a hardware or integration angle. Most DoD SBIR topics require some physical deliverable or prototype.

Do: Go to dodsbirsttr.mil/topics-app and filter by your technology area. The pre-release is live now, submission opens May 6. Technical questions are usually due 2-3 weeks before close - check each component’s instructions. If you see a topic that fits, read the full description before committing - the title alone won't tell you whether they want a feasibility study or a working prototype.

NASA Phase I SBIR/STTR - 92 topics, proposals due May 21

What: NASA overhauled its entire SBIR/STTR structure. The annual one-shot solicitation is gone. It’s now a standing BAA (Broad Agency Announcement) with rolling appendices released throughout the year. The first release dropped April 21 with 92 open topics across three appendices (73 SBIR and 19 STTR). Phase I awards are now up to $225K (a 50% increase from the old $150K cap). Phase II increased to $1.275M (was $850K). Max 2 proposals per company per appendix release, and limits reset with each new appendix.

What the government is looking for: NASA’s topics span almost every directorate:

• Lunar/Mars surface infrastructure - dust mitigation, regolith handling, surface power, 3GPP communications for the Moon, EVA suit design. Artemis is driving significant demand here.

• In-space manufacturing and orbital economy - semiconductor/quantum materials production in space (CHIPS-QM), commercial logistics, robotic manipulation. NASA needs suppliers for a post-ISS commercial space station economy.

• Aeronautics - sustainable aviation fuels, propulsion noise, AAM/VTOL, thermal management. Bread-and-butter NASA but with real near-term applications.

• Instruments and sensors - planetary science instruments, space weather sensors, quantum sensing components, high-performance detectors and optics.

• Computing and AI - quantum computing, computational AI, autonomous health management for small spacecraft.

Who should look at this:

• Any hardware company in aerospace, materials, sensors, or energy storage - NASA’s topics are unusually broad this cycle.

• Founders with technology that has both space and terrestrial applications - the 50% award increase and rolling appendix model make NASA more accessible than before.

• University spin-offs and STTR-eligible teams - 19 STTR topics, and the 13-month STTR timeline gives more room than the 6-month SBIR window.

Who can probably skip this:

• Pure software/SaaS companies without a hardware or scientific computing angle.

• Companies that need more than $225K to reach a meaningful proof of concept. Phase I is still a feasibility study.

Key change to know: At NASA specifically, TABA (Technical and Business Assistance) funds are now folded into the total award value, not added on top. Budget accordingly - if you allocate $6,500 to TABA, that comes out of your $225K, not in addition to it. Other agencies may handle this differently - the statute allows each agency head to decide whether TABA is included in or added to the award amount.

Do: Browse topics at sbir.gov/topics or NASA’s 2026 info hub. Technical questions are due May 5. You have three weeks to submit. The 2-proposal-per-appendix limit means you need to choose carefully - but if you miss this window, another appendix release is coming later this year.

DOE SBIR moves to Office of Technology Commercialization

What: DOE restructured its SBIR/STTR programs under the Office of Technology Commercialization. New details: Phase I awards up to $250K, Phase II up to $1.6M each, with multiple sequential Phase IIs possible (up to 4 per project). Phase II topics expected spring 2026, Phase I solicitation expected later in 2026. Priority sectors: advanced manufacturing, biotech, critical materials, quantum, semiconductors, energy innovation.

So what: No live deadline yet, but the sequential Phase II model is a structural shift for energy/cleantech founders. Total funding per project could reach $6M+ across multiple Phase IIs. DOE is also one of the agencies that now has direct-to-Phase-II authority under the reauthorization.

Do: Subscribe to DOE OTC updates. If you’re an existing DOE Phase I awardee, watch for the Phase II topics this spring - you’ll get first shot.

Those are the live opportunities. Now for the bigger background question: the reauthorization was signed on April 13. What does it actually change? I read the 14-page bill.

🔍 I read the SBIR reauthorization so you don’t have to. Here’s the honest take.

The scenario

You’re a scientist-founder running a small team. You saw the headline: “SBIR reauthorized through 2031.” You felt a moment of relief - the program isn’t going away. Then someone mentioned “proposal caps” and “strategic breakthrough funding” and you wondered if you missed something important.

You didn’t miss much. Here’s why.

The mistake

The reauthorization coverage falls into two camps: breathless takes calling it “a once-in-a-decade gift to every small innovator” and dismissive takes saying “it’s just an extension.” Both are wrong, but the dismissive camp is closer to the truth for most founders.

The law (S.3971, Public Law 119-83) has 10 sections. Two of them matter to the average SBIR applicant. The rest are either government-side plumbing (Phase III training for contracting officers, data tracking requirements), expanded security screening (relevant if you have foreign ties), or mechanisms designed for a very narrow set of companies. The strategic breakthrough allocation, for example, requires a prior Phase II, 100% matching funds, and market research supporting it as an effective solution to an identified agency need. Maybe a few dozen companies nationwide qualify.

The real story: Congress spent most of its energy on the “SBIR mills” problem. These are companies that collect dozens of awards for decades without ever commercializing anything. One analysis found that 25% of all SBIR awards from 2010-2024 went to just 70 companies, totaling 11,971 awards worth $5.3 billion. The proposal caps in Section 4 target these serial submitters.

The framework

The 2-3 provisions that might actually affect you:

1. Agencies must now make TABA available, and the amounts went up (Sec 7)

• What changed: The law says agencies “shall authorize recipients” to select Technical and Business Assistance “if desired.” Phase I recipients can access up to $6,500 per project; Phase II up to $50,000. You can now use TABA funds to hire staff, pay for I-Corps, or get cybersecurity assistance. You also choose your own vendor (the old agency-selected vendor model is gone).

• Why this matters: Most founders don’t use TABA because they don’t know it exists or their agency didn’t actively offer it. Now agencies must make it available. That $6,500-$50,000 can pay for a business advisor, market research, or compliance help you were going to pay for out of pocket anyway.

• Watch out for: How TABA interacts with your award total varies by agency. At NASA, TABA is folded into the award amount. The statute gives each agency head discretion on whether TABA is included in or added to the award. Check your agency’s implementation before budgeting.

2. Foreign affiliation screening got stricter (Sec 2)

• What changed: The law requires agencies to evaluate whether applicants present a security risk, including examining relationships with entities or individuals on specified federal lists. It also expands due diligence to cover foreign ownership, financial ties, foreign affiliations of covered individuals and key personnel, investment relationships, technology licensing agreements, joint ventures, and business relationships involving countries of concern.

• Why this matters: If you have co-founders, key personnel, or investors with ties to designated countries, your application will get additional scrutiny. This isn’t automatic disqualification - but it means delays and potential denial if your disclosures don’t match what the agency finds.

• Watch out for: This applies to the due diligence process, which means existing awards could be affected if your situation changes. If you have any foreign affiliations, review your disclosures before your next submission, not after a flag appears.

3. Proposal caps are coming in FY2027, but probably don’t affect you (Sec 4)

• What changed: Starting FY2027, each agency’s SBIR/STTR program director must set a limit on how many Phase I and certain Phase II proposals a company can submit - on a fiscal-year, solicitation, or topic basis. Agencies also have a waiver mechanism for urgent or time-sensitive topics.

• Why this matters: It probably doesn’t, unless you’re submitting 20+ proposals per year across multiple agencies. The provision appears designed to curb SBIR mills, though the statute doesn’t state that purpose explicitly.

• Watch out for: The caps haven’t been set yet. Watch for agency announcements in late FY2026. If you’re a frequent multi-agency submitter, this could force you to prioritize.

What the law doesn’t address: The reauthorization doesn’t fix the valley of death between Phase I and commercialization. It doesn’t reform the review process or address wired contracts. For most founders, the day-to-day experience of the SBIR program is unchanged.

The checklist

Does the reauthorization affect you? Quick check:

Do you have foreign co-founders, investors, or key personnel with ties to countries of concern? Yes → Review your security disclosures before your next submission. Read Section 2 of the law. No → No action needed on this provision.

Have you budgeted TABA into your proposals? No → On your next application, include up to $6,500 (Phase I) or $50,000 (Phase II) for business advising, market research, cybersecurity, or I-Corps. Agencies must now make it available. Yes → Check if the new amounts apply and whether your agency includes TABA within or on top of the award.

Do you submit more than 10 proposals per year across agencies? Yes → Watch for agency-specific proposal cap announcements in late 2026. No → The proposal caps won’t affect you.

Do you have a prior Phase II, 100% matching funds, and market research supporting your technology as an effective solution to an identified agency need? Yes to all three → Look into the strategic breakthrough allocation (Sec 3). You may be eligible for up to $30M. No to any → Skip it. This mechanism wasn’t designed for most companies.

One thing to do this week

Two actions, five minutes each:

1. Pick one opportunity from today’s round-up that matches your technology area. Read the full topic description - not the title, the actual description. Check whether they want a feasibility study or a working prototype. That answer tells you whether it’s worth three weeks of your time.

2. On your next proposal, budget TABA into your application. Under the new law, agencies must make up to $6,500 (Phase I) or $50,000 (Phase II) available for business advising, market research, cybersecurity, or I-Corps. Most founders leave this money on the table because they don’t know to ask for it.

This is Edition 1. If you found this useful - forward it to a founder who’s about to submit their first SBIR proposal. They need this more than you do.

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Till next time,

—Lana.