Reference
Quick reference: Contracting Officer checklists, FAQ, glossary, acronyms, and contact information.
Contracting Officer Checklists
1 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
2 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
3 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
4 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
Won't a sole-source Phase III look like a workaround?
No — 15 U.S.C. §638(r)(4) provides explicit statutory authority distinct from FAR Part 6 competition rules. See the full answer →
Is a services-only Phase III really eligible?
Yes — the statute explicitly includes "services" within Phase III scope; Digital Force (B-423319) confirms SBIR-developed technology as a material component of professional services is sufficient. See the full answer →
Can the scope grow via post-award modifications?
Yes, within general scope and without a separate J&A — SBA Policy Directive §4(c)(5). See the full answer →
How tight does the SBIR connection need to be?
Broader than most reviewers assume — the "derives / extends / completes" framework is read generously, and not every component of a Phase III must be SBIR-derived. See the full answer →
Can a Phase III be awarded after a long gap from Phase I/II?
Yes — the statute contains no time limit. A credible logical connection narrative is what matters. See the full answer →
What is SBIR Phase III?
Work that derives from, extends, or completes efforts made under prior SBIR funding agreements. Can include products, services, or any combination thereof.
Is Phase I or II completion required for Phase III?
No. Phase III authority exists upon Phase I or II award, not completion. This enables rapid technology transition.
Are there dollar or time limits on Phase III contracts?
No. SBA Policy Directive Section 4(c) confirms no dollar limit, duration limit, or contract type restriction.
What funds are used for Phase III?
Program funds (e.g., O&M, Procurement, RDT&E), not SBIR set-aside funds.
Is a formal J&A required?
No. SBA Policy Directive Section 4(c)(3) states "Further justification is not needed." Only requires a memorandum for file documenting SBIR connection.
Is synopsis in SAM.gov required?
No. Phase III awards are exempt from synopsis per SBA Policy Directive Section 2(j)(4)(iii).
Can we collaborate with the SBIR contractor on requirements?
Generally yes. Since the awardee is pre-determined by statute, collaboration is unlikely to create OCI. Contracting officer retains discretion.
Does this create personal services?
Not if properly structured. Contract must be performance-based with deliverable focus; contractor retains control over employees.
What data rights does the government receive?
SBIR Data Rights (limited rights) for 20 years, then Government Purpose Rights thereafter.
Who owns the analytical outputs and reports?
Government owns with unlimited rights. SBIR protects the tools, not the data generated using the tools.
What is form, fit, and function data?
External interface specifications and functional requirements. Not protected by SBIR — government gets unlimited rights.
Quick Reference Cards
Phase III Eligibility
Requirements:
- Contractor received Phase I or II award
- Work derives from / extends / completes SBIR effort
- Logical connection documented
Not required:
- 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
Acronym Dictionary
| Acronym | Definition |
|---|---|
| SBIR | Small Business Innovation Research |
| STTR | Small Business Technology Transfer |
| PWS | Performance Work Statement |
| FAR | Federal Acquisition Regulation |
| DFARS | Defense Federal Acquisition Regulation Supplement |
| GAO | Government Accountability Office |
| SBA | Small Business Administration |
| COR | Contracting Officer's Representative |
| KO / CO | 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 |
| COTS | Commercial Off-The-Shelf |
| GOTS | Government Off-The-Shelf |
| ATO | Authority to Operate |
| FOIA | Freedom of Information Act |
| WAWF | Wide Area Workflow |
| PMO | Program Management Office |
| HCA | Head of Contracting Activity |
| DoD | Department of Defense |
| NDAA | National Defense Authorization Act |
| SAM | System for Award Management |
| RDT&E | Research, Development, Test & Evaluation |
| O&M | Operations & Maintenance |