Regulatory Compliance Requirements
- Projects should consider data package needed for FDA’s Biomarker Qualification Submission or submission to FDA’s Center for Devices and Radiological Health.
- Milestones should include planned interactions with regulatory agencies (e.g., filing for Medical Device Development Tool qualification, Letter of Intent for Biomarker Qualification, CLIA certification, FDA Q-Submission meeting).
- If involving human subjects, compliance with 45 CFR Part 46 regarding protection of human subjects, and inclusion policies for women, racial/ethnic minorities, and individuals across the lifespan.
- If clinical trial optional is exercised, adherence to ClinicalTrials.gov registration and reporting, IRB/IEC approval, Data and Safety Monitoring, and Investigational New Drug (IND)/Investigational Device Exemption (IDE) requirements.
Data Protection and Privacy
- Compliance with the 2023 NIH Policy for Data Management and Sharing for scientific data generated.
- SBIR/STTR recipients may retain data rights for up to 20 years after award date.
Intellectual Property (IP) Policies
- An Intellectual Property Plan is required (max 1 page) to describe potential commercialization impediments, the IP landscape of the detection method, future filing plans, and how IP will be shared among multiple investigators/institutions.
- Applicants are encouraged to consult their tech transfer office.
Risk Management and Security Requirements
- Foreign Disclosure Requirements: Required for owners and covered individuals (senior key personnel) regarding funded and unfunded relationships with foreign countries.
- Awards may be denied if ties to 'foreign countries of concern' (e.g., People’s Republic of China) pose a security risk (e.g., interfere with activities, create duplication, conflicts of interest, undeclared, violate law, national security risk).
- Repayment of Funds: Required if material misstatement or significant change in ownership/structure determined to pose a national security risk.
Cooperative Agreement (Substantial Funder Involvement)
- This is a Cooperative Agreement (
U44
), meaning there will be substantial Federal scientific or programmatic involvement from NIH (NINDS).
- NIH program staff will assist, guide, coordinate, and participate in project activities.
- Recipients primarily define objectives and approaches, conduct research, and own data, but NIH staff provide input on milestones, assess progress, may recommend critical experiments, and participate in regulatory meetings.
- Funding continuation is tied to meeting milestones and overall progress.
- A Dispute Resolution process is in place for scientific/programmatic disagreements between recipients and NIH.
Other Special Requirements
- Multi-site Studies: Expected for analytical validation; strong justification needed for single-site applications.
- Leveraging Existing Resources: Encouraged to use resources like NINDS Human Biospecimen and Data Repository (BioSEND) and ongoing clinical trials/studies.
- Project Milestones: Mandatory annual quantitative milestones for go/no-go decision making.
- Rigor and Reproducibility: Strong emphasis on rigorous experimental design, minimization of bias, transparent reporting, and data sharing (code/scripts, analytic tools, protocols, metadata).