Following SBIR/STTR reauthorization through September 30, 2031, NIH and HHS have implemented several policy changes affecting applicants and awardees. While most companies will see little change in their day-to-day proposal preparation, several updates are worth noting.
Expanded Flexibility for Technical and Business Assistance (TABA)
- NIH has updated its TABA policy, allowing SBIR/STTR awardees to request up to $6,500 for Phase I projects and up to $50,000 for Phase II projects.
- In addition to hiring outside consultants, companies may now use TABA funds to hire or augment staff, support commercialization training, conduct market research and validation, develop regulatory and manufacturing plans, obtain cybersecurity assistance, and participate in NIH I-Corps.
- This gives awardees greater flexibility to build internal commercialization capabilities as they prepare for market entry.
New HHS Application Limit
- HHS has implemented a new annual application limit as required by reauthorization. Beginning April 13, 2026, a Small Business Concern and its affiliates may submit a maximum of nine SBIR/STTR applications or proposals across all HHS agencies per fiscal year.
- The limit includes new applications, resubmissions, renewals, revisions, grants, cooperative agreements, and contract proposals. For most applicants, this change will have little practical impact.
NIH Reinforces Proposal Originality Requirements
- NIH also issued guidance regarding the use of artificial intelligence (AI) in proposal preparation.
- While NIH does not prohibit AI tools, applicants remain responsible for ensuring that proposals reflect their original ideas and do not contain fabricated citations, plagiarism, or other inaccuracies.
- The notice also established a separate limit of six applications per Principal Investigator per calendar year across most NIH funding mechanisms.
Additional Policy Changes
- Foreign disclosure requirements have expanded. NIH’s updated foreign disclosure and risk management policies align with broader federal efforts to strengthen research security, foreign influence screening, and supply-chain transparency.
- NHLBI budget restrictions were removed. NIH rescinded prior NHLBI-specific SBIR/STTR budget guidance, simplifying proposal budgeting and reducing confusion for applicants.
- Commercialization training remains available. NIH continues to support participation in programs such as I-Corps to strengthen customer discovery, market validation, and commercialization readiness.
| Notice | Title | Agency / Office | Date | Basic Information |
|---|---|---|---|---|
| NOT-OD-26-076 | Notice to Rescind NOT-OD-24-077 | NIH / OD | April 20 | Rescinds prior guidance allowing TABA funding through an administrative supplement. |
| NOT-OD-26-073 | New Policy Limiting the Number of Applications | NIH / OD | April 20 | HHS has implemented a new annual cap of nine SBIR/STTR applications or proposals per Small Business Concern, including affiliates, across all HHS agencies. |
| NOT-OD-26-075 | Policy Changes to SBIR and STTR Discretionary Technical and Business Assistance | NIH / OD | April 20 | Updates NIH policy for requesting Technical and Business Assistance (TABA) in SBIR/STTR applications. |
| NOT-OD-26-074 | Policy Changes to SBIR and STTR Foreign Disclosure and Risk Management | NIH / OD | April 20 | Outlines foreign disclosure and risk management policy changes for SBIR/STTR applicants. |
| NOT-HL-26-005 | Notice to Rescind NOT-HL-24-008 | NHLBI | May 13 | Rescinds prior NHLBI-specific budget guidance for SBIR/STTR applications. |
| NOT-OD-26-037 | I-Corps at NIH Entrepreneurship Program | NIH / OD | March 5 | Provides commercialization training for Phase I SBIR/STTR awardees. |