2026 SBIR Phase IA QA(91990026R0003).xlsx

XLSX spreadsheet 39 KB Posted Jun 3, 2026

Attached to: Department of Education Small Business Innovation Research (SBIR) Phase IA 2026: Solicitation
Solicitation number: 91990026R0003
Issued by: Department of Education Contracts and Acquisition Management

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File	Type	Posted
Phase IA- 91990026R0003 Final.docx	DOCX document	Apr 30, 2026
Phase IA- 91990026R0003 Final.pdf	PDF	Apr 30, 2026

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Sheet1

		2026 SBIR Phase IA Q&A (91990026R0003)
	Number	Question	Government Response
	1	I would like to know whether this RFP is likely to consider innovative education technology designed to address the administrative and operational challenges that school districts and states face in fulfilling their responsibilities to provide healthy, safe, educationally appropriate public school buildings and grounds that are resilient, energy-efficient, and affordable. Facility information and data are growing at an explosive rate. This is due to real-time monitoring of indoor environmental factors, energy, and security, as well as the number of computer-operated systems that govern heating, ventilation, and cooling. School districts are struggling with what to do with all the data, how to organize it, analyze it, and how to use it to inform their decisions.	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas.
	2	Our entity is wholly owned by a UK-based organization that is owned by UK citizens. Are we eligible to apply for this solicitation to pursue the above project?	No. Please see Part VI, Section A of the solicitation.
	3	I am looking at Phase IA, Notice ID 91990026R0003 — "novel prototype, no or limited previous development." My existing code is early-stage and not validated. Only 4% of the planned state coverage is built. No research has been done on it. Does this count as "limited previous development"?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	4	Regarding the SBIR PD/PI employment requirement, would a Project Director who is employed full-time outside the United States but intends to lead the proposed SBIR project through the applicant small business be considered eligible (I am a US citizen)?	No. Per page 16 of the solicitation, all work must be conducted by individuals who are located within the United States who are either citizens or hold a green card. Individuals who are in the United States without citizenship, visa, or green card, and U.S. citizens working outside the U.S. are not eligible to conduct work on the contract.
	5	For projects led by individuals whose primary expertise is in public/global health research rather than education research specifically, would the inclusion of consultants or advisors with expertise in early childhood development, social-emotional learning, or education technology generally be considered sufficient to address team expertise requirements?	Reviewers for ED/IES SBIR will consider the skills and experience of all members of the project team in fulfilling key roles on the project successfully. No further information can be provided in response to this question.
	6	Would a novel storytelling platform focused on supporting identity formation, belonging, and social-emotional development in young children from non-traditional family structures fall within the scope of the “social and behavioral skills” priority area described in the solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	7	Eligibility of transportation technology as education technology:
REDACTED is an AI-powered student transportation coordination platform designed for students with disabilities receiving IEP-mandated transportation services. Transportation is a related service under IDEA. Does ED/IES SBIR consider technology that supports the delivery of IEP-mandated transportation services to be eligible education technology under the Phase IA solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	8	Definition of novel:
The Phase IA solicitation requires the proposed product to be novel with no or limited previous technological development. Our company operates a transportation service for students with disabilities and has operational experience but has not previously developed any software or technology product. Does prior operational experience in the relevant field affect the novelty requirement, or does novelty apply only to the technology product itself?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	9	Special education eligibility:
The solicitation references education and special education settings. Does technology that supports the transportation component of special education services qualify, or must the technology directly support instruction, assessment, or classroom-based intervention?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	10	Principal Investigator requirement:
The PI must be employed at least 20 hours per week by the company. Can the founder and CEO of the small business serve as the Principal Investigator, or is a researcher with academic credentials required?	Yes, founders/CEOs can be Principal Investigators.
	11	Research partner requirement: Is a university or research institution required as a subcontractor or partner for Phase IA, or can the small business conduct the feasibility research independently with the founder serving as PI?	A university/research institution partnership is not required and the small business may conduct the feasibility research with a founder serving as PI.
	12	Our proposed project focuses on developing a reproducible computational workflow platform for microbiology and life sciences education. The platform is designed to provide standardized, cloud-accessible computational environments that allow students to perform authentic bioinformatics and data analysis workflows without the configuration failures and infrastructure barriers that commonly disrupt instruction.

Importantly, the platform is intended for computational analysis of biological and clinical datasets rather than wet-bench laboratory simulation or instrumentation. The goal is to support reproducible scientific computing instruction by tightly integrating curricular materials with pre-configured computational environments.

Phase IA would focus on demonstrating the technical feasibility of a containerized platform for delivering deterministic computational workflows in microbiology education. The effort would include developing prototype reproducible execution environments, implementing a lightweight orchestration and deployment framework, validating reproducibility across heterogeneous systems, and evaluating usability and reliability in instructional settings. Does our abstract align with your solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	13	We plan to develop a new educational tool for high school and undergraduate laboratory environments that demonstrates how AI can be applied to hardware-based energy systems and the control of dynamic systems. The platform will provide hands-on learning experiences, enabling students to explore AI-driven monitoring, optimization, and real-time control in practical engineering and energy applications. Does this idea fit the scope of this program? Can letters of support/endorsement come from Instructors who would potentially use the product? Please advise.	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. Regarding letters, the solicitation includes a section about recommendations for strong letters of support for commercial pathways.
	14	If a small business has developed and piloted a technology in non-education contexts, but has not developed, evaluated, or commercialized it as an education technology product nor sold it outside paid pilots, would a proposal to create and evaluate a novel education-focused version of that technology potentially be appropriate for Phase IA?	Yes, offerors may indicate N/A in the fourth certification check box of Section A, Part Q.
	15	Phase IA novelty eligibility

We operate an existing consumer-facing software platform in the behavioral health space. The platform has no formal school, district, or university partnerships, no institutional licenses, and no integrated educational product of any kind. All users access it as individual consumers.

We propose a new Phase IA product — an AI-powered tool designed to serve students in education settings — that addresses a problem our existing consumer platform does not address and uses technology we have not previously developed.

Does the existence of our consumer behavioral health platform (with no school deployments or institutional education use) constitute a "previously developed education technology product" under Phase IA eligibility requirements? Or does the absence of any formal school deployment or institutional education product mean our proposed new tool qualifies as first-of-its-kind under Phase IA?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	16	Education Setting scope for Letter of Agreement

The solicitation requires a Letter of Agreement to Participate from an "education setting."

May this letter come from a community-based or non-formal education program — such as an ADHD coaching practice, a tutoring center, a community center with academic support programming, or an adult education program — or must it come from an accredited educational institution (school, district, or university)?	Products for learners may be for use in education settings, which can include schools or remote locations to replace, supplement, or enable the delivery of curricula or instruction or that facilitate out- of-school learning opportunities (e.g., after-school or summer programs, distance learning programs, on-line programs, enrichment programs, self-directed learning). For research that will occur in out-of-school learning context (e.g., after-school or summer programs, distance learning programs, on-line programs, enrichment programs, self-directed learning), a letter of agreement in Section E must come from a representative of an organization to indicate that research will be conducted under the auspice of their organization.
	17	Does F-1 visa status qualify under the "lawfully admitted resident" definition for SBIR ownership eligibility?	No, under 13 CFR § 121.702(a)(1)(i).
	18	If the company's Principal Investigator (PI) holds work-authorized status (e.g., U.S. citizen or green card holder), while I serve as a co-founder and majority shareholder on F-1 status, would the company still be eligible to apply?	No, under 13 CFR § 121.702(a)(1)(i).
	19	Are there any additional documentation requirements for companies with international student founders?	N/A
	20	Priority Area Alignment: Does the IES consider a prototype that integrates real-time affective-behavioral regulation tracking with structured literacy instruction to be a responsive focus under the "Social and Behavioral Context for Academic Outcomes" priority area?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	21	Instructional Hybridity: Is a project that develops a primary instructor-facing digital dashboard to support 1-on-1 intervention eligible for Phase IA if the student continues to engage with physical, non-digital multisensory manipulatives (e.g., sandpaper letters, tactile tiles) as part of the evidence-based practice?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	22	Novelty Threshold: If the proposed prototype utilizes existing tablet hardware but develops an entirely novel software engine for behavior-literacy correlation—where no such integrated data correlation currently exists in the market—does this meet the "Novel Education Technology" requirement?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	23	Security Liaison: The solicitation states the Project Director cannot also serve as the Contractor Security Liaison (CSL). For a micro-business, is it permissible for a technical subcontractor or a designated administrative partner to serve as the CSL?	The CSL may be an employee at the company or a consultant from outside of the company.
	24	Pilot Site Requirements: Regarding Section E (Letter of Agreement), is a letter from a private clinical learning center that specializes in dyslexia intervention and serves high-need populations sufficient to satisfy the "education setting" requirement for Phase IA?	Products for learners may be for use in education settings, which can include schools or remote locations to replace, supplement, or enable the delivery of curricula or instruction or that facilitate out- of-school learning opportunities (e.g., after-school or summer programs, distance learning programs, on-line programs, enrichment programs, self-directed learning). For research that will occur in out-of-school learning context (e.g., after-school or summer programs, distance learning programs, on-line programs, enrichment programs, self-directed learning), a letter of agreement in Section E must come from a representative of an organization to indicate that research will be conducted under the auspice of their organization.
	25	Priority Fit: Given the explicit focus on "Priority Area IA: Novel Education Technology Products for Use by Administrators," does the IES consider backend data-privacy infrastructure that optimizes administrative school funding and compliance to be a competitive fit for this track?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	26	Timeline & Start Dates: Following the late June 2026 submission deadline, what is the estimated window for award notifications, and what is the anticipated target start date for the 9-month performance period?	We anticipate making award notifications approximately ninety days after the application submission deadline and that awards will begin approximately a week after award notifications.
	27	Contract Structure: Are Phase IA contracts under this solicitation typically structured as Firm-Fixed-Price with milestone drawdowns, or do they operate on a cost-reimbursement basis?	Awards will be firm-fixed-price.
	28	Phase II Bridging Gaps: What is the anticipated timeline for the FY2027 Phase II submission cycle for successful FY2026 Phase IA awardees? Will there be an operational gap between the end of Phase IA and the start of Phase II funding?	We do not yet have an anticipated timeline for FY2027 Phase II submissions.We will take the timing between Phase I and Phase II into consideration to minimize any timing gaps.
	29	I am preparing a proposal under Solicitation 91990026R0003. Our company has developed substantial technical architecture, codebase, and documentation for a novel adaptive game-based K-12 education technology platform, however the prototype is not yet functional for end-users without developer assistance.
Under Section II.B of the solicitation, would this level of prior development be considered "limited" prior development appropriate for Phase IA, or would it be more appropriate for Phase IB?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	30	Would a platform focused on operational infrastructure and interoperability for public schools fall within the intended scope of the current ED/IES SBIR topics?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas.
	31	Is there interest within the program for parent-facing operational systems that improve school-to-family coordination and administrative efficiency?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas.
	32	Would proposals involving cross-system integration and workflow modernization for K–12 operations be considered responsive to the solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas.
	33	REDACTED is developing REDACTED, an AI-powered, game-based learning platform designed to support K–12 learners, with an initial focus on math learning, engagement, executive-functioning support, and accessibility for ADHD and other neurodivergent learners, ages 6 to 110. We currently have:• An MVP in development with two playable learning games to be launched in June 2026. • Initial pilots and testing preparation underway. • AI companion functionality integrated into the experience. • A planned focus on measurable academic and engagement outcomes. We are considering proposing a new, distinct component focused on adaptive learning systems, AI-guided support, and learner progression analytics. We would greatly appreciate clarification on the following:1. Given our current stage, would ED/IES generally view this as a stronger fit for Phase IB rather than Phase IA if the proposed work focuses on a distinct new component added to an existing MVP? 2. Are there any SBIR requirements or guidelines we should review regarding the use of international collaborators or contractors supporting portions of development work? 3. Is a formal nonprofit, university, or research institution partner required for Phase IA or Phase IB SBIR proposals, or can evaluators, advisors, and school partners participate without being formal research institution partners? 4. For a platform designed to support neurodivergent learners, would ED/IES generally expect proposed outcomes to focus primarily on measurable educational and learner engagement outcomes?	1. The Phase IA solicitation requests proposals for Phase I projects for the development of a prototype of a novel (i.e., first of its kind, not successfully tried before) education technology product for which no or limited previous technological development has occurred. The Phase IB competition requests proposals for Phase I projects for the development of a prototype for a new component (or multiple new components) to be integrated into an existing education technology prototype or product. Offerors must determine whether to prepare a proposal under the Phase IA or IB solicitations. For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA versus Phase IB program tracks. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. 2. All work must be conducted by individuals who are located within the United States who are either US citizens or hold a green card. Individuals who are in the United States without citizenship, visa, or green card, and U.S. citizens working outside the U.S. are not eligible to conduct work on the contract. 3. No, it is not a requirement to have a formal nonprofit, university, or research institution partner though many ED/IES SBIR awardees do partner with researchers. The project team must demonstrate expertise in the following areas: the design and development of new education technology products; education theory and practice; education research for the development and evaluation of education technology, and in the commercialization of education technology-related products. In addition, the team must have expertise with the current innovation and in the targeted content domain. 4. The intended outcomes should support learning or promote outcomes in one of the topic areas listed in the priority areas outlined in the solicitation.
	34	Could you please confirm: The correct submission portal and format requirements for Phase IA applications	A single MS WORD or PDF document must be emailed to: David.Yadeta@ed.gov, Contract Specialist with a CC to David.Geary.ed.gov, Contracting Officer. The due date and time for the receipt of proposals is 11 a.m. EST on June 29, 2026. All formatting requirements are included in the solicitation.
	35	Could you please confirm: Whether proposals should be submitted through Grants.gov, SAM.gov, or via email	A single MS WORD or PDF document must be emailed to: David.Yadeta@ed.gov, Contract Specialist with a CC to David.Geary.ed.gov, Contracting Officer. The due date and time for the receipt of proposals is 11 a.m. EST on June 29, 2026. All formatting requirements are included in the solicitation.
	36	Could you please confirm: Any specific file format or page limit requirements beyond what is stated in the solicitation	N/A
	37	Could you please confirm: Whether our pending Phase IB application creates any restrictions on a separate Phase IA submission for a different product	Offerors are permitted to submit multiple proposals under either or both solicitations provided the proposals have different foci.
	38	I am working on a ED/IES proposal to be submitted for the June 29 deadline, and am writing to request permission to deviate from the >50% employment threshold for SBIRs. I am also the PI on several NSF Educational Research grants which total 50% FTE which is in conflict with the requirements for the SBIR. These educational research grants have given me significant insights into the needs and gaps in the AI in Education field, and I believe our SBIR submission will provide a value-add for educational technology tools and will positively impact the field.

Please let me know if it is possible to be granted this deviation so that we can plan on how best to approach this SBIR submission.	No, we are unable to grant permission to deviate from the >50% employment threshold requirement at this time.
	39	I have conducted concept validation and prompt testing using an AI platform but have not yet built a working application. Does this level of pre-development work satisfy the no or limited previous technological development requirement for Phase IA?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	40	I am currently a single-member LLC with no full-time employees. Does this structure satisfy the small business eligibility and principal investigator employment requirements?	The SBIR/STTR definition of a small business is a firm with 500 or fewer employees. It does not matter if they are full- or part-time employees, or even leased employees—they all count toward the 500 employee limit. At the low-end of the employee spectrum, the small business could also be a start-up with as few as one employee.
	41	My proposed product is a K-5 AI child development platform that teaches academic concepts through immersive storytelling and emotional regulation skill-building. Is this within scope for the FY2026 Phase IA solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	42	The project is an AI-driven simulation-based applied-learning system designed to support the development of higher-order thinking skills, including critical thinking, creative problem solving, and adaptive decision-making through interactive learning environments.

The broader goal is to explore whether simulation-based learning environments can better support applied learning, cognitive development, and skill transfer compared to more traditional instructional approaches.

We are currently in the prototype/MVP development stage and are considering Phase IA as a feasibility and early validation pathway. I wanted to ask whether this type of learning technology would generally be considered within scope for the program.	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	43	Does the "employee" requirement in the Project Director certification refer specifically to W-2 employment status, or can it be satisfied by an individual engaged as an independent contractor who dedicates more than half their working time to the project?	For the SBIR/STTR programs, an employee includes all individuals employed on a full‐time, part‐time, or other basis. This includes employees obtained from a temporary employee agency, professional employee organization or leasing concern. Generally, an independent contractor is not considered an employee, but the Small Business Administration will treat an independent contractor as an employee where there is evidence of an employee/employer relationship.
	44	If W-2 employment is strictly required, does the written deviation option referenced in the same certification ("or has requested and received a written deviation from this requirement from the Funding Agreement officer") provide a pathway for companies whose Project Director is an independent contractor rather than an employee? If so, what percentage figure would be entered in the deviation field?	No, the Project Director must be “primarily employed” by the applicant small business during the SBIR award period and cannot be an independent contractor.
	45	<Refers to Question 44> If neither of the above is available to us, what steps would you recommend a small business take to meet this requirement prior to submission?	The offeror must make the determination of how to meet employment requirements.
	46	Is personal financial literacy / financial capability an eligible content area under the FY2026 Phase IA solicitation?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	47	Would the dual-axis adaptive mechanism described above — mastery-based routing combined with AI-generated, locally contextualized scenarios using live financial data — be considered sufficiently novel under the Phase IA requirement that "no or limited previous technological development has occurred," given that individual components of adaptive learning exist broadly but this specific combination applied to personal financial literacy does not appear to exist in the current market?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	48	Our small business has developed a working software prototype (not yet deployed in any school) as part of our R&D process. Does the existence of an internal prototype that has not been commercially deployed or previously funded by the government qualify under the Phase IA requirement of "no or limited previous technological development"?	For projects with some limited previous technological development, offerors should consider the nature and amount of the prior development in determining the goodness of fit for a proposal under the Phase IA program. In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
	49	Are letters of support or commitment from pilot school partners required to be included with the proposal at the time of submission, or may pilot partnerships be established during the 9-month project period if awarded?	Letters must be included with the proposal at the time of submission.
	50	For the Section E letter from an education setting that will host the Phase I pilot research, I would like to confirm the acceptable signatory level. Specifically:

If the pilot research would take place at a public elementary school within a school district, is a letter signed by the school principal sufficient to satisfy the Section E requirement, or does the letter need to be signed by a district-level administrator (e.g., superintendent, research and accountability director) with authority over the entire district?	The letter from an education setting should be signed by an individual with the authority to make decisions about participation in research.
	51	Does a postsecondary learning tool that applies multimodal AI feedback loops specifically to mitigate public speaking anxiety fall within the eligible scope for the Phase IA Social/Behavioral training focus areas?	The offeror must make the determination if a proposal is a good fit for the Phase IA competition. See the solicitations for guidance and specifications about the priority areas. ED/IES SBIR makes awards for new education technology products to improve education, and these products take many forms.
	52	Since our underlying adaptive feedback engine integrates a licensed federal technology transfer framework, are there specific commercialization metrics in the IES review criteria we should target to best present this institutional de-risking?	We cannot answer this question at this time, as it would give an unfair advantage during the solicitation and evaluation phase. Per U.S. Government Federal Acquisition Regulations (FAR), ED/IES SBIR program personnel and other government personnel are not permitted to engage with potential offerors to provide technical assistance while the solicitations are open or during proposal review.
	53	My small business has previously developed an education technology product (REDACTED 1) that synthesizes Maryland-specific Blueprint policy data and education research into searchable document outputs for state and district stakeholders. The product I propose to develop under Phase IA — REDACTED 2 — is a generative-AI strategic-planning engine that produces customized school-improvement plans for district administrators by combining three independent inputs: implementation-research evidence, improvement-science methods, and district fiscal data. The two products differ in:
•	Technological approach: REDACTED 2 is a document-classification and retrieval pipeline (crawler + LLM-based scoring + RAG search). REDACTED 2 would be a generative plan-construction engine using a different architecture (multi-source structured synthesis with a planning DSL).
•	End-user and use case: REDACTED 1 serves researchers and policy staff searching existing documents. REDACTED 2 would serve district leaders generating new plans.
•	Geographic / domain scope: REDACTED 1 is Maryland-Blueprint-specific. REDACTED 2 would launch in a different state (Delaware) and a different domain focus (early-literacy implementation).
My question: under the Section A.Q certifications — specifically the third and fourth bullet certifications, which ask whether the proposed product will be (a) independent from and (b) employ a different technological approach from any existing product previously developed by the small business — is the distinction described above sufficient to certify "Yes" to both bullets? Or does the Phase IA novelty requirement contemplate a higher bar of domain or technical separation that I should be aware of when scoping the proposal?	We cannot answer this question at this time, as it would give an unfair advantage during the solicitation and evaluation phase. Per U.S. Government Federal Acquisition Regulations (FAR), ED/IES SBIR program personnel and other government personnel are not permitted to engage with potential offerors to provide technical assistance while the solicitations are open or during proposal review.
	54	Is it possible to have a multiple program director proposal?	Only one individual may serve as the Project Director. Co-Project Directors are not permitted.
	55	Is an STTR mechanism allowed at Dept. of Education?	The Department of Education does not offer an STTR program.
	56	The certification states that the Project Director will spend "more than one half of their time (based on a 40-hour workweek)" as an employee of the Awardee during the performance of the award.

Our intended Project Director works professionally across more than one organization. We would like to clarify what "more than one half of their time based on a 40-hour workweek" means in practice. Specifically:

1. Does the requirement mean that more than 50% of the time the Project Director spends working on REDACTED SBIR PROJECT must be dedicated to the SBIR project? Or,

2. Does the requirement mean that more than 50% of the Project Director's total professional working hours across all engagements must be dedicated to the SBIR project?	During the performance of the award, the Project Director must spend more than one half of their working time (based on a 40-hour workweek) as an employee of the Awardee.
	57	It states that this solicitation can be used for novel education technology products for educator or administrator. Please confirm that administrator can include products designed for improved administration and operation of a school, local education agency, or state education agency.	Novel education technology products for educator or administrator use (or other school personnel use) must be intended to either: (a) facilitate instruction; (b) improve the efficiency or accuracy of day-to-day administrative tasks or responsibilities; or (c) support decision making on the selection, implementation, or evaluation of interventions including practices, programs, or policies.
	58	The additional specification section cites learning product examples in the classroom or after school. Please confirm again that this solicitation does not exclude products that improve school, LEA, or SEA administration and operational offerings.	The solicitation does NOT exclude products that improve school, LEA, or SEA administration and operational offerings.
	59	This section cites the font size requirements of no less than 12 point. Does the font size requirement also apply to tables and figures. If not, what minimum letter size needs to be adhered to for tables and figures?	Figures, charts, graphs, tables, or screen shots (outside of what is requested in other sections) are permitted to use 10-point font size. Please note however – reviewers need to be able to be able to easily read what is presented by offerors.
	60	This section identifies the identification of Woman-owned SBC Certification. If certification is pending at the time of submission, can one still indicate “Yes” for this status.	Please only indicate "Yes" when there is a confirmed certification.
	61	This section notes a requirement for data security moderate risk/public trust clearance process. If a project does not have direct contact with students but does work with anonymized student data from a data system, does the project team need to go through the clearance process? If the project team members do need to go through clearance process, is this required upon or right after contract award? What timeframe should a project team allocate for the clearance process in terms of the project plan?	Typically, a security clearance is only needed for those working directly with students and/or working with personally identifiable data. The need for a security clearance will be determined after the contract is awarded. The security clearance process can take a few months but this varies.
	62	Does this section (Questions 1-18 on pages 44-46) need to be completed and included in the submission of the proposal or at the time of contract award?	Yes, you are required to complete the SBIR/STTR Funding Agreement Certiﬁcation to include with the submission.

	63	If the prime company submitting a bid is not Majority Owned by a Multiple Venture, does the applicant need to complete checkboxes #1 through #8 on page 48? If the applicant is expected to complete those questions, regardless of whether it is majority owned by a Multiple Venture, how does the applicant treat the following statement when it does not apply? - The Applicant is more than 50% owned by multiple domestic business concerns that are VCOCs, hedge funds, or private equity firms	Any small business that is majority-owned by multiple venture operating companies (VCOCs), hedge funds, or private equity firms and is submitting an application for an SBIR Funding Agreement must complete this certification prior to submitting an application. Small businesses that are majority-owned by multiple Venture Capital Operating Companies (VCOCs), hedge funds, or private equity firms are eligible to participate in the SBIR program, provided no single investor owns more than 50% of the company.
	64	If the applicant has not received any Phase II awards in the past, is there any action or information that the applicant needs to complete as part of the proposal submission?	Phase I awards that were not followed by a Phase II award for the same product should be reported in Part III of SECTION G: Documentation and Status of SBIR Phase I and Phase II Awards Since 2010.
	65	Does the applicant organize the initial IRB review or is the IRB organized by the applicant?	All projects must undergo initial Institutional Review Board (IRB) review for the protection of human subjects prior to conducting any pilot research with users. Initial review will determine whether the research activities require compliance with ED regulations outlined in 34 CFR 97.102, or are exempt. Grounds for exemptions differ for adult versus child participants. Whether the protocol is exempt and if so, on what grounds must be reported to ED post-award.
	66	Do the questions (#1 through #10) shown on pages 83 through 86 need to be completed as part of the Section J proposal submission or are these questions strictly completed post contract award and are not needed for the initial proposal submission?	SECTION J. Required Certifications to Complete Now at the Time of the Proposal” lists certifications that must completed within the proposal that is submitted. These certifications are also required at points during an award.
	67	If one small business submits as a prime contractor for a distinct project but that same small business is included as a subcontractor for another applicant who is submitting a proposal for a different and separate project, does the US DoED SBIR have any issues to evaluate these two proposals? Would there be any reason for disqualification between the two applicants’ and their corresponding proposals?	No, offerors are permitted to submit multiple proposals under either or all solicitations provided the proposals have different foci.
	68	Independence Statement & Use of Research Datasets
The solicitation states that the proposed "novel education technology product" must be "independent from (will not be integrated with) any other existing education technology prototypes or products previously developed by the small business (or a member of the project team)." Does this restriction apply to the data or datasets used for AI model training? specifically, if REDACTED LLC utilizes existing academic research data or biomarker datasets (licensed from a university or research institution) to train our proprietary engine, but the technology and product itself are novel developments created solely by REDACTED LLC, does this violate the "independence" requirement? We want to ensure that leveraging licensed or open data to train a new product does not disqualify us from the Phase IA "novelty" track.	The novelty requirement refers to the product itself.
	69	IRB Timing & Human Subjects
Regarding the Common Rule (34 CFR Part 97) and human subjects protection: Please confirm that while the plan for IRB submission must be detailed in the proposal narrative, the actual IRB approval or exemption determination is an administrative milestone to be completed during the first 30–60 days of the performance period. We are assuming the IRB letter itself is not required to be submitted with the proposal package on June 29, 2026. Is this interpretation correct?	Proof of IRB approval is not required for proposal submission.
	70	Budget Allowability for Data & Contractors
Regarding the $250,000 Phase IA budget: Are costs associated with (a) licensing existing academic research datasets for biomarker model training, and (b) retaining Subject Matter Experts (SMEs) as independent contractors (1099) for specialized consultation, considered fully allowable direct costs under this solicitation?	Expenses that are allowable include all costs for research and development and evaluation of an education technology product, including direct and indirect costs. Awardees may use up to $6500 in Phase I and up to $50,000 in Phase II for Technical and Business Expenses to prepare for commercialization. See Part III. Proposal Contents, Paragraph I “Technical and Business Assistance Plane (TABA)” for information on the types of expenses that can be budgeted through TABA. Projects may charge a reasonable profit, although offerors must ensure that sufficient funds are budgeted for activities to ensure that the project will be successfully completed as the principal goal of the award.
	71	Moderate Risk/Public Trust clearance applicability for projects with no PII access or student contact Reference: pages 16 and 28 (Section C, Project Team and Company); page 114 (contract clause H.16, Contractor Security Vetting Requirements). Reference: pages 16 and 28 (Section C, Project Team and Company); page 114 (contract clause H.16, Contractor Security Vetting Requirements). For a Phase IA SBIR project where the Project Director and all project team members will have no contact with students and no access to non-public student data or PII (for example, a project analyzing only publicly available K–12 district website content): 1. Is the Project Director required to complete the Moderate Risk/Public Trust clearance process based on the pre-designated Moderate Risk classification, or may ED determine that no Moderate Risk clearance is required where there is no student contact or PII access? 2. If Moderate Risk/Public Trust clearance is not required for those roles, does the U.S. citizenship requirement still apply, or are permanent residents eligible under a Low Risk/Public Trust designation? 3. Do the answers affect any proposal-stage certifications, disclosures, or résumé information we should include?	Typically, a security clearance is only needed for those working directly with students and/or working with personally identifiable data. The need for a security clearance will be determined after the contract is awarded. All work on the contract must be conducted by individuals who are located within the United States who are either citizens or hold a green card. Individuals who are in the United States without citizenship, visa, or green card, and U.S. citizens working outside the U.S. are not eligible to conduct work on the contract.
	72	Definition of “limited” prior development for prototypes tested only by the developers

Reference: page 7 (What is “Limited” Previous Technological Development).

The solicitation describes prototypes that function “only when handled by a developer in a laboratory setting but not by an end-user in an education setting without developer assistance.” If a software prototype has been tested only by the developers (not by end-users in any setting, and not in any laboratory or education-setting study), does it qualify as “limited” prior development for Phase IA? Or does the absence of laboratory or education-setting testing make the project ineligible?

In cases where “limited” technological development has already occurred, the prototype should not yet be usable by end-users (e.g., learners, educators, administrators) without the assistance of the developer. Please see the solicitation for more details.
73	IRB pathway when a named subcontractor has an existing FWA and IRB-of-record

Reference: page 30 (Section D, Phase IA Budget).

If a named subcontractor on a Phase IA proposal has an active Federal-Wide Assurance (FWA) and an established IRB-of-record:

1. May the pilot study be reviewed under the subcontractor’s FWA through an IRB Authorization Agreement (IAA)?

2. May the IRB review costs sit within the subcontractor budget?

3. Or must the offeror obtain its own FWA and engage a separate IRB regardless of the subcontractor’s existing IRB infrastructure?

Yes, the Institutional Review Board (IRB) process can be facilitated through the subcontractor. For offerors who do not have an in-house IRB, funds must be allocated to support a third-party review of human subjects’ involvement in the pilot study
74	YouTube video timestamp interpretation

Reference: page 15 (Section B, Video Demonstration Requirements).

The solicitation states that “if the posting date on YouTube for the video is later than the submission date on June 29, 2026, at 11 a.m. Eastern Time (ET), the video will be deemed ineligible for inclusion in the review process.” The phrase “later than the submission date on June 29, 2026, at 11 a.m. ET” can be read two ways: (a) later than the offeror’s actual submission date and time, or (b) later than the June 29, 2026 11:00 a.m. ET deadline.

To confirm: if an offeror submits a proposal on June 25, 2026, and the referenced YouTube video is uploaded on June 27, 2026 (still before the June 29 deadline), is the video eligible? Or must the upload timestamp precede the offeror’s actual submission timestamp?

The YouTube video should be uploaded before the submission deadline on June 29 at 11 a.m. ET.
75	SBC Registration Control ID Form attachment format

Reference: page 19 (Section A Item T, SBA Company Registry); page 92 (Proposal Checklist).

Please clarify whether…

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