Responses_Amendment_0001.pdf

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Attached to: Small Business Innovation Research (SBIR) - 2017 Phase I - ED-IES-17-R-0004
Solicitation number: ED-IES-17-R-0004
Issued by: Department of Education Contracts and Acquisition Management

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December 20, 2016

Request	for	Proposals	ED‐IES‐17‐R‐0005	Small	Business	Innovation	Research
Program	(SBIR)	Phase	I	Amendment	0001

Closing Date: January 5, 2017 2:00 P.M. ET

U.S.	Department	of	Education’s	(Department	or	ED)	responses	to	clarification
questions	submitted	by	December	5,	2016,	2:00	P.M.	ET:

WARNING!	Offerors	must	note	that	there	are	email	attachment	size	restrictions.	The
Department	of	Education	cannot	accept	attachments	larger	than	25	MB.	The
Government	is	not	responsible	for	attachment	size	restrictions	that	may	exist	on
offerors'	email	servers!	Offerors	are	advised	to	check	with	their	provider	for
information	on	email	size	restrictions	and	plan	accordingly.

offerors

attempt

submit

proposal

Kevin.Wade@ed.gov

and

receive

error

message,

they

MUST

contact

Kevin

Wade

PRIOR

THE

CLOSING

THE

SOLICITATION

during

standard

business

hours

(8:00

A.M.

5:00

P.M.

ET,

Monday

through

Friday).

The

solicitation

closes

promptly

2:00

P.M.

ET,

January

2017.

Late

proposals

will

not

accepted.

1. Are

there

any

changes

from

the

2016

competition?

looks

the

same

me.

noted

two

major

changes:

less

reliance

theory

change;

new

reliance

peer

reviewed

publication;

inclusion

reference

ESSA.

Does

that

sound

right?

Response: the SBIR solicitation is updated from year to year and may contain new content.

One

the

rules

the

solicitation

says

75%

the

prototype

must

developed

the

United

States.

have

unique

situation

was

hoping

get

clarification

on.

co‐founder

lives

Canada

and

Canadian

citizen.

The

rest

our

employees

are

American

citizens

and

are

located

the

United

States.

This

co‐founder

travels

and

out

the

United

States

for

long

periods

times

meet

with

us,

but,

lot

the

work

will

done

from

his

home.

Does

this

make

still

eligible

apply?

Response:

The

Small

Business

Administration’s

SBIR

Policy

Directive,

page

under

Eligibility

Requirements,

states,

“For

both

Phase

and

Phase

II,

the

R/R&D

work

must

performed

the

United

States.

However,

based

rare

and

unique

circumstance,

agencies

may

approve

particular

portion

the

R/R&D

work

performed

obtained

country

outside

the

United

States,

for

example,

supply

material

other

item

project

requirement

not

available

the

United

States.

The

funding

agreement

officer

must

approve

each

such

specific

condition

writing.”

The

funding

agreement

officer

(Contracting

Officer

CO)

does

not

find

that

this

situation

qualifies

rare

unique.

Also

see

the

response

question

#33.

3. The phase 2 of this award is for up to 2 years. Does that mean that the phase 2 award is for a

total

900,000

but

the

timeline

for

completion

can

years?

does

mean

that

grantee

can

awarded

900,000

for

year

and

900,000

year

for

total

1.8M?

Response: $900,000 in total over 2 years.

4. We

are

currently

working

through

submission

for

different

SBIR

through

the

NSF

for

educational

technology.

were

awarded

the

NSF

SBIR

would

there

any

conflict

with

submitting

for

this

one?

should

the

proposals

for

different

projects?

Response:

Offerors

may

submit

both

programs.

However,

doing

so,

offerors

are

only

allowed

funding

from

one

program

for

the

same

similar

work.

award

made

through

one

program,

the

offeror

must

notify

the

other

program

that

the

proposal

should

removed

from

further

review.

5. As

the

last

question

there

anything

that

prohibits

from

having

multiple

submissions

this

SBIR?

Say

both

are

educational

curriculum

one

STEM

based

game

and

the

other

interactive

history?

Response: No, provided the R&D work is not duplicative in any way.

6. Would

need

partner

with

university

educational

research

nonprofit

for

this

SBIR?

currently

have

partnerships

with

organizations

public

schools

and

education

technology

professionals

that

have

already

agreed

work

with

testing

our

solutions

and

giving

feedback,

allowing

pull

analytics

based

the

usage.

However,

none

are

part

university

setting.

that

acceptable

need

partner

with

other

research

firms

and

departments

the

university

level?

Response:	While	the	solicitation	notes	the	importance	of	qualified	education
researchers,	there	is	not	a	requirement	to	partner	with	outside	researchers.

7. I

was

looking

the

grant

for

educational

game

and

was

curious

this

was

strictly

for

existing

companies

can

anyone

apply

with

idea?

was

going

attempt

the

private

sector

with

but

would

try

and

this

route

instead.

Response:

Please

refer

the

Request

For

Proposals

(RFP),

Section

“Each

organization

submitting

proposal

must

qualify

small

business

concern

defined

the

SBA.”

8. Do

Principal

Investigators

need

employed

small

business

right

now,

just

soon

SBIR

approved

and

before

funding

granted?

have

read

some

other

agency's

SBIR

solicitation

where

this

was

explicitly

stated,

but

cannot

find

this

IES's

SBIR.

Response:

The

does

not

need

employed

the

company

the

time

the

proposal.

The

must

employed

the

company

least

51%

the

time

the

time

award.

9. Phase

R&D

will

primarily

tech

development,

and

one

our

PIs

tech

expert.

Our

education

experts

may

not

qualify

(because

time

she

can

commit

the

project)

but

will

part

our

key

personnel.

Would

this

sufficient

for

having

the

appropriate

experience

and

training

for

the

project?

Response:

noted

the

solicitation,

the

must

employed

the

company

least

51%

the

time

the

time

award.

Otherwise,

further

information

can

provided

outside

what

provided

the

solicitation.

10. I

would

check

see

write

all

answers

into

the

RFP

document

need

separate

document

website?

Response:	The	proposal	must	be	prepared	according	to	the	instructions	provided	in
Section	VI.	Proposal	Submission	Information.

11. When will the money be allocated to the contractor?

Response: Please review Section V. Considerations.

12. We

had

previously

registered

for

the

November

29‐30

conference

Austin

and

had

requested

schedule

one‐on‐one

meeting

this

time

discuss

our

proposal

for

Solicitation

ED‐IES‐

17‐R‐0004.

recently

were

notified

meeting

time

the

conference

would

not

available.

Alternatively,

would

possible

schedule

time

talk

per

phone

discuss

our

proposal?

Response:

During

the

time

when

the

program

solicitation

open,

the

ED/IES

SBIR

Program

Manager

not

permitted

provide

technical

assistance

potential

applicants.

13. I

want

include

father

team.

has

many

years

government

grant

experience

and

connections

few

universities

that

will

helpful

for

R&D.

Would

including

family

member

the

team

negatively

affect

chances

funding

(he

happens

have

the

same

name

me)?

Response: Involvement among family members on a proposal is permitted.

14. I

wanted

know

you

can

the

requirements

the

number

pages

that

can

turned

per

Appendix?

understand

that

there

are

certain

sections

that

have

included

the

15‐Page

project

narrative.

There

are

several

Appendices

that

are

not

included

with

the

15‐Page

narrative.

Please

let

know

how

many

Appendices

should

included

the

proposal

but

not

the

15‐Page

narrative.

Response:

There

not

prescribed

number

pages

for

the

full

proposal

including

the

cover

pages,

project

narrative,

and

appendices.

Appendices

are

not

counted

toward

the

15‐page

limit

the

project

narrative.

15. I'm

carefully

reading

through

the

solicitation

document,

but

want

avoid

any

major

miss‐

steps.

there,

any

chance,

sample

proposal?

particular

area

concern

for

providing

the

correct

level

detail

the

budget

justification

and

budget

spreadsheet.

other

words,

want

clear

the

expectations

how

Phase

project

should

conducted.

Response: No sample budgets are provided.

16. Is

there

any

way

review

the

submitted

proposals

small

business

that

won

last

year's

Phase

award

learn

what

winning

proposal

looks

like?

Response:

Offerors

may

submit

request

view

proposals

through

Freedom

Information

Act

Request

(FOIA).

Please

note,

proprietary

information

proposals

can

redacted

the

writer

the

proposal

prior

release

through

FOIA.

17. Can

single

proposing

firm

submit

multiple

RFP

responses

for

the

development

different

education

technology

products

that

fall

into

different

priority

areas?

possible

for

single

firm

awarded

multiple

RFP

awards

through

this

RFP

limited

one

award

per

firm?

Response:	Yes,	firms	can	submit	multiple	proposals	provided	the	proposals	are
different,	and	firms	are	eligible	to	win	multiple	awards.

18. The

RFP

states

that

the

proposing

firm

must

perform

least

two‐thirds

the

research

and/or

analytic

effort

but

can

partner

with

consultants

and

subcontracts

for

some

the

remaining

work

and

contract

price.

Are

there

any

eligibility

rules

around

the

types

consultants

and

subcontractors

can

used

and

paid

with

this

RFP

award

funding?

the

consultants

and

contractors

also

need

small

businesses?

Response:

There

not

requirement

the

solicitation

that

the

consultants

need

small

businesses.

19. Will there be different RFP evaluation committees and reviewers for the different priorities?

Response:

Yes,

different

reviewers

are

assigned

review

different

proposals.

Information

the

technical

evaluation

reviewers

can

found

Section

IV.

Method

Selection

and

Evaluation

Criteria

20. I

know

that

were

awarded

the

funds

would

give

rights

the

government

use

(SBIR

Technical

Data

rights).

Would

able

sell

this

public

school

districts

just

the

data

driven

from

the

research

that

the

governments?

guessing

are

protected

the

fact

that

based

off

our

copy

written

material.

Response:

While

the

clause

data

rights

indicate

that

the

agencies

have

the

right

utilize

data

developed

through

SBIR,

the

Department

Education

has

not

used

this

clause

the

history

its

program.

21. Because

are

monitoring

children

(human

subjects),

assume

must

include

all

the

human

subject

materials?

started

this

project

over

the

summer

and

were

wondering

awarded

the

funds

can

back

date

for

any

work

done,

and

how

far

back?

Response: Please refer to Appendix X for information on Human Subjects.

22. Finally,

read

something

about

having

location

for

research

and

development.

Since

business

in‐home

and

on‐campus

educational

consulting/tutoring

business,

work

out

home.

Would

need

find

actual

work

place

the

majority

the

research

would

the

school

that

would

use

our

project?

Response: Offerors may propose to work from a home or on campus.

23. If

our

company

uses

another

firm

the

programming

our

product’s

software

platform

our

R&D,

does

this

count

towards

the

one‐third

the

total

price

Phase

that

can

done

outside

our

firm?

Response: Yes, what is described would appear to count toward the one‐third requirement.

24. What information should be included on the cover page?

Response:

Details

what

required

included

the

cover

pages

are

included

Section

III.

Contract

Proposal

Preparation

Instructions

and

Requirement.

25. On

page

Section

letter

Our

product

will

new

product

and

have

not

built

yet.

Are

required

have

concept

test

prior

our

proposal?

Response:

The

solicitation

does

not

require

concept

testing

product

has

not

been

built.

The

solicitation

indicates

that

offerors

may

provide

concept

testing

results.

26. How do we apply for phase I and Phase II funding fast track funding to happen without any breaks?

Response: The Department is not offering a Fast‐Track program in FY2017

27. On

page

section

What

definition

professional

affiliations

should

using?

also

need

include

titles

each

person

too?

Response:	The	term	professional	affiliation	refers	to	the	company	or	institution	where
individuals	are	employed	or	work.	Titles	are	not	requested.

28. Can an organization submit multiple proposals? Within the same category?

Response: Yes, provided the proposals are different.

29. Can an organization be awarded multiple proposals? Within the same category?

Response: Yes, provided the awards are for different projects.

30. Can an organization be a prime and a subcontractor for multiple proposals and/or awards?

Response: Yes.

31. If

can

submit

multiple

proposals,

can

use

the

same

Letter

Agreement

for

Participation

for

each

proposal,

would

required

that

have

unique

school

for

each

proposal?

Same

question

applies

for

the

(maximum

Letters

Endorsement?

Response: The solicitation does not require separate letters.

32. If

are

awarded

Phase

grant,

can

transfer

from

the

Phase

awarded

entity

another

entity

prior

submission

Phase

grant

application

(in

preparation

for

commercialization

efforts)?

Response: The Department cannot provide guidance on this question.

33. While

understand

that

Phase

and

Phase

work

must

performed

the

United

States

based

company,

can

have

team

members

that

reside

the

but

are

not

Citizens?

Response:

conceivable

that

team

member

resides

the

U.S.,

but

not

citizen;

however,

from

the

Small

Business

Administration’s

SBIR

Policy

Directive,

50,

“The

birth

certificates,

naturalization

papers,

passports

show

that

any

individuals

relies

upon

meet

the

eligibility

requirements

are

U.S.

citizens

permanent

resident

aliens

the

United

States.”

34. Can

you

clarify

how

the

grant

funding

will

disbursed

upon

award?

Since

(the

offering

company)

has

limited

funds

startup,

the

company

would

need

some

money

front

begin

research

development

activities.

Response: The payment schedule is listed in Section V. Considerations.

35. Regarding

the

forms

required

for

Appendix

(RFP

60),

are

expected

out

the

forms

the

RFP

and

include

them

our

single

PDF

for

submission

can

this

information

submitted

online

somehow?

For

example,

how

attach

the

SBIR.gov

SBC

Registration

Control

Certification

G.2

required

page

63?

Response: All required forms must be included as part of the single proposal package.

36. One

last

question,

should

the

1‐page

resumes

adhere

the

General

Format

instructions

shown

page

the

RFP?

Response: Offerors can format the 1‐page resumes as they choose.

37. Re.

the

Letter

Agreement

from

authentic

education

setting,

statement

confirming

participation

the

research

process

enough?

are

any

additional

details

required?

Response: The solicitation does not require.

38. What

agreements,

any,

you

need

from

subcontractors

(other

than

certifications

from

subcontractor

key

personnel)?

Response:	The	solicitation	does	not	require	any	forms	or	agreements	from
subcontractors.	Offerors	are	reminded	the	Background	Investigation	Requirement	(RFP
p.	32)	also	applies	to	subcontractors	or	consultants.

39. Recent

SBIR

awards

made

ED/IES

have

focused

K‐12

education.

Are

Adult

Education

concepts

being

considered

for

award

under

this

solicitation?

Response:

See

Section

IX.

Priority

Areas

for

information

proposals

the

area

adult

education.

40. I

have

question

about

collaboration

with

partner

educational

institution.

small

business

will

creating

the

films

and

curriculum

materials

and

testing

the

prototype

classrooms.

The

educational

partner

has

expertise

designing

the

instrument

for

evaluation,

which

would

used

determine

the

effectiveness/impact

the

materials

kids

different

ages.

company

would

actually

conduct

the

piloting

and

evaluation.

checking

make

sure

that

balance

work

appropriate

for

this

grant

application.

Response:

Provided

the

offering

firm

budgets

least

two‐thirds

the

funds,

there

further

guidance

the

division

tasks

for

the

project.

41. I

had

question

the

grant

contractor

payout.

According

the

RFP,

states

payment

cycles

will

made.

First

payment

days

after

startup,

second

payment

days

into

program

and

final

payment

days

after

the

conclusion,

this

correct?

And,

all

expenses

needed

service

the

grant

are

the

contractors’

responsibility?

Response:

The

payment

schedule

described

the

question

correct.

The

awardee

responsible

for

all

expenses

and

costs.

42. What do you mean specifically about an 'authentic' educational setting?

Response:	Taken	directly	from	the	IES	Research	Grants	program’s	2017	Request	for
Applications	at:	http://ies.ed.gov/funding/pdf/2017_84305A.pdf,	Authentic	Education
Settings	are	defined	as	follows:

Proposed

research

must

relevant

education

the

United

States

and

must

address

factors

under

the

control

the

U.S.

education

system

(be

the

national‐,

state‐,

local‐,

school‐level).

help

ensure

such

relevance,

the

Institute

requires

researchers

work

within

with

data

from

authentic

education

settings.

Authentic

education

settings

include

both

in‐school

settings

(including

PreK

centers)

and

formal

programs

that

take

place

after

school

out

school

(e.g.,

after‐school

programs,

distance

learning

programs,

online

programs)

under

the

control

schools

state

and

local

education

agencies.

Formal

programs

not

under

the

control

schools

state

and

local

education

agencies

are

not

considered

taking

place

authentic

education

setting

and

are

not

appropriate

for

study

under

the

Education

Research

Grants

program.

The

Institute

permits

limited

amount

laboratory

research

(see

Part

III

Research

Goals)

carried

out

addition

work

within

with

data

from

authentic

education

settings,

but

will

not

fund

any

projects

that

are

exclusively

based

laboratories.

Authentic education settings vary by education level and are defined as follows:

Authentic Pre‐K Education Settings are defined as center‐based prekindergarten settings, which include the following:

o Public prekindergarten programs o Child care centers o Head Start programs

Authentic K‐12 Education Settings o Schools and alternative school settings (e.g., alternative schools or juvenile justice settings) o School systems (e.g., local education agencies or state education agencies) o Settings that deliver supplemental education services (as defined in Section 1116(e) of the Elementary and Secondary Education Act of 1965, as amended by the No Child Left Behind Act of 2001) (http://www2.ed.gov/policy/elsec/leg/esea02/index.html) o Career and Technical Education Centers affiliated with schools or school systems

Authentic Postsecondary Education Settings o 2‐year and 4‐year colleges and universities that have education programs leading to occupational certificates or associate’s or bachelor’s degrees.

o Career and Technical Education Centers affiliated with postsecondary institutions.

Authentic Adult Education Settings are those where eligible providers (e.g., state and local education agencies, community‐based organizations, institutions of higher education, public or non‐profit agencies, libraries) identified under Title II of the Workforce Innovation and Opportunity Act (WIOA: https://www.gpo.gov/fdsys/pkg/PLAW‐113publ128/pdf/PLAW‐ 113publ128.pdf) provide one or more of the following:

o Adult English language programs.

o Adult Basic Education (ABE).

o Adult Secondary Education (ASE).

o Programs that assist students who lack secondary education credentials (e.g., diploma or GED) or basic skills that lead to course credit or certificates.

43. We

are

currently

exploring

secondary

purpose

our

product,

which

supporting

children

with

autism.

Although

are

just

exploring

this

area,

would

this

something

worthwhile

apply

for

the

grant?

Response: No guidance can be provided related to this question.

44. The

artificial

intelligence

software

are

creating

really

the

core

our

product

that

think

will

able

some

really

cool

stuff

that

theory

could

span

from

early

childhood

through

high

school,

and

potentially

even

have

use

for

administrators,

there

anyway

can

frame

the

R&D

potential

this

technology

apply

for

SBIR?

Response: No guidance can be provided related to this question.

45. My

question

about

the

format

submissions.

The

RFP

indicates

that

submissions

may

Word

PDF

format.

However,

several

signatures

are

called

for.

Should

take

this

mean

that

"actual"

hand‐written

signatures

are

not

required

applicant

wishes

submit

Word

document?

Response:

Offerors

should

include

signatures

their

proposals.

Signatures

can

embedded

electronically

with

proposals

offerors

may

out

forms,

sign,

scan,

and

save

the

components

the

proposal

PDF.

46. I

interested

applying

for

the

Small

Business

Innovation

Research

grant.

there

application

form?

Can

you

tell

how

about

starting

the

application

process.

Response: Please see:

https://www.fbo.gov/index?s=opportunity&mode=form&id=0957820fb556d351ce0c3 8a7dcbc58dc&tab=core&_cview=0

47. I

was

able

sam.gov

but

when

attempted

registering

with

grants.gov,

asked

for

the

opportunity

number

and

wouldn't

the

solicitation

number

its

place.

Can

you

let

know

what

the

opportunity

number

for

this

application?

Response: This solicitation is through a contracts mechanism, not a grant.

48. Is

there

requirement

that

our

partners

have

non‐profit

organizations

universities?

Are

for‐profit

LLC

organizations

allowed

partner

this

proposal?

Response: There is no such requirement.

49. Are we required to have a university partner to develop our technology?

Response: There is no such requirement.

50. If we hire contractors will they be considered 1099 employees, subcontractors, etc?

Response: Subcontractors.

51. What can the budget cover? Materials, Equipment, Personnel, small business fee, travel, and consultants?

Response:	Potential	offerors	should	refer	to	the	solicitation	and	the	SBIR	Policy
Directive	for	information	on	what	can	be	included	within	the	budget.

52. Can

the

User

Interface

Design

developed

only

the

backend

technology

make

the

product

functions?

Response: No guidance can be provided related to this question.

53. What Are the Qualifications of the PI?

Response:

Potential

offerors

should

refer

the

solicitation.

further

guidance

can

provided

this

question.

54. Is there a Procedure's Guide?

Response: No guidance can be provided related to this question.

55. Would

you

please

help

understand

this

part

the

instructions?

will

use

two

external

consultants

(which

will

fall

below

the

maximum

33%

allowed

for

subcontractors)

and

key

personnel

will

work

this

project.

Here

the

excerpt:

NOTE:

While

biographical

summaries

must

included

within

the

15‐

pages,

Appendix

must

also

include

two

certifications

and

1‐page

resumé

for

each

the

key

personnel

listed

above

Project

Team.

Would

you

please

let

know

which

certification

this

refers

(or

not

the

below,

then

which

certifications

this

referring

to)?

And

also,

please

confirm

that

each

key

employees

will

have

individually

provide

these

certifications.

G.10

FAR

52.222‐54

–

Employment

Eligibility

Verification

(in

the

grant

document

page

73)

G.11	EDAR	3409.570	Conflict	of	Interest	(page	76)
G.12	EDAR	3452.239‐72	Department	Security	Requirements	(page	77)
G.13	FAR	52.204‐10	–	reporting	executive	compensation	and	first‐tier	subcontract	awards
(page	78)
G.14	FAR	52.209‐5	Certification	Regarding	Responsibility	Matters	(Oct	2015)

Response:

The

two

certifications

required

for

each

member

the

project

team

are

within

the

bordered

box

Appendix

the

RFP.

The

other

clauses

listed

the	question	above	are	for	the	authorized	representative	of	the	offeror	to
complete/acknowledge/submit	as	appropriate.

56. Do

offerors

include

Table

Contents

contained

pages

ii,

iii

the

proposal,

should

reside

elsewhere

the

proposal,

should

the

proposal

not

include

Table

Contents?

Response: Offeror should not provide a Table of Contents.

57. I

confused

and

hope

you

can

help

regarding

how

respond

several

Appendix

requirements

our

submission,

specifically:

G.9

–

include

all

the

text

through

the

Certification

just

the

certification.

the

whole

text,

then

where

would

find

(a)(1),

(a)(2).

For

(b)

does

52.204‐7

apply?

G.10,

G.12,

G.13,

G.16,

G.17,

G.18,

G.19

–

include

all

the

text

through

the

Certification

just

the

certification?

G.15

–

assume

that

since

need

check

(b)

that

the

text

its

entirety

must

included.

(correct?)

Response:

For

G.9,

(a)(1),

the

anticipated

NAICS

code

541720

(Research

and

Development

the

Social

Sciences

and

Humanities);

however,

possible

that

another

NAICS

code

applicable

based

the

actual

product

the

offeror

producing.

the

offeror

unsure,

safe

assume

541720

would

apply.

The

answer

(a)(2)

depends

the

choice

for

(a)(1).

The

size

standard

for

NAICS

541720

$20.5M.

The

Small

Business

Administration

also

limits

the

size

the

company

500

employees.

FAR

52.204‐7

does

apply.

It is recommended to include the full text as much as possible for clarity.

58. One

our

employees

would

and

move

the

new

concern

51%

order

qualify.

Would

this

arrangement

any

cause

for

concern

eligibility

competitive

issues?

Response:

With

the

information

that

was

provided

the

question,

would

not

appear

that

there

are

any

potential

issues

with

this

arrangement.

59. How

the

51%

effort

calculated?

Would

hours

the

small

business

and

hours

another

organization

satisfy

this

requirement?

Response: 51% effort would be calculated based on a 40‐hour work week.

60. I

currently

preparing

educational

research

grant.

Most

new

curriculums

need

approved

the

superintendent

and

this

takes

time.

Because

the

holidays,

many

schools

will

Friday

and

not

reopen

until

January.

For

this

reason,

not

sure

can

secure

letter

January

5th

(though

working

hard

so).

Please

let

know

one

following

option.

Turn

the

letter

later

January

include

statement

promise

within

the

proposal

that

school

will

participate

research.

Response:	The	solicitation	requires	a	letter	of	participation	within	a	proposal.	No
additional	information	can	be	added	to	a	proposal	after	submission.

File details come from the government source that posted it. Updated Nov 14, 2017.