For an NSF SBIR phase I, I understand that 1/3 of the budget can be used for consultants and CROs (does this fall under subcontractors?).
In the case of CROs, the company needs to be US based. However, I am unclear about this definition given that many CROs in my field are international, and so while they have sites (perhaps even headquarters) in the US, they do work outside of the US as well.
Is there a more solid definition of what constitutes a US CRO for the purposes of a NSF SBIR?
Depending on the scope of work, CROs can either fall under subcontractors or Fee-for-service (see Line item G6 for NSF budget guidelines). Most of the times, fee-for-service is the best category as CROs are often used to complete work tasks that require specialized equipment or facilities that are not available to the applicant, but the work is carried out to the applicant’s specifications and is considered “routine”. However, if the CRO would contribute a considerable amount of original input (innovation), it would be best captured under a subcontract.