The UI generally owns the research data generated from all research, development, and related activities conducted under its oversight. Research data, materials and results may be shared through an appropriate contractual agreement between UI and the startup if permitted by the research agreement under which the data were generated. Generally, data may be shared through a data use agreement (DUA), sponsored research agreement or subaward agreement.  Tangible research materials such as biological materials or model organisms may be shared through a Material Transfer Agreement (MTA) or a license from UIRF for internal research purposes.   Contact the Division of Sponsored Programs (DSP) to determine which agreement type may be appropriate.

Startup space in Bioventures or TRI  have access to shared equipment as a condition of the lease. Use of University owned equipment or assets by companies outside of leased space or rental of UI equipment may be allowed if there is additional capacity beyond what is needed for University directed activities AND the companies pay for access to these resources.

University faculty and staff owned startups and other external companies have access to core facilities on campus. Priority for the use of core facilities will go to institutional needs. Core facility use fees will be dependent on the status of the company as outlined below.

Companies may not conduct human subjects research in UI space, including leased space or in designated incubators. Companies may, however, sponsor human subjects research  through a Sponsored Research Agreement routed through and negotiated by DSP.

Considerations for startup-sponsored human subjects research

• Conflict of Interest (COI) requirements apply. 
  • Individuals employed by both UI and startup may not be allowed to participate in human subjects research or may do so only through COI management plan approved by Vice President for Research.  This includes individuals who are employed by UI and have an ownership interest in the startup. 
• Company employees may not be listed as a UI research team member or serve as the Principal Investigator of the sponsored research agreement 
• Companies or individuals “engaged in research” per Common Rule criteria must enter into an appropriate reliance relationship with UI IRB (Institutional Review Boards) or seek IRB approval from a commercial IRB for the contracted research 
• As “Sponsor” of the research, companies are responsible for CT.gov registration and reporting requirements unless formally delegated to the University of Iowa Principal Investigator in the sponsored research agreement
• Research results, data and specimens may only be shared with Company through an appropriate Sponsored Research Agreement (SRA) or DUA
  • Company is responsible for appropriate security requirements for data/specimen storage
  • Consent forms must indicate that data/specimens will be shared, how they will be used, and what will happen to their data/specimens at the conclusion of the research   

The University has established an Animal Care and Use Program which is overseen by the Institutional Animal Care and Use Committee (IACUC) for all animal use at the University of Iowa. To foster economic development within the State of Iowa, the University is also willing to make these services available to qualified University of Iowa faculty/staff owned startup companies for a fixed period, up to five years. The Office of Animal Resources will provide animal husbandry, regulatory review and oversight and veterinary services to such startup companies on a fee for service basis. 

Startup companies may also contract animal research to University collaborators using a research services agreement. View service fees (HawkID login/password required).

Safety oversight is the responsibility of the company owner. Companies leasing space from the University must adhere to all relevant state and federal regulations and acquire and maintain any necessary licenses or permits, such as those for radiation use or import/transport. Companies are responsible for maintaining an accurate chemical inventory with EHS Assist for University reporting purposes; chemical inventories must be reviewed annually and documented within EHS Assist. 

Visit the  Environmental Health and Safety (EHS) website for a list of services and their associated fees. Radiation and waste service agreements must be signed for related services to occur. EHS will not conduct audits or reviews of safety programming, regulatory compliance, or training for the company.

The company is responsible for mitigation of any damage, contamination, etc., to the leased University space, as well as the disposal costs associated with all radioactive and other hazardous wastes. 

Sponsored Research Agreements (SRA) are a mechanism for the startup company to contract for work to be performed by University personnel using University facilities and resources. A startup company may sub-contract to the University from Small Business Innovation Research (SBIR), Small Business Technology Transfer (STTR) or similar awards for which the company is the prime awardee and may also use their own funding to contract with the University  for the provision of research services. 

Considerations for Sponsored Research Agreements        

• An Individual cannot be named as PI (Principal Investigator) for the startup company and for the University on an agreement
• The University PI cannot provide signature authority or administrative oversight of the project for the startup company, or negotiate terms on behalf of the company
• When a company applies for federal or other sponsored funding and plans to contract with the University to perform a portion of the research, the University PI must route the subaward proposal for the University  portion of the work before company submission to the sponsor
• Companies are responsible for proposal development and submission requirements, including SAM (System for Award Management) registration, use of sponsor system, etc.
  • Company may not use UI personnel for proposal development activities
  • DSP (Division of Sponsored Programs) or departmental research administration cannot register the company or company employees in external sponsor systems
  • Entrepreneurs may work with BioConnect Iowa to prepare their SBIR/STTR applications
• Agreements to the University must include the appropriate F&A
• The startup is encouraged to obtain their own professional services for legal advice, accounting and financial reporting, proposal development, etc.

Subawards from the University to startup companies should follow these guidelines:

• An Individual cannot be named as PI for the startup company and for the University on the subaward agreement
• The University  PI cannot provide signature authority or administrative oversight of the project for the startup company. The Univeristy PI cannot negotiate subaward terms on behalf of the company.
• The company’s address, phone, and email cannot be a University address, phone, or email unless the company has an agreement with the University to lease University space, phone service, and email. Contacts or key personnel for the company cannot use a University address, phone, or email unless they are company employees, and the company has an agreement with the University to lease University space, phone service, and email. 
• The outgoing subaward procedures, roles, and responsibilities apply the same as for other subawards issued by the University.

Conflict of interest in research involves situations in which an investigator has a financial interest that may compromise, or have the appearance of compromising, professional judgment in the design, conduct, or reporting of research. Holding equity in a non-publicly traded company or receiving payments > $5000 in past twelve months AND participating in research in which that company has an interest in the outcome (sponsoring the research or utilizing technology licensed to the company) creates a significant financial interest according to University of Iowa Conflicts in Research Policy and federal regulation. Investigators are required to disclose financial interests in eCOI prior to initiating research, regardless of the funding source. The policy also requires investigators to disclose new financial interests that arise within 30 days of the occurrence of the new interest. The COI team will work with investigators to create a management plan, if possible.

Investigators who conduct studies regulated by the Food and Drug Administration or who conduct research funded by the other federal agencies, including the National Science Foundation, are subject to agency-specific regulations relating to financial conflicts of interest in research.

Faculty members are encouraged to participate in entrepreneurial activities but must also ensure that the activities do not compromise their ability to fulfill university duties. A "conflict of commitment" may occur when a faculty member engages in an "external activity" which requires time and/or effort such that the activity interferes, or appears to interfere, with fulfillment of the faculty member's obligations to the University. Faculty members are expected to disclose their involvement with startup companies in eCOI to comply with the UI Conflicts of Commitment Policy.  If the college determines that engaging in the external activity poses a conflict of commitment, they will work with the faculty member to develop a written management plan. 

When an employee supervises someone at the UI, and that other individual also holds an ownership interest in the employee’s startup company, the Conflict of Interest in Employment (Nepotism) policy applies. An outside significant business relationship (such as co-owning a startup) may influence, or appear to influence, decisions made in the UI supervisory role. For example, consider a scenario in which two faculty members co-own a startup and one of the faculty members is the DEO (Departmental Executive Officer) of the department where the second faculty member is also appointed. Disagreements related to the startup could potentially influence the DEO’s decisions about the other faculty member’s UI role such as teaching assignments or salary increases. In this situation, a Conflict of Interest in Employment (Nepotism) management plan will be needed to remove the DEO from the decision-making role regarding the other faculty member’s UI employment. Disclosures should be made as soon as possible and no later than within ninety days after commencement of the conflict-of-interest situation through the eCOI system.

Conflicts of interest in the workplace often involve financial matters but other types of considerations also may implicate this policy. Any time an outside interest or relationship may influence UI decisions, there is a potential conflict. For example, a faculty member may want to hire other UI employees or UI students to work in the faculty member’s startup. If the faculty member has evaluative authority for the other UI employee (as their supervisor) or UI student (as their instructor or advisor) there is the potential for the activities within the startup to influence decisions or evaluations at the UI. Additionally, referring work or research opportunities to the startup when the same work could be provided by the UI would implicate the Conflict of Interest in the Workplace Policy; the UI must be offered the right of first refusal. This policy requires that all University employees disclose any potential or actual conflicts of interest in the workplace in advance of initiating an activity or when the employee, in the exercise of reasonable diligence, first becomes aware of the conflict or the potential for conflict. Disclosures must be made using the online eCOI system.

A “conflict of interest vendor” in purchasing is defined as any paid employee of the University, another Regent institution, or any other State of Iowa Agency who is the partner or sole proprietor of a company or an employee who holds five percent or more of stock either directly or indirectly in a company.

If a UI employee meets either of these criteria they are required to contact purchasing at po-coi@uiowa.edu to disclose the conflict and go through the conflict of interest vendor review process.   

The UI faculty member with the conflict must not be involved in any University purchases from the conflict of interest company.  

Faculty members who are considered a conflict of interest in purchasing need to be aware of the full policies and procedures.   

The guidelines governing the use of University facilities and resources by startup companies also apply to students and postdoctoral researchers involved with a startup.

Participation in startup activities should not distract from a student’s progress toward completing graduation requirements or a postdoc’s career goals. Advisors and mentors should provide guidance and support to ensure that participation in the startup aligns with the individuals’ educational and career objectives.

Students and postdocs are in an inherently vulnerable position and care should be taken to ensure they are engaged in startup activities voluntarily. They should never be coerced, pressured, or compelled to work for or on projects funded by the startup. The decision to participate should be based on their own interests and career goals. 

Before involving students and postdocs in  startup activities, consider whether the activities could:

• interfere with the student’s progress toward degree completion or the postdoc’s training timeline
• negatively impact the student’s requirements for graduation or impact the student’s ability to maintain full-time enrollment 
• place restrictions on the publication or presentation of research results that may impact a student’s thesis, dissertation, oral presentations, or other requirements for degree completion
• conflict with the conditions of the individual’s funding e.g.,  fellowship or training grant, which restricts related work for additional  compensation
• conflict with the individual’s visa status. e.g., most international postdocs have visas that would not allow work outside the University of Iowa. Those with F-1 visas with an option for practical training (OPT) should check with the College or University who issued their I-20 before initiating work with a startup 

Engaging students and postdocs in activities related to a startup company requires approval from local and senior leadership. For those approved, management plans for conflicts of commitment and interest must be developed as appropriate. These approvals ensure that all parties are informed and supportive of the student’s or postdoc’s engagement with the startup while safeguarding their academic interests and maintaining compliance with institutional policies. 

Undergraduate Student Approval. Undergraduate student involvement in startup companies requires approval from the student’s academic advisor or mentor, the Director of Undergraduate Studies, or another administrator responsible for the student’s academic program, and the Associate Dean for Undergraduate Education/Associate Dean for Academic Affairs (or equivalent)in the student’s college.

Graduate or Professional Student Approval. Graduate or professional student involvement in startup companies requires approval from the student’s academic advisor or mentor, the Departmental Executive Officer responsible for the student’s  academic program, and the Associate Dean for Graduate or Professional Education in the student’s college. 

Postdoc Approval. Postdoc involvement in startup companies requires approval from the postdoc’s mentor, the Departmental Executive Officer or Director of the postdoc’s hiring unit, and the Associate Dean/Associate Vice President/Associate Provost in the postdoc’s College or Central Services Unit. In most cases, the final level of approval will come from the Associate Dean for Graduate Education in the postdoc’s academic college.