The University of Iowa (UI), in line with its mission to bring research into the service of the people of Iowa, the nation, and the world, is committed to supporting a campus culture of innovation through the acceleration of research-based startups.
Many UI researchers choose to take an active role in broadening the impact of their research through commercialization and startup company formation. For the purposes of this guide, a startup company is defined as a legally formed, privately held, for-profit entity based on an individual’s (or individuals’) research and intellectual property.
Various campus offices, including the Office of Innovation, UI Ventures, John Pappajohn Entrepreneurial Center, and UI Research Foundation have resources available to help researchers identify and secure the facilities, funding, and personnel necessary for their business to succeed.
These guidelines are intended to help the UI research community navigate the startup landscape, and the applicable institutional policies that govern the circumstances when startup companies and university research activities intersect. Researchers are expected to know and comply with any state or federal laws applicable to their startup company.
The ultimate goal is to balance promoting innovation and entrepreneurship with safeguarding the integrity and objectivity of university research and our commitments and obligations to the UI research community.
Community Policies
The university is committed to fostering a safe, healthy, and respectful work environment for all employees, students, and guests. To accomplish that objective, it is essential for all individuals on campus, irrespective of their position or employment status, to adhere to university policies, including those governing laboratory and occupational safety, as well as policies addressing harassment, bullying, discrimination, and retaliation.
Separation of Company Research from University Research
University resources may not be used for the activities of a company, including the company portion of a research collaboration in which the university is engaged, except under specific documented agreements between the startup and the university governing the use of space, equipment, personnel, etc.
Use of University Logos and Wordmarks
UI researchers must follow the Policy Manual on the Use of the University of Iowa Name.
Generally, the use of the university name and wordmark for any purpose in any non-university endeavor not previously sanctioned by the Office of Strategic Communication is prohibited.
University faculty or staff may use their name in conjunction with the name of the university for self-identification purposes in connection with products or services when they are the subject of a pending U.S. patent, a valid in-force U.S. patent, or a U.S. copyright, in which a pecuniary interest is held by the university, and which arose out of university research or scholarship, or in other manner arose out of activity connected with the university. Prior written authorization will be required from the Vice President for Research, based on a finding that the foregoing facts regarding patent, copyright, and interest in the university apply in a given case.
Reach out to the Office of Strategic Communication with any questions about the UI name or wordmark as it relates to a startup company.
Financial Separation and Procurement of Goods and Services
Startup company financials must maintain their financial records independently from university financials. It is advisable to utilize private funds for acquiring software such as QuickBooks to effectively track and manage startup financial records. Startup companies must establish dedicated bank accounts under the company’s Federal Employer Identification Number (FEIN) or employee Social Security Number (SSN). These accounts should be separate from any UI-related accounts.
University accounts and funds should not be used to financially support or sponsor any activities of such companies. Any University investment in startup companies should be managed through the UI Research Foundation (UIRF).
University funds, which includes resources such as faculty startup funds, grants, contracts, donations, etc., may not be used for the procurement of goods or services for startup companies. UI funds may not be used to support the activities, expenses, or payroll of a startup company. Furthermore, goods or services purchased by the university should not be used by startup companies. UI resources are to be used to further the university’s mission, and all expenditures made from UI accounts must strictly align with official university business. Should any costs be inadvertently paid for by the university through its accounts or transactions, the employee or company is obligated to promptly reimburse such costs.
Use of University Facilities and Resources
In accordance with the UI Policy Manual, university employees may not use university resources, including university personnel, working time, supplies, equipment, or communications in support of the activities of an external entity. This includes refraining from the use of university computers, printers, phones, email accounts, supplies, administrative staff, and other office resources. In addition, startup companies and their employees should not use university office or laboratory space for the conduct of their business,
Access to Services
A company coming out of a university lab may still need access to specialized capabilities, labs, or equipment on campus. There are several ways to enter into a contract for such access that are in accordance with university, state, and federal policies and that can allow the company to retain the IP (Intellectual Property) created while accessing facilities and equipment.
Research Data and Materials
A company coming out of a university lab may still need access to specialized capabilities, labs, or equipment on campus. There are several ways to enter into a contract for such access that are in accordance with university, state, and federal policies and that can allow the company to retain the IP (Intellectual Property) created while accessing facilities and equipment.
Equipment
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 required for university-directed activities AND the companies pay for access to these resources.
Research Cores
University startup 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.
Services Provided | ||
|---|---|---|
Relationship to University | Core Services | Sponsored Agreements |
| Faculty/staff companies located in Research Park or Incubator | Standard fee. No additional fees will be assessed for core services during the first 5 years of the lease agreement. | Full cost plus the other sponsored activities F&A rate for fee for service agreements or the organized research rate for sponsored research agreements. Originators of pass-through agreements should be identified and charged the appropriate F&A rate. |
| Faculty/staff companies located elsewhere in Iowa | Standard fee, plus F&A rate for other sponsored activities | Full cost plus the other sponsored activities F&A rate for fee for service agreements or the organized research rate for sponsored research agreements. Originators of pass-through agreements should be identified and charged the appropriate F&A rate. |
| Companies located in the Research Park or Incubator Spaces | Standard fee, plus F&A rate for other sponsored activities | Full cost plus the other sponsored activities F&A rate for fee for service agreements or the organized research rate for sponsored research agreements. |
| Companies licensing University technology | Standard fee, plus F&A rate for other sponsored activities | Full cost plus the other sponsored activities F&A rate for fee for service agreements or the organized research rate for sponsored research agreements. |
| Companies with no relationships | Standard fee, plus F&A rate for other sponsored activities | Full cost plus the other sponsored activities F&A rate for fee for service agreements or the organized research rate for sponsored research agreements. |
Human Subjects Research
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 (SRA) 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 the Vice President for Research.
- 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
- Research results, data and specimens may only be shared with company through an appropriate 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.
Animal Research Services
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 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 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).
Environmental Health and Safety (EHS)
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 using university space to conduct research with recombinant or synthetic nucleic acids must adhere to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules and obtain necessary approvals from the university’s Institutional Biosafety Committee (IBC). Registrations/applications for the review of company-sponsored research should be submitted separately from applications for review of UI-sponsored research. 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 unless required for university compliance.
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.
Federal Awards and Sponsored Research Agreements
Sponsored research agreements 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 UI portion of the work before company submission to the sponsor.
- Companies are responsible for proposal development and submission requirements, including System for Award Management (SAM) registration, use of sponsor system, etc.
- Company may not use UI personnel for proposal development activities.
- DSP 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 UI 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 UI 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 UI PI cannot provide signature authority or administrative oversight of the project for the startup company. The UI 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 UI.
Subrecipient F&A cost rates:
Must follow the prime sponsor’s F&A limits and be supported by appropriate documentation.
For federally funded projects, confirm the subrecipient has federally approved fringe benefit and F&A rates.
If no federally negotiated rate agreement exists, the 15% modified total direct costs (MTDC) de minimis rate applies.
The University of Iowa does not negotiate F&A rates with subrecipients; the above limits apply.
Contact DSP with proposal budget questions, including review of subrecipient F&A and fringe benefit rate documentation.
Conflicts of Interest
Faculty and staff involvement in a startup company creates opportunities for development and commercialization of inventions. At the same time, this involvement nearly always creates conflicts of interest and commitment as well as the risk of noncompliance with State law and federal regulations, that must be managed. These issues must all be taken into consideration when planning a business.
Researchers should familiarize themselves with the Conflict of Commitment and Interest Policies at the University of Iowa and University of Iowa Health Care.
Conflict of Interest in Research
Conflict of interest in research involves situations in which an investigator has a financial interest that may compromise—or appear to compromise—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 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.
Conflict of Commitment
Faculty are encouraged to pursue entrepreneurial activities, including forming or participating in a startup, but these activities must not interfere with their ability to meet University of Iowa responsibilities. A conflict of commitment occurs when startup work requires time or effort that compromises—or appears to compromise—a faculty member’s ability to fulfill teaching, research, service, or administrative duties. All startup involvement must be disclosed in the eCOI system, even if the work takes place outside normal business hours or off campus, so the college can assess whether the engagement creates a conflict. If the college determines that a faculty member’s startup activities could interfere with their UI obligations, college leadership will work with the individual to develop a written management plan that may include limits on time commitments, adjustments to duties, or other measures to ensure that university responsibilities remain fully met.
Conflict of Interest in Employment (Nepotism)
[Revised] When a UI employee supervises, evaluates, or has decision‑making authority over another UI‑affiliated individual (faculty, staff, graduate student, or postdoc) who also owns equity in or works for the employee’s startup, the university’s Conflict of Interest in Employment (Nepotism) policy is triggered. Co‑owning with or employing another UI-affiliated student or employee in a startup creates a significant outside business relationship, which can influence—or appear to influence—an individual’s decisions in their UI role. This includes decisions about teaching assignments, performance evaluations, salary adjustments, workload, or research opportunities. For example, if two UI faculty members co‑own a startup and one of them serves as the departmental executive officer (DEO) of the other’s department, disagreements or business pressures from the startup could affect (or appear to affect) departmental decisions. In this case, the DEO must be removed from all evaluative or supervisory responsibilities related to the co‑owner’s UI employment. Disclosures should be made as soon as the conflict arises and no later than 90 days after the relationship begins through the eCOI system.
Conflict of Interest in the Workplace
[Revised] A workplace conflict of interest occurs when involvement in a startup could influence—or appear to influence—an individual’s responsibilities or decision‑making at the University of Iowa. Such conflicts may arise through financial interests, but also through non‑financial relationships, including situations in which a UI student or employee who works for or holds equity in a startup is also supervised, instructed, advised, or evaluated by the same individual at the university. A conflict exists when a faculty or staff member hires or engages UI employees or UI students for a startup while simultaneously holding supervisory, instructional, advisory, or evaluative authority over those individuals at the university (e.g., serving as their supervisor, instructor, advisor, PI, or committee member). In these circumstances, the startup relationship may influence UI decisions related to performance evaluations, grades, research assignments, or workload. A conflict also occurs when work, research opportunities, or projects are directed to a startup that could reasonably be performed by the university; in such cases, the university must be offered the right of first refusal before the opportunity is referred externally.
Conflict of Interest in Purchasing
If a company owned by a faculty member seeks to do business with the UI, the company is considered a conflict-of-interest vendor. UI Purchasing must evaluate any proposal to purchase goods or services from the company, and the faculty member/owner of the company must not be involved in UI purchasing decisions related to the company.
Intellectual Property
The University of Iowa Intellectual Property Policy outlines the criteria under which the university owns certain types of intellectual property. With respect to patentable inventions, the university owns inventions:
- Made by employees or postdoctoral appointees in the scope of their employment, including inventions that are an extension of their university research
- Made by any individual using significant university resources
Researchers interested in commercializing their university-owned inventions through their startup company should reach out to the University of Iowa Research Foundation (UIRF) to discuss licensing opportunities for their company.
Typically, inventions made by company employees in space rented by the company—such as the TRI space or the Iowa Bioscience Innovation Facility (IBIF)—fall outside of the university’s IP Policy, but companies should be aware that there are a few circumstances under which the policy applies to such inventions. For example, inventions:
- Made using resources in the IBIF along with resources in university laboratory space might be jointly owned by the university and the company
- Made in the IBIF by a university employee would be owned by the university if the invention is an extension of that employee’s university research; this holds true even if the employee works part-time for the university and part-time for the company
University researchers and companies may request that UIRF perform an ownership determination to clarify whether or not the university owns a specific invention.
Research Security Considerations
Startup companies must consider sponsor and/or federal research security requirements and must comply with research security requirements while not utilizing University resources. Startup companies may be unfamiliar with requirements tied to federal funding such as disclosure of foreign relationships and research security training requirements. They must have their own systems in place to satisfy any research security compliances.
Startup companies may lack secure systems needed for required data and cyber security. The need to secure systems to protect controlled, proprietary, or federally funded data is extremely important. The use of personal devices, cloud storage, or informal data sharing increases risks of cyber security breaches. Startup companies cannot rely on UI systems for data and cyber security. The company will need to have its own appropriate cyber security safeguards.
In some instances, startup companies may need to complete mandatory research security training. Although the use of UI training systems would be prohibitive, startup companies may access Research Security Training and other research security resources via the NSF’s SECURE Center. This training is viewed as satisfying the training compliance by various federal agencies.
Undergraduate Student, Graduate Student, Professional Student, and Postdoctoral Participation in Faculty/Staff Startups
Participation in startup companies can be an exciting and valuable opportunity for students and postdocs, offering unique experiences and insights into entrepreneurship, technology transfer and the real-world application of research discoveries. However, it is crucial to establish policies to ensure ethical conduct, protect intellectual property, and maintain transparency. The following guidelines prioritize the protection of students and postdocs, their academic development, and their voluntary participation in research conducted or funded by university startups.
Use of UI Facilities
The guidelines governing the use of university facilities and resources by startup companies also apply to students and postdoctoral researchers involved with a startup.
Academic Prioritization and Oversight
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.
Voluntary Participation
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.
Considerations
Before involving students and postdocs in university 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 individuals’ funding (e.g., fellowship or training grant, which restricts related work for additional compensation)
- conflict with the individual’s visa status. 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
Approvals
Engaging students and postdocs in activities related to a startup company requires approval from local and senior leadership. For those approved, appropriate 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 academic advisor or mentor, the director of undergraduate studies, or another administrator responsible for their 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 academic advisor or mentor, the departmental executive officer responsible for their 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.