Comment on FR Doc # 2012-18120

I commend the NIH for taking several key steps to make the STTR program more meaningful. In particular I applaud the NIH for doing the following: 1. Matching the guidelines dollar limits of STTR to SBIR. 2. For increasing the set aside percentages for STTR. However, I strongly urge the NIH to consider the following additional measures: 1. Increase the frequency of application deadlines for STTR and SBIR. Rationale: The current 3 cycle format is fine for academia but does not work well for start ups like ours. Often we make progress in a few months and would like the option of applying earlier for additional funding. The current long intervals are best suited for academic institutions that work on different timelines. 2. Allow switching between STTR and SBIR grants. Rationale: Currently an STTR phase 1 awardee can only apply for a STTR phase 2. I would request consideration of allowing an STTR phase 1 to be able to apply for SBIR phase 2 if they are eligible. It allows the small business a better shot at getting a grant given the higher set aside percentage. It also speaks to the progress made by the small business from being dependent on a university PI to having adequate intellectual and scientific strength within its organization. 3. Allow STTR companies to apply for the commercialization assistance supplement. This may be already addressed in the current changes. Thank you again for a making these key changes that greatly benefits the small business community.