Artifact · A3 · 2026-05-28

CO action-memo template.

A fillable Phase III sole-source action memo a contracting officer could sign. Seven sections with boilerplate text, fill-in callouts, and source-cited language variants. Pre-populated with CHN Analytics-specific facts in Sections 3 and 4.

A3 · CO Action-Memo Template · artifact id: co-action-memo-template-v0.html · 2026-05-28 · v0

How to use this template

This template mirrors the seven-section structure documented in R5 (CO action-memo research, 2026-05-28) and is grounded in the NASA NSSC Justification Template (Appendix A, 2024), the NMCARS Annex 13 Navy template structure, the Army SBIR MFR requirements page, and the AFWERX Phase III Execution Guide. Sections 3 and 4 are pre-populated with CHN Analytics-specific facts; all other bracketed fields are fillable by the sponsoring CO or TPOC.

Agency terminology varies: Air Force calls this document a Determination and Finding (D&F or DNF); Army uses Statement/Memo for the Record (MFR); Navy uses the Business Clearance Memo (BCM) paired with NMCARS Annex 13; NASA uses Justification for Phase III. The section content is substantively identical across agencies. A CO should use this template as the source material and reformat to match their agency's document standard.

Gating condition before CO signs A2 (derive-extend-complete mapping) flags that FA8649-21-P-0756 was issued to CHN Analytics LLC, which currently 301-redirects to northai.io. The Phase III authority runs to "the SBIR and STTR award recipients that developed the technology" (15 U.S.C. 638(r)(4)(B)). Before this memo is signed, the CO must confirm whether NorthAI is CHN Analytics LLC operating under a rebrand (no action needed) or a separately incorporated entity that acquired CHN's assets (novation of FA8649-21-P-0756 required). Tim Okonkwo should provide legal-entity confirmation. This flag appears in Section 3 and Section 7.

Memo header block (fillable)

MEMORANDUM FOR RECORD SUBJECT: Phase III STTR Sole-Source Award to CHN Analytics, Inc. Pursuant to 15 U.S.C. 638(r)(4) DATE: [date of signature] PREPARED BY: [CO name, grade/title, office symbol] CONTRACTING OFFICE: [office symbol and address] CONTRACT ACTION VALUE: $[amount] ([FFP / CPFF / T&M]) PREDICATE AWARD: FA8649-21-P-0756 (STTR Phase I)

Section 1 · Determination

The operative paragraph. The CO states the legal conclusion.

I, [CO name], Contracting Officer, [office symbol], warrant authority [warrant number and threshold], have determined that the proposed contract action awarding a Phase III STTR sole-source contract to CHN Analytics, Inc. is appropriate and authorized pursuant to 15 U.S.C. 638(r)(4). This determination is supported by the findings set forth in Sections 2 through 6 of this memorandum. No Justification and Approval (J&A) under FAR 6.302-5 is required. No synopsis under FAR 5.202 is required. This award issues without further justification by operation of 15 U.S.C. 638(r)(4)(B).

CO name, grade, title, office symbol, and warrant number and ceiling. Contract type (FFP preferred for fixed-scope work; CPFF for R&D-intensive delivery; T&M only for well-defined labor). Total contract value and period of performance.

Army SBIR/STTR Phase III (armysbir.army.mil): "affirm in the BCM that the SBIR/STTR Phase III award is derived from, extends, or completes efforts made under prior SBIR/STTR Phase I or II awards and is authorized pursuant to 15 U.S.C. 638(r)(4)." // NASA NSSC Justification Template (Appendix A, 2024): "NASA Shared Service Center (NSSC) will negotiate with the above firm a Phase III contract." // NMCARS Annex 13 (Navy): "This is a justification to award a Small Business Innovation Research (SBIR) (or Small Business Technology Transfer (STTR)) Phase III contract to [insert name of contractor]."

Section 2 · Statutory Authority

Cite the exact statute and regulatory codification. Do not paraphrase.

STATUTORY AUTHORITY: This action is authorized under 15 U.S.C. 638(r)(4)(B), which provides that Federal agencies shall "issue, without further justification, Phase III awards relating to technology, including sole source awards, to the SBIR and STTR award recipients that developed the technology." The work qualifies as Phase III under 15 U.S.C. 638(e)(6)(C) (STTR Phase III definition), which defines Phase III as "work that derives from, extends, or completes efforts made under prior funding agreements under the STTR program." CHN Analytics held a STTR Phase I award (FA8649-21-P-0756); accordingly, subsection (e)(6)(C) governs the Phase III definition and sole-source authority for this action. Per SBA Policy Directive (May 2023), Section 4(c)(3), it is sufficient to state "that the project is an SBIR/STTR Phase III award that is derived from, extends, or completes efforts made under prior SBIR/STTR Funding Agreements and is authorized pursuant to 15 U.S.C. 638(r)(4)." That statement, combined with the predicate award identification in Section 3 and the derives-extend analysis in Section 4, satisfies all documentation requirements. The FAR was amended in April 2023 (FR 2023-06420) to codify that contracting officers may award Phase III sole-source actions without further justification based on 15 U.S.C. 638(r)(4). NOT REQUIRED FOR THIS ACTION: - Justification and Approval (J&A) under FAR 6.302-5 - Pre-award synopsis under FAR 5.202 - Post-award synopsis under FAR 5.301 - DD Form 2579 (Small Business Coordination Record) - Market research for alternative sources

No fill-in required in this section for a CHN Analytics Phase III action. All citations are fixed statutory text. If the CO's agency uses agency-specific legal citations, add those as a supplemental line below the statutory text (e.g., AFMAN 64-101 for AFWERX or NMCARS Subpart 5206.3 for Navy commands). Do not remove or paraphrase the 15 U.S.C. 638(r)(4)(B) and (e)(6)(C) cites.

15 U.S.C. 638(r)(4)(B) verbatim: "issue, without further justification, Phase III awards relating to technology, including sole source awards, to the SBIR and STTR award recipients that developed the technology." // 15 U.S.C. 638(e)(6)(C) verbatim: "where appropriate, a third phase for work that derives from, extends, or completes efforts made under prior funding agreements under the STTR program." // SBA Policy Directive (May 2023), Section 4(c)(3): "in conducting actions relative to a Phase III SBIR/STTR award, it is sufficient to state for purposes of a Justification and Approval pursuant to FAR 6.302-5, that the project is an SBIR/STTR Phase III award that is derived from, extends, or completes efforts made under prior SBIR/STTR Funding Agreements and is authorized pursuant to 15 U.S.C. 638(r)(4)." // AFWERX Phase III Execution Guide (AFRL-cleared): "No J&A required under FAR 6.302-5 (see 10 U.S.C. 2304(f)(6)) and 15 U.S.C. 638(r)(1) and (r)(4)."

Section 3 · Phase I/II Lineage

Identify the predicate award. This is the factual foundation for the derives-extend-complete argument.

PHASE I/II LINEAGE: CHN Analytics, Inc. received STTR Phase I award FA8649-21-P-0756 from the Air Force Research Laboratory (AFRL) under AFWERX open-topic solicitation AF20C-TCSO1. This award is the predicate funding agreement establishing Phase III eligibility. Phase I award details: Awardee: CHN Analytics, Inc. UEI: HGMHPZK5GED3 Award Number: FA8649-21-P-0756 Phase: Phase I (STTR) Issuing Agency: Air Force Research Laboratory (AFRL) / AFWERX Topic: AF20C-TCSO1 Period of Performance: 2021-02-19 to 2021-05-18 (90 days) Award Value: $49,500 Research scope (USASpending verbatim): "Research in attempt to discover a new method for identifying commercialization partners for government-funded research output using multiple, connected big data sets (patents, grants, financial) powered by artificial intelligence." Phase II award: [Insert Phase II award number and details if a Phase II was subsequently awarded. If no Phase II was awarded, state: "No Phase II award was issued. Phase II completion is not a statutory prerequisite for Phase III eligibility under 15 U.S.C. 638(r)(4). See SBA Policy Directive (2019), Section 9: 'A Federal Agency may enter into a Phase III SBIR/STTR agreement at any time with a Phase I Awardee.'"] CHN Analytics, Inc. is the firm that performed the research and developed the technology under FA8649-21-P-0756. No other firm has rights to the STTR data or technology developed under this prior funding agreement. Legal entity continuity note: [CO must confirm one of the following before signing: Option A -- Rebrand: CHN Analytics LLC is now operating under the NorthAI brand but is the same legal entity. The Phase III award issues to the same entity; no novation required. Option B -- Novation: NorthAI is a separately incorporated entity that acquired CHN Analytics' assets. A novation agreement for FA8649-21-P-0756 must be executed per FAR Subpart 42.12 before Phase III can issue.]

If a Phase II award exists: Phase II award number, issuing agency, period of performance, and award value. Confirm with CHN Analytics / NorthAI (Tim Okonkwo) which legal-entity continuity option applies and delete the inapplicable option from the final signed memo. Source for the predicate award facts: USASpending.gov Award ID FA8649-21-P-0756; entity UEI HGMHPZK5GED3.

NASA SBIR/STTR Phase III Contracting Handbook (2014, Section I): "The file should also contain reference to the prior contract number of the Phase I and/or Phase II efforts, regardless of whether it was a NASA contract or another agency's award." // Army SBIR Phase III page (armysbir.army.mil): documentation must show "narrative and lineage to prior SBIR/STTR PH I/II/III efforts" and "the TPOC and/or SBC must provide the narrative and lineage." // NASA NSSC Justification Template (Appendix A, 2024): "The firm first introduced the technology in a Phase [I/II/III] titled '[title]' on [Agency] Contract No. [prior award number]."

Section 4 · Derive / Extend / Complete Argument

The analytical heart. The CO (with TPOC input) explains which prong applies and why. Three worked examples below cover the primary CHN product lines.

DERIVE / EXTEND / COMPLETE ARGUMENT: The work to be performed under this Phase III contract derives from, extends, and completes efforts made under STTR Phase I award FA8649-21-P-0756, as follows. The predicate Phase I scope -- "discover a new method for identifying commercialization partners for government-funded research output using multiple, connected big data sets (patents, grants, financial) powered by artificial intelligence" -- is the ancestor technology for the products addressed in this action. [Select the worked example(s) below that match the product scope being procured. A single Phase III contract may cover one or all three products; each has an independent prong analysis.]

The CO selects which worked example(s) apply based on the statement of work (SOW) for the action being awarded. If the action covers Tech Vector only, use Example A. If it covers all three products, include all three examples and use the CO-facing one-liner summary paragraph from A2 as the opening narrative.

Example A · Tech Vector DERIVES FROM Fit: STRONG / KNOWN, direct textual match. Anchor argument.

TECH VECTOR -- DERIVES FROM: The Phase III scope for Tech Vector derives from efforts made under FA8649-21-P-0756. The connection is direct and textual. The Phase I verbatim scope states the research goal was to "discover a new method for identifying commercialization partners for government-funded research output using multiple, connected big data sets (patents, grants, financial) powered by artificial intelligence." Tech Vector is the productized implementation of that exact method. Tech Vector provides a guided query over a 200M-document corpus spanning patents, grants, legal filings, and DoD spending data, powered by AI, returning a landscape of who is conducting relevant research in a given technology domain. The data sources in the Phase I description (patents, grants, financial) are the same data sources Tech Vector accesses. The mission of the Phase I (identify who is doing relevant research across government-funded output) is the same mission Tech Vector performs for its defense and government buyers. The Government technical expert [TPOC name, title, office symbol] has reviewed the Phase I technical report and the proposed Phase III SOW and confirms that Tech Vector operationalizes the AI-over-connected-big-data method discovered under FA8649-21-P-0756. Reference: [TPOC Statement/MFR, date, attached at Tab A.] This is a DERIVES FROM determination. The technology is the same technology, applied at commercial scale. No separate "extends" or "completes" finding is required for Tech Vector, though both prongs are independently available as companion framing.

TPOC name, title, and office symbol. Date and tab reference for the TPOC Statement or MFR confirming the technology connection. SOW task numbers that correspond to the Tech Vector scope. If the Phase I technical report is available, cite it by report number or date and confirm the data-source match (patents, grants, financial) in the TPOC statement.

A2 (derive-extend-complete-mapping-v0.html), Tech Vector DERIVES cell: "Tech Vector is the productized commercial execution of exactly what the Phase I was funded to discover... The data sources in the Phase I description (patents, grants, financial) are the same data sources Tech Vector accesses... Both the Phase I verbatim and the Tech Vector product description are primary public sources; the textual match is direct, not inferred." Fit: STRONG / KNOWN. // DoD SBIR Phase III Contracting (business.defense.gov): "The technology is the same as, derived from, or evolved from a Phase I or Phase II SBIR/STTR contract." // AFWERX Execution Guide: "Derives from" = "work that traces back to efforts performed under prior SBIR/STTR funding agreements."

Example B · Defense BD EXTENDS Fit: STRONG / INFERRED, financial-data dimension. Upgrades to KNOWN with Tim's Phase I report.

DEFENSE BD -- EXTENDS: The Phase III scope for Defense BD extends the Phase I technology under FA8649-21-P-0756 to an application not researched or performed in the prior STTR effort. The Phase I scope explicitly named "financial" as one of the three connected big data sets powering the AI commercialization-partner identification method. Defense BD operationalizes the financial-data dimension of that Phase I methodology into a standalone, buyer-facing product: a structured DoD RDT&E budget dashboard covering $100B+ in spending data, filterable by agency, budget activity, program element, and technology cluster, used for budget forecasting and investment targeting by defense commercial firms. This is an EXTENDS determination under 15 U.S.C. 638(e)(6)(C) and the AFWERX execution guide definition of "extends" ("work for other applications not researched or performed in prior SBIR/STTR efforts"). Defense BD extends the financial-data dimension of the Phase I methodology in two respects: (1) from a research method to a production-deployed commercial product; and (2) from the commercialization-partner identification use case to the budget-signal intelligence use case -- a related but distinct buyer mission (where is DoD allocating R&D funding) not addressed in the 3-month Phase I feasibility exercise. Note on "financial" data semantic ambiguity: The Phase I scope lists "financial" as a data set without specifying whether this refers to commercial investment data (VC rounds, startup capital flows) or government budget and appropriations data (DoD RDT&E program elements, President's Budget submissions). Defense BD's EXTENDS argument holds under either reading: if "financial" meant commercial investment data, Defense BD extends from a related data dimension; if "financial" meant government budget data, Defense BD extends that dimension into a production product. Tim's Phase I technical report resolves this ambiguity and, if confirmed as government budget data, upgrades this cell from INFERRED to KNOWN. The Government technical expert [TPOC name, title, office symbol] has reviewed the Phase I technical report and the proposed Phase III SOW and confirms that Defense BD extends the financial-data dimension of FA8649-21-P-0756 to a new operational application not researched in Phase I. Reference: [TPOC Statement/MFR, date, attached at Tab B.]

TPOC name, title, and office symbol. Date and tab reference for the TPOC Statement or MFR. SOW task numbers corresponding to the Defense BD scope. Preferred: obtain Tim's Phase I technical report and confirm the "financial" data definition before signing, then update the semantic-ambiguity note to reflect the confirmed reading. If Phase I technical report confirms government budget data, change "INFERRED" notation to "KNOWN."

A2 (derive-extend-complete-mapping-v0.html), Defense BD EXTENDS cell: "Defense BD extends the Phase I scope in two documented ways. First, the financial data dimension... Defense BD operationalizes the financial layer of the Phase I methodology into a standalone, buyer-facing product with filter-to-program-element granularity over $100B+ in RDT&E data. Second, the scope of the buyer mission... Defense BD serves defense commercial firms trying to forecast where DoD is allocating R&D funding -- a related but distinct buyer question." Fit: STRONG / INFERRED. // AFWERX Execution Guide: "Extends" = "work for other applications not researched or performed in prior SBIR/STTR efforts." // SBA Policy Directive (May 2023), Section 4(c)(3): "derives from, extends, or completes efforts made under prior SBIR/STTR Funding Agreements."

Example C · NorthStar EXTENDS Fit: STRONG / INFERRED, conversational-interface modality. Upgrades to KNOWN with Tim's Phase I report.

NORTHSTAR -- EXTENDS: The Phase III scope for NorthStar extends the Phase I technology under FA8649-21-P-0756 to a conversational interface application not researched or performed in the prior STTR effort. NorthStar is a conversational multi-agent AI assistant that accepts natural-language questions and returns SLM-generated interactive research reports drawn from a 200M-document corpus spanning patents, grants, and DoD spending data. The underlying corpus and core AI methodology derive from the same connected-big-data-set approach that the Phase I established. The EXTENDS prong applies because NorthStar's primary innovation -- the conversational SLM-generative interface layer -- is an application not researched in the 3-month Phase I feasibility exercise. The Phase I discovered an AI method for identifying technology relationships over connected big data; NorthStar applies that method through a different access modality that was not in the Phase I scope. This is an EXTENDS determination under 15 U.S.C. 638(e)(6)(C) and the AFWERX execution guide definition of "extends" ("work for other applications not researched or performed in prior SBIR/STTR efforts"). NorthStar extends the Phase I AI methodology to a strategy-layer buyer experience -- a researcher querying "who is leading work on quantum sensing for navigation?" through natural-language interaction rather than structured data query. The SLM-generative layer, the natural-language question format, and the interactive follow-up capability were not applications researched under FA8649-21-P-0756. The Government technical expert [TPOC name, title, office symbol] has reviewed the Phase I technical report and the proposed Phase III SOW and confirms that NorthStar's SLM-generative conversational interface was not in scope under FA8649-21-P-0756 and represents an extension of the Phase I AI methodology to a new operational context. Reference: [TPOC Statement/MFR, date, attached at Tab C.]

TPOC name, title, and office symbol. Date and tab reference for the TPOC Statement or MFR. SOW task numbers corresponding to the NorthStar scope. Preferred: obtain Tim's Phase I technical report and confirm no conversational NLP interface was in Phase I scope before signing, then change "INFERRED" to "KNOWN" in the CO's file notation. If NLP/conversational interface was partially in Phase I scope, shift primary argument from EXTENDS to DERIVES and adjust narrative accordingly.

A2 (derive-extend-complete-mapping-v0.html), NorthStar EXTENDS cell: "NorthStar applies that method through a different access modality: a conversational interface backed by technology-specific Small Language Models that generate interactive research reports. The SLM-generative layer, the natural-language question format, and the interactive follow-up capability were not applications researched in the 3-month feasibility Phase I... The Phase I corpus and method are the ancestor; the SLM conversational surface is the extension." Fit: STRONG / INFERRED. // AFWERX Execution Guide: "Extends" = "work for other applications not researched or performed in prior SBIR/STTR efforts." // GAO: agencies have "broad discretion in determining what derives from, extends, or completes a Phase I/II award."

CO-facing one-liner (all three products) If the Phase III action covers all three products, use this paragraph as the opening narrative in Section 4 before the worked examples: "The work to be procured under this Phase III action -- Tech Vector, NorthStar, and Defense BD -- derives from, extends, and completes efforts made under STTR Phase I award FA8649-21-P-0756 (CHN Analytics LLC, AFWERX, AF20C-TCSO1, 2021). Tech Vector derives from the Phase I methodology directly: the Phase I scope was to discover an AI method for identifying commercialization partners using connected big data sets of patents, grants, and financial data; Tech Vector is the productized implementation of that exact method over a 200M-document corpus at commercial scale. NorthStar extends the Phase I methodology to a conversational SLM interface not researched in Phase I, making the same corpus accessible through natural-language queries and interactive generated reports. Defense BD extends the financial-data dimension of the Phase I methodology into a structured RDT&E budget-intelligence product covering $100B+ in DoD spending data." (Source: A2, CO-facing one-liner summary section.)

Section 5 · Procurement Justification

Document why competitive procedures are not required. The statutory authority does the work; this section is brief.

PROCUREMENT JUSTIFICATION: Full and open competition is not required for this action. The competition for STTR Phase I award FA8649-21-P-0756 and any subsequent Phase II awards satisfied all competition requirements of the Armed Services Procurement Act, the Federal Property and Administrative Services Act, and the Competition in Contracting Act (CICA). (1) CHN Analytics, Inc. was competitively selected for STTR Phase I award FA8649-21-P-0756 through a peer-reviewed, merit-based AFWERX open-topic solicitation process. That competitive selection satisfies CICA competition requirements. By Phase III, the technology has survived the government's competitive review process. No additional competition is required. (2) Pursuant to 15 U.S.C. 638(r)(4)(B), this Phase III award issues "without further justification." The statute expressly removes the competition justification burden for Phase III sole-source awards to the awardee that developed the technology. (3) Congress intends that agencies give preference, including sole-source awards, to the awardee that developed the technology for Phase III work. SBA Policy Directive (May 2023), Section 4(c)(7): "For Phase III, Congress intends that agencies... give preference, including sole source awards, to the awardee that developed the technology." That awardee is CHN Analytics, Inc. (4) The April 2023 FAR amendment (FR 2023-06420) codifies that contracting officers may award Phase III sole-source actions without further justification based on 15 U.S.C. 638(r)(4). No market research for alternative sources is required. No other firm has developed the technology underlying FA8649-21-P-0756.

No variable fill-in required. If the CO's agency requires an agency-specific competition exception citation (e.g., AFAC, NMCARS, AFMAN), add it as a paragraph (5) after the four paragraphs above. Do not delete or soften the 15 U.S.C. 638(r)(4)(B) paragraph; it is the operative authority.

NASA NSSC Justification Template (Appendix A, 2024) verbatim: "The competition for SBIR -- Phase I and Phase II awards satisfies any competition requirement of the Armed Services Procurement Act, the Federal Property and Administrative Services Act, and the Competition in Contracting Act. Therefore, an agency that wishes to fund an SBIR Phase III project is not required to conduct another competition in order to satisfy those statutory provisions." Note: NASA's template cites 10 U.S.C. 2304(b)(2) and 41 U.S.C. 253(b)(2) (pre-2023 codification). Current operative cite is 15 U.S.C. 638(r)(4). // NASA SBIR/STTR Phase III Contracting Handbook (2014, CICA Committee Report language): "an agency which wishes to fund an SBIR project in Phase III (with non-SBIR monies) or enter into a follow-on procurement with an SBIR company, need not conduct another competition in order to satisfy the Federal Competition in Contracting Act (CICA). Rather, by Phase III the project has survived two competitions and thus has already satisfied the requirements of CICA." // NMCARS Annex 13 (Navy): "Phase III (commercialization) is the ultimate goal of the SBIR/STTR Programs, and because the Phase III work derives from, extends, or completes efforts performed under Phase I and Phase II, use of the authority cited is required."

Section 6 · Funding

Identify the appropriation. Phase III must be funded from non-SBIR/STTR sources. Mandatory certification.

FUNDING: Funding source: [Program element / project / task / subtask number] Appropriation type: [RDT&E / O&M / Procurement / Other -- select one] Fiscal year: FY[YYYY] Amount: $[ceiling] (obligated at award: $[amount]) Funding document: [MIPR number / PR number / funding document identifier] Finance office: [office symbol of the finance office certifying fund availability] CERTIFICATION: This action is NOT funded with SBIR or STTR program dollars. Funding is from [program/project name] non-SBIR appropriations. This is required under 15 U.S.C. 638 and SBA Policy Directive (May 2023), Section 4(c): "SBIR Phase III refers to work that derives from, extends, or logically concludes effort(s) performed under prior SBIR funding agreements, but is funded by sources other than the SBIR Program." Permissible funding types for this action: RDT&E appropriations, Operations and Maintenance (O&M) funds, procurement accounts. SBIR and STTR appropriation line items are not permissible. Fiscal year alignment: [If period of performance crosses a fiscal year boundary, state:] "The period of performance for this action runs from [start] to [end], crossing FY[YYYY]/FY[YYYY]. Funding is provided incrementally as follows: $[amount] from FY[YYYY] [appropriation type], and $[amount] from FY[YYYY+1] [appropriation type] subject to appropriation. RDT&E and O&M funds are one-year appropriations and must be obligated by September 30 of the appropriation year. Multi-year procurement authority [is / is not] applicable to this action." [If period of performance does not cross a fiscal year boundary, delete this paragraph.]

Program element / project / task / subtask. Appropriation type (RDT&E is most common for early Phase III work; O&M for sustainment; procurement for production). Fiscal year. Contract ceiling and amount obligated at award (may differ if incrementally funded). MIPR or PR document number. Finance office symbol. Program or project name for the certification statement. For AFWERX actions: the customer memorandum funding commitment block (Section 4, AFRL-2025-0532 format) should be referenced as the upstream funding commitment document -- it specifies "[DOD/DAF PARTNER FULL NAME] will provide [AMOUNT AND TYPE OF FUNDS] non-SBIR/STTR Government funds."

AFWERX Phase III Execution Guide (AFRL-cleared): "Cannot be funded with SBIR or STTR dollars." Permissible: RDT&E, O&M, procurement. // SBA Policy Directive (May 2023), Section 4(c): "SBIR Phase III refers to work that derives from, extends, or logically concludes effort(s) performed under prior SBIR funding agreements, but is funded by sources other than the SBIR Program." // NASA SBIR/STTR Phase III Contracting Handbook (2014): "Phase III awards must be funded from non-SBIR funding sources." // AFWERX Customer Memorandum (AFRL-2025-0532): "verifies funds availability" -- finance office concurrence block within the customer memo establishes the upstream funding pathway before contract execution.

Section 7 · Approvals

Signature authority, routing thresholds, and required concurrences. Varies by agency and action value.

APPROVALS: Prepared by: [CO name], [grade/title] Contracting Officer, [office symbol] Warrant authority: [warrant number, threshold] Signature: __________________________ Date: __________ Concurred by (Technical / TPOC): [TPOC name], [grade/title] Technical Point of Contact, [office symbol] Statement: "I have reviewed the Phase I statement of work, the Phase I technical report (FA8649-21-P-0756, [report date]), and the proposed Phase III SOW. I confirm that the Phase III work [derives from / extends / completes -- select applicable prong(s)] STTR Phase I award FA8649-21-P-0756 as described in Section 4 of this memorandum." Signature: __________________________ Date: __________ Concurred by (Small Business Office): [OSBP representative name], [title] Office of Small Business Programs, [office symbol] Signature: __________________________ Date: __________ [Insert if dollar threshold triggers additional approval -- see routing table below:] Approved by: [HCA or CCO name], [title] [Echelon level], [office symbol] Signature: __________________________ Date: __________ Data rights confirmation: [CO initials] -- Confirmed: [DFARS 252.227-7018 (DoD) OR FAR 52.227-20 (civil agencies)] is included in the contract. CHN Analytics, Inc. retains SBIR/STTR data rights for 20 years from award date under the governing data rights clause. Small business concern (SBC) concurrence: CHN Analytics, Inc. (NorthAI) has confirmed in writing that STTR Phase I award FA8649-21-P-0756 is the predicate for this Phase III action and that the Phase III work [derives from / extends / completes] that prior effort. Reference: [CHN/NorthAI letter or email, date, attached at Tab D.]

CO name, grade, title, office symbol, warrant number and ceiling. TPOC name, grade, title, and office symbol. TPOC must confirm the specific prong (derives / extends / completes) and reference the Phase I technical report by report date or number. OSBP representative name and office. For AFWERX actions: DAF-specific routing applies; the Air Force calls this document a D&F or DNF and uses CAC-enabled digital signatures (three signatories for Customer Memorandum-linked actions per AFRL-2025-0532). For the SBC concurrence, a company letter or email from Tim Okonkwo (CHN Analytics LLC / NorthAI) confirming the prior award number and stating the new work derives from it satisfies the Army and NASA procedural requirement.

NMCARS Subpart 5206.3 approval thresholds (acquisition.gov): $700K or less = Activity CCO; $700K to $5.5M = Echelon I/II CCO; $5.5M+ = Head of Contracting Activity (HCA). These are Navy thresholds and serve as a reference for other agencies with equivalent structures. // NASA NSSC Justification Template (Appendix A, 2024): "COR/TM Signature ________ Date ________" // AFWERX Customer Memorandum (AFRL-2025-0532): three CAC-enabled digital signatures required for Phase II customer memo; Phase III D&F follows DAF agency-specific routing. // Army SBIR Phase III page: "the PM or contracting officer's representative completes a procurement request and submits it to the contracting officer for contracting" after SBC concurrence.

Approval routing reference (multi-agency)

Agency	Document name	Signed by	Threshold / routing note
Air Force / AFWERX	Determination and Finding (D&F / DNF)	CO + TPOC concurrence	DAF agency-specific routing; CAC digital signatures; Customer Memorandum pre-commitment documents funding pathway
Army	Statement / Memo for Record (MFR)	TPOC drafts, CO concurs	TPOC/technical expert drafts the derives-from argument; CO signs; PM routes through contracting office
Navy (NMCARS)	Business Clearance Memo (BCM) + Annex 13 J&A	CO; CCO or HCA per threshold	$700K or less: Activity CCO; $700K-$5.5M: Echelon I/II CCO; $5.5M+: HCA
NASA (NSSC)	Justification for Phase III (Appendix A)	COR/TM signature	Standard NSSC routing; TPOC / technical manager signature block
OPD-DE / DIB policy	Memo for the File / Contract File Documentation	CO	Follow agency-specific BCM or D&F format; derive-extend-complete narrative and 638(r)(4) cite are mandatory regardless of format

Minimum affirmation (SBA-compliant, one sentence)

A CO who writes only this sentence, cites the predicate award, and obtains TPOC concurrence has satisfied the legal documentation requirement per SBA Policy Directive (May 2023), Section 4(c)(3):

"This project is an STTR Phase III award that is derived from, extends, and completes efforts made under STTR Phase I award FA8649-21-P-0756 (CHN Analytics, Inc., AFWERX, AF20C-TCSO1) and is authorized pursuant to 15 U.S.C. 638(r)(4)."

This template provides the expanded seven-section version so a CO has documentation depth available if the action is questioned. The minimum affirmation above is the floor; this memo is the ceiling.