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Non-Federal entities who receive Federal grants or cooperative agreements must disclose in writing any real or perceived conflicts of interest in relation to those awards to the Federal awarding agency (or pass-through entity) in accordance with established policies by the Federal agency (or pass-through entity. ). This may be necessary anytime throughout the award's lifecycle, depending on when the conflict of interest occurs or is discovered.
Conflicts of interest include any relationship or matter which might place the recipient, the recipient’s employees, or the recipient’s subrecipients in a position of conflict, real or apparent, between their responsibilities under the award and any other outside interests. Conflicts of interest may also include, but are not limited to, direct or indirect financial interests, close personal relationships, positions of trust in outside organizations, consideration of future employment arrangements with a different organization, or decision-making affecting the award that would cause a reasonable person with knowledge of the relevant facts to question the impartiality of the applicant, the applicant’s employees, or the applicant’s future subrecipients in the matter.
Non-Federal entities should consult their HR on their conflict of interest policies.
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2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
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