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Overview

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Non-Federal entities who apply for and/or receive Federal financial assistance awards are required to "establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain." [1]

During the application process, non-Federal entities are required to disclose to receive Federal grants or cooperative agreements must disclose to the Federal awarding agency (or pass-through entity) in writing any potential conflicts of interest in relation to those awards, in accordance with the established policies by of the Federal agency (or pass-through entity). This may be necessary throughout the award's lifecycle, depending on when the situation in question occurs or is discovered. Failure by the non-Federal entity to disclose conflicts or interest could result in termination of the award

The U.S. Fish and Wildlife Service (FWS) provides its applicants and recipients with possible conflict of interest situations to consider when applying for and receiving FWS awards. Broadly, applicants (and recipients) need to address Conflicts of interest include any relationship or matter which might place the recipient, the recipient’s put them, their employees, or the recipient’s their subrecipients in a position of conflict, real or apparent, between conflict with 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 regarding their organization's conflict of interest policies.

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For more information on the 2 CFR 200 faqs, click here.

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DOI-AAAP 0008 - Conflict of Interest and Mandatory Disclosures for Financial Assistance:Department of the Interior Implementation of 2 CFR Part 200, Sections 200.112 and 200.113

U.S. Fish and Wildlife Guidance

Issuing a New Financial Assistance Award Guidance (1/6/2017)

B. Reviewer conflict of interest certification: Discretionary programs issuing both competitive and single source awards must provide all staff reviewers, peer reviewers, evaluators, panel members, and advisors a copy of Department policy DOI-AAAP-0008. Before participating in any review or evaluation process, all staff reviewers, peer reviewers, evaluators, panel members, and advisors must sign and return to the program office point of contact the Department of the Interior Conflict of Interest Certification attached to DOI-AAAP-0008. Reviewers participating in more than one review panel in a fiscal year can sign a signal certification covering all reviews in that fiscal year, as long as that intention is clearly noted on the signed certification. Such reviewers must sign at least one new certification each fiscal year before participating in any review or evaluation for the year. [....]  All discretionary programs must maintain signed reviewer conflict of interest certification statements related to approved awards following the same records schedule as for the program’s official award files (see Service policy 283 FW 2 for more information), in either the official award file or a centralized subject-matter file.Notice of Funding Opportunity template

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Frequently Asked Questions

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