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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]
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Notice of Funding Opportunity template
Frequently Asked Questions
What is the purpose of this section of the Uniform Guidance?
The purpose of this section and much of the Uniform Guidance is to help to improve Federal awards performance and outcomes, in addition to ensuring the financial integrity of taxpayer funds in partnership with non-Federal stakeholders.
Does the Department of Interior have a conflict of interest policy for its employees?
Yes, the Department of Interior adopted a conflict of interest policy (DOI-AAAP-0008) on December 22, 2014.
What does the Department of Interior policy say concerning those employees who evaluate applications for Federal financial assistance?
The policy says that upon receipt of a memorandum of appointment, each proposal evaluator and/or advisor shall sign and return the Conflict of Interest Certificate to the Grants Officer. If an actual or potential conflict of interest exists, the appointee shall not be allowed to evaluate or provide advice on a potential applicant's proposal or provide advice on a potential applicant's proposal until the conflict of interest has been resolved with the servicing Ethics Counselor.
What if an evaluator signs the Conflict of Interest Certificate and then later becomes aware of a potential conflict of interest during the review process?
The Department of Interior policy clearly states that evaluators and advisors must immediately disclose in writing to the Grants Officer as soon as it becomes known that an actual or potential conflict of interest exists. The Grants Officer must then obtain the assistance of the servicing Ethics Counselor in order to reach an opinion or resolution and a record of this must be included in the official award file.
Where are the signed Conflict of Interest Certificates housed?
(March 21, 2018)
I. Conflict of Interest Disclosures: Applicants must notify the Service in writing of any actual or potential conflicts of interest that are known at the time of application or that may arise during the life of this award, in the event an award is made. 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. Applicants must notify the Service in writing in their application if any key project personnel, including subrecipient and contractor personnel, are known to be related to, married to, or have a close personal relationship with any Federal employee in or associated with the program to which you are applying for funding or who otherwise may be involved in the review and selection of the application. Upon receipt of such a notice, the Service Project Officerprogram, in consultation with their Ethics Counselor, will determine if a conflict of interest exists and, if so, if there are any possible actions to be taken by the applicant to reduce or resolve the conflict. Failure to disclose and resolve conflicts of interest in a manner that satisfies the Service may result in the project not being select for funding.
Notice of Award Letter template (January 6, 2017)
Conflict of Interest Disclosures:
Recipients are responsible for notifying the Service Project Officer in writing of any actual or potential conflicts of interest that may arise during the life of this award. 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 this 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 Recipient, the Recipient’s employees, or the Recipient’s subrecipients in the matter. Upon receipt of such a notice, the Service Project Officer in consultation with their Ethics Counselor will determine if a conflict of interest exists and, if so, if there are any possible actions to be taken by the Recipient, the Recipient’s employee(s), or the Recipient’s subrecipient(s) that could reduce or resolve the conflict. Failure to resolve conflicts of interest in a manner that satisfies the Service may result in any of the remedies described in 2 CFR 200.338, Remedies for Noncompliance, including termination of this award.
Frequently Asked Questions
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What is the purpose of this section of the Uniform Guidance?
The purpose of this section and much of the Uniform Guidance is to help to improve Federal awards performance and outcomes, in addition to ensuring the financial integrity of taxpayer funds in partnership with non-Federal stakeholders. All signed certificates from the proposal evaluators and advisors must be retained in the master files for the Funding Opportunity Announcement.
What are some examples of situations that may represent a potential or actual conflict of interest?
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