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Non-Federal entities who apply for and 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." [2] Broadly, applicants (and recipients) need to address any relationship or matter which might put themselves, their employees, or their subrecipients in conflict with their responsibilities under the award and outside interests. During the application process, non-Federal entities disclose in writing any potential conflicts of interest related to the funding opportunity. If disclosed, the Federal agency may elect to work with the applicant on a mitigation plan as part of the Federal awards terms and conditions. Successful applicants agree when accepting the Federal award to disclose any subsequent real or perceived conflict's of interest related to the award during its lifecycle. Failure to do so could result in termination of the award.
Authorities
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2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
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A: Yes. When a subaward for scientific collaboration on a research and development project is included in the application for assistance or requested for prior approval and approved by the Federal awarding agency, the disclosure of any potential nonscientific conflict of interest, if required by the Federal awarding agency, provides sufficient information to the Federal awarding agency for the purpose of compliance with section 200.112.
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U.S. Fish and Wildlife Guidance
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Notice of Funding Opportunity template (March 21, 2018)
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The 2 CFR 200 requires all non-Federal entities to disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity in accordance with the applicable Federal awarding agency policy.
As a recipient of financial assistance awards, how do I become aware of the
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U.S. Fish and Wildlife conflict of interest requirements?
All FWS awards include conflict of interest disclosure requirements for recipients.
All Department of Interior financial assistance awards will include a term and condition that prohibits the recipient, employees of the recipient, and subrecipients conflict of interest. Recipients should review this term and condition in the notice of award concerning the Department of Interior's conflict of interest policy.
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