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Overview
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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 must disclose in writing any potential conflicts of interest related to the funding opportunity. If disclosed, the Federal agency or pass-through entity 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 or subaward to disclose any subsequent real or perceived conflicts of interest during its lifecycle. Failure to do so could result in termination of the award or subaward.
Authorities
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2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Anchor 200.112 200.112
§200.112 Conflict of interest.
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[78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014; 80 FR 43309, July 22, 2015]
The Council on Financial Assistance Reform's (COFAR) Frequently Asked Questions on 2 CFR 200 (July 2017 update)
200.112
.112-1 Conflict of Interest
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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 Service Guidance
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Notice of Funding Opportunity (March 21, 2018)
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Conflicts of interest include any relationship or matter that 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. 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 including any key project personnel, subrecipients, and contractors, that 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 have received funding or who otherwise may be involved with your project. Failure to disclose and 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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As a recipient, how do I ensure I'm compliant with the Uniform Guidance and FWS policy on conflicts of interest?
In the application package, you must disclose any potential conflict of interest to the Service. See here for more information.
I plan to subaward Federal funds. What are my responsibilities as a pass-through entity regarding potential conflicts of interest by my subrecipient?
As a pass-through entity, you must communicate the Federal awarding agency's conflict of interest disclosure policy to your subrecipients, as stated in 2 CFR 200.112.
I have received a Federal subaward and may have a conflict of interest. Do I report this to the Service?
No. You must report this to the pass-through entity who will communicate, if needed, with the Service.
I know avoiding conflict of interest is very important under Federal procurement rules. Are there conflict of interest requirements for contracts under Federal financial assistance awards?
Yes. 2 CFR 200.318(c)(1) requires non-Federal entities to maintain written conflict of interest standards for contractual activities under Federal awards.
How does the Service inform applicants and recipients of conflict of interest requirements?
All FWS awards include conflict of interest disclosure requirements for recipients. Please refer to your Notice of Award or contact the U.S. Fish and Wildlife Service Technical Representative for information regarding conflict of interest.
Learning Aids
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Related Pages
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Resources
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References
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1. "Conflict of Interest." Merriam-Webster.com. Merriam-Webster, n.d. Web. 29 Dec. 2017.
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