OMB Uniform Guidance - Key Impacts on CNCS Grantees - Conflict of Interest

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OMB Uniform Guidance

Key Impacts on CNCS Grantees

1 -  Conflict of Interest

Dear Colleagues,

This is the first in a series of messages addressing individual rules within the Uniform Guidance, and what they mean to CNCS grantees.  

The regulation section number denotes where in the Uniform Guidance the rule being discussed in this bulletin is found.

2 CFR §200.112. Conflict of Interest 

This rule requires non-federal entities (grantees and subgrantees) to disclose, in writing, potential conflicts of interest in accordance with CNCS policy. CNCS added this requirement to grant General Terms and Conditions. Non-federal entities must develop and implement conflict of interest policies and procedures that incorporate this notice requirement.

Why is this important?

Failing to identify a conflict of interest puts the grantee at risk of allowing improper considerations to influence or appear to influence the rating and ranking of subgrantee (both contract and subgrant) applications. Undisclosed conflicts of interest could result in disallowed costs or other penalties up to and including termination of your grant, and potential suspension or debarment. 

What You Should Do

Non-federal entities must develop and implement Conflict of Interest policies and procedures ensuring timely disclosure to CNCS if they are not already in place.

If you have concerns or questions regarding these conflict of interest rules, please send them to  Your feedback and questions will guide us to develop additional information and guidance.

In Service,

Dana Bourne, Chief Grants Officer
Corporation for National and Community Service Grant Offices
Washington, DC and Philadelphia, Pennsylvania