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OMB
Uniform Guidance
Key Impacts
on CNCS Grantees
1 - Conflict of Interest
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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 blewis@cns.gov. 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
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