Sneak Preview: Agency Officials Discuss New Grants Policies

June 5, 2015 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) Officials with the Environmental Protection Agency (EPA) are reviewing stakeholder comments it received concerning its interim financial assistance conflict of interest policy, and said changes could be forthcoming in the next few months.

Alexandra Raver, EPA grants policy specialist, told attendees at a recent Federal Demonstration Partnership meeting that EPA was assessing concerns related to the EPA’s interim policy that was issued to comply with the conflict of interest provision (§200.112) in the Office of Management and Budget’s (OMB’s) uniform grant guidance. EPA sought comments from its awardees after issuing the policy last year.

The conflict of interest provision (§200.112) of the uniform guidance states that federal awarding agencies must establish conflict of interest policies for federal awards. Nonfederal entities must disclose in writing any potential conflict of interest to the federal awarding agency or pass-through entity in accordance with applicable federal awarding agency policy. The EPA interim policy provides details for its awardees, including applicability, definitions, situations requiring disclosure, disclosure requirements, timing and content of disclosures, and EPA actions.

A particular area of concern for research university grant recipients is the requirement in the EPA interim policy for applicants to “conduct a reasonable conflict of interest inquiry to meet their disclosure obligations. EPA’s interim policy defines and applicant as an “individual (including applicants for competitive fellowships under 40 C.F.R. Part 46) or nonfederal entity who submits a competitive proposal and/or final Standard Form 424, ‘Application for Federal Assistance’ following selection by EPA to receive federal financial assistance award under competitive or noncompetitive procedures.” University officials are concerned that this would require an applicant to conduct conflict of interest inquiries on an individual project basis rather at the organizational level with procurement office staff conducting inquiries for the institution, adding that the EPA interim policy is “redundant, costly and unnecessarily burdensome.”

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).

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