Guide section list
Comprehensive reference guide
Conflict of interest
Subpart B: General Provisions
Text Accordion Closed
200.112 Conflict of interest
The Federal awarding agencies must establish conflict of interest policies for Federal awards. The University must disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity, if a subrecipient, in accordance with applicable Federal awarding agency policy.
Explanation Accordion Closed
It is the responsibility of each agency to establish COI policies for their awards. Therefore NAU’s responsibilities may depend upon each agency’s standing policies and procedures and its interpretation and implementation of the Uniform Guidance.
A technical correction clarifies that this clause refers to procurement conflicts of interest and not to financial conflicts of interest as defined by NIH and NSF (sometimes referred to as “objectivity in research”). Nonetheless, the University must ensure that all purchases by staff and faculty are carried out ethically and in accordance with State and University policies and procedures.