EPA's Financial Assistance Conflict of Interest Policy

EPA's Final Financial Assistance Conflict of Interest Policy (applicable October 1, 2015)

As required by Title 2 of the Code of Federal Regulations, section 200.112, EPA has established a Final Financial Assistance Conflict of Interest Policy governing disclosure of actual and potential conflicts of interest by applicants for, and recipients of, federal financial assistance awards from EPA. This Final COI Policy applies to individuals and non-Federal entities requesting and receiving EPA financial assistance on or after October 1, 2015.  The Final COI Policy responds to comments provided by the applicant/recipient community with a streamlined approach to reduce administrative burden. 

The streamlined approach: 1) uses a solicitation clause requiring applicants to notify EPA if their COI point of contact is aware of any unfair competitive advantage the applicant had in competing for EPA awards; 2) relies on systems in place developed by recipients and subrecipients to disclose and address contract/subaward COIs for EPA funded transactions without prescribing the procedures or type of COI inquiry they must conduct; and 3) eliminates the requirement that selected recipients disclose contract/subaward COI prior to award while retaining coverage requiring that recipients disclose any contract/subaward COI post award that affects an EPA funded transaction even if the contract/subaward was entered into prior to award.

EPA’s Final Financial Assistance Conflict of Interest Policy

EPA's Revised Interim Financial Assistance Conflict of Interest Policy (applicable May 22, 2015)

As required by Title 2 of the Code of Federal Regulations, section 200.112, EPA has established a Revised Interim Financial Assistance Conflict of Interest Policy governing disclosure of actual and potential conflicts of interest (COI Policy) by applicants for, and recipients of, federal financial assistance awards from EPA. This Revised Interim COI Policy applies to individuals and non-Federal entities requesting and receiving EPA financial assistance on or after May 22, 2015. EPA streamlined the Interim COI Policy to eliminate the need for applicants to conduct a formal COI inquiry under competitive solicitations to determine whether they obtained an unfair advantage from EPA employees, but will still require their COI Point of Contact to inform EPA should they become aware of a COI in competing for EPA awards.

EPA’s Revised Interim Financial Assistance Conflict of Interest Policy

EPA's Interim Financial Assistance Conflict of Interest Policy (December 26, 2014 to May 22, 2015)

As required by Title 2 of the Code of Federal Regulations 200.112, EPA has established an interim financial assistance conflict of interest policy governing disclosure of actual and potential conflicts of interest COI Policy by applicants for, and recipients of, federal financial assistance awards from EPA. This policy applies to all individuals and non-federal entities requesting and receiving EPA financial assistance on or after December 26, 2014.

EPA's Interim Financial Assistance Conflict of Interest Policy