As the end of fiscal year 2014 approaches and the beginning of fiscal year 2015 draws near, nonprofit organizations must begin to prepare for the implementation of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly known as the "Super Circular"). As detailed in our prior newsletters, one of the Super Circular's seminal purposes is to curb waste, fraud, and abuse. To that end, the Super Circular seeks to strengthen oversight of federal awards by requiring that federal agencies and pass-through entities obtain disclosures of conflicts of interests from prospective recipients of federal funds. This guidance markedly differs from that of predecessor circulars, particular Circular A-110, in ways that have not been fully clarified.
Conflict of Interest Standards of Circular A-110 -
OMB Circular A-110 (Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) requires organizations receiving federal funds to maintain a written code of conduct for its employees who engage in the performance of the work under a federal award. Within this code of conduct, the organization must include a proviso relating to conflicts of interest. Specifically, A-110 provides that...
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