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<br /> <br />32 <br />Revised 9/8/2021 <br /> <br /> Centers for Medicare & Medicaid Services <br /> Standard Grant/Cooperative Agreement Terms and Conditions <br /> Attachment E <br /> <br /> <br /> Conflict of Interest Policy <br />CMS requires recipients to establish safeguards to prevent employees, officers, or agents of the <br />non-Federal entity such as consultants, contractors, members of governing bodies, and others <br />who may be involved in grant-supported activities from using their positions for purposes that <br />are, or give the appearance of being, motivated by a desire for private financia l or other gain for <br />themselves or others, such as those with whom they have family, business, or othe r ties. These <br />safeguards must be reflected in written standards of conduct. Except as provided below, CMS <br />does not require a recipient to establish separate standards of conduct if it maintains such <br />standards for its non-grant-supported activities, as long as those standards are consistent with <br />State, local, and tribal laws and regulations, and cover, at a minimum, expected conduct in regard <br />to financial interests, gifts, gratuities and favors, nepotism, and suc h other areas for <br />governmental organizations as political partic ipation and bribery. <br />Definitions: <br />"Principal Investigator/Project Director (PI/PD)" means the individual(s) designated by the <br />recipient to direct the project or program being supported by the grant. The PI/P D is responsible <br />and accountable to officials of the recipient organization for the proper conduct of the project, <br />program, or activity. This designation also includes co-principal investigators/co-project <br />directors, and any other person at the organization who is responsible for the design, conduct, or <br />reporting of grant activities funded or proposed for funding by CMS. <br />"Significant financial interest" means anything of monetary value, includin g, but not limited to, <br />salary or other payments for services (e.g., consulting fees or honoraria); e quity interest (e.g., <br />stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, <br />copyrights and royalties from such rights). <br />This term does not include: <br /> a. salary, royalties or other remuneration from the applicant organization; <br /> b. income from seminars, lectures, or teaching engagements sponsored by public or <br /> non-profit entities; <br /> c. income from service on advisory committees or review panels for public or nonprofit <br /> entities; <br /> d. an equity interest that, when aggregated for the PI/PD and the PI/PD’s spous e and <br /> dependent children, meets both of the following tests: does not exceed $10,000 in value <br />DocuSign Envelope ID: 7832B0E4-F34E-430E-A3C2-1A6A14F29307