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<br /> <br />34 <br />Revised 9/8/2021 <br />funding by CMS; or (ii) in entities whose financial or other interests would <br />reasonably appear to be affected by such activities. <br /> One or more objective persons (1) reviews the potential conflict of intere st; (2) <br />determines whether a pote ntial (appearance of) or real conflict of interest exists; <br />and (3) Establishes what conditions, or restrictions, should be imposed to <br />eliminate the conflict of interest. <br /> This information is conveyed to the Responsible Representative for the <br />organization w ho is designated to act on behalf of the applicable CMS award. <br />• Prior to expending funds under a new CMS award, the Responsible Representative <br />must inform the applicable CMS Grants Management Specialist and Project Officer <br />of any real or potential conflict of interest. The report must detail Rec ipient’s plan to <br />eliminate the conflict prior to spending CMS funding on the activities in question. <br />• Require that similar reports for subsequently identified conflicts be ma de within 30 <br />days of identifying them. Funding for those specific activities should cease until the <br />aforementioned steps are completed. <br />• Require that continual updates be made for any real or potential conflicts of interest <br />not fully resolved. Recipient must make additional information available to the CMS <br />Grants Management Specialist and Project Officer, upon request, as to how it is <br />handling (or had handled) the real or potential conflict of interest. <br />• Recipients must maintain records of all disclosures and of all actions taken to resolve <br />conflicts of interest for at least three years beyond the termination or completion of <br />the grant to which they relate, or until the resolution of any CMS action involving <br />those records, whichever is longer. <br />• The Recipient’s policy must include adequate enforcement mechanisms, and pr ovide <br />for sanctions where appropriate. <br />Recipient may resolve such conflicts of interest through one or more of the following options <br />outlined below. This is not an exhaustive list and Recipient may pursue other re medies. <br />• Modification of approved project to remove potential or real conflict of intere st. <br />• Termination of agreement or other services that create potential or real conflict of <br />interest. <br />• Removal of individuals with potential or real conflict of interest. <br />• Severance of relationships that create potential or real conflicts of interest. <br />• Divestiture of significant financial interests. <br />Recipient must ensure that CMS award funds are administered in accor dance with conflict of <br />interest policies that meet, at a minimum, the standards outline d above, inclusive of pass -through <br />entities, subrecipients, contractors, or collaborators. Each entity must have its own policies in <br />place that meet these requirements or mandate that the PIs/PDs working for such entities follow <br />those of the Recipient. <br /> <br /> <br />DocuSign Envelope ID: 7832B0E4-F34E-430E-A3C2-1A6A14F29307