Conflict of Interest Policy

Are there any clear expectations on what is involved in the Conflict of Interest Policy?

The Health Center Program Compliance Manual and Site Visit Protocol provide specific guidelines. Regardless of the name of the document (Conflict of Interest vs Standards of Conduct), the result is the same. Conflicts of Interest can happen; therefore, guidelines need to be written and followed. The following information should be provided in the document:

 

  • Apply to all health center employees, officers, board members, and agents involved in the selection, award, or administration of such contracts; Remember, an agent of the health center includes, but is not limited to, a governing board member, an employee, officer, or contractor acting on behalf of the health center.
  • Require written disclosure of real or apparent conflicts of interest; A conflict of interest arises when the employee, officer, or agent (including, but not limited to, any member of the governing board), any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in, or a tangible personal benefit from a firm considered for a contract. 
  • Prohibit individuals with real or apparent conflicts of interest with a given contract from participating in the selection, award, or administration of such contract.  This includes, but is not limited to, prohibiting board members that are employees or contractors of a subrecipient of the health center from participating in the selection, award, or administration of that subaward. This also includes prohibiting board members who are employees of an organization that contracts with the health center from participating in the selection, award, or administration of that contract.
  • Restrict health center employees, officers, board members, and agents involved in the selection, award, or administration of contracts from soliciting or accepting gratuities, favors, or anything of monetary value for private financial gain from such contractors or parties to sub-agreements (including subrecipients or affiliate organizations).  Health centers may set standards for situations in which the financial interest is not substantial, or the gift is an unsolicited item of nominal value. 
  • Enforce disciplinary actions on health center employees, officers, board members, and agents for violating these standards.

 

For additional specific requirements, please visit: https://bphc.hrsa.gov/programrequirements/site-visit-protocol/conflict-interest 

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