Health centers differentiate staff and board member conflicts of interest (COI) based on their distinct roles: staff COI focuses on operational and procurement activities, while board member COI centers on governance, strategic decisions, and composition restrictions. Both require written standards, disclosure, recusal, and disciplinary measures per HRSA regulations. Per HRSA Chapter 13: Conflicts of Interest, health centers must also maintain written standards of conduct covering COI and governing the actions of their employees and Board members engaged in the selection, award, or administration of contracts that comply with all applicable Federal requirements. By implementing robust COI policies, training, and monitoring, health centers ensure ethical decision-making, maintain community trust, and comply with federal requirements, ultimately supporting their mission to serve underserved populations.

Mitigation Strategies for ensuring compliance may include the following:

• Regular COI training for staff and board members
• Transparent board member selection processes.
• Annual COI disclosures to identify potential conflicts early