Federal Agency Compliance
Conflict of Interests
UT Faculty and staff are expected to take all reasonable precautions to ensure that their outside financial interests (including interests of a spouse, dependent children, and nondependent children) do not place them in conflict with carrying out their duties and responsibilities as employees of the university. Conflicts of interest include (but are not limited to) the following situations:
- A UT employee allows outside financial interests to interfere with or compromise judgment and objectivity with respect to duties and responsibilities to the university and sponsoring organizations.
- A UT employee makes university decisions or uses university resources in a manner that results or is expected to result in (1) personal financial gain or the financial gain of relatives or (2) an unfair advantage or favored treatment afforded to a third party outside the university.
- A UT employee allows outside financial interests to affect the design, conduct, or reporting of research.
UT Fiscal Policy #FI0125 explains the UT Conflict of Interest Policy, provides examples of conflicts of interest and includes information about faculty and staff reporting requirements and links to the Outside Interest Disclosure Form that all faculty and staff should complete annually.
All UTC faculty and staff named in a grant proposal or contract must submit an Outside Interest Disclosure Form—either the general UT form or the PHS FCOI form for proposals to any Public Health Service agency (HHS, NIH, HRSA, etc.). The disclosure forms must be completed and signed by the individual and supervisor, and attached to Evisions for routing prior to the proposal submission. If any member of the proposal team has a conflict to disclose, notify ORSP immediately so that an appropriate resolution can be determined prior to submitting the proposal.
Education Department General Administrative Regulations (EDGAR) contains regulations for administering discretionary and formula grants awarded by the U.S. Department of Education and establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher education, hospitals, and other non-profit organizations.
FFATA Requirements for Subcontracts
The Federal Funding Accountability and Transparency Act (FFATA) makes information on federal expenditures of taxpayer dollars more accessible to the public. FFATA requires prime recipients of federal awards to report on their subawards via a public website. Subawards include subcontracts, subgrants, and other instruments awarding funds to third party recipients.
Click here for FFATA Data Collection Form.
The National Science Foundation (NSF) Proposal and Award Policies and Procedures Guide (PAPPG) guide is effective for proposals submitted, or due, on or after January 30, 2017. The guide is comprised of documents relating to the Foundation's proposal and award process. It consists of two parts:
- Part I is comprised of NSF’s proposal preparation and submission guidelines -- the NSF Grants.gov Application Guide. The Grants.gov Application Guide provides guidance for the preparation and submission of proposals to NSF, whether by the NSF Fastlane System or Grants.gov.
- Part II is comprised of the documents used to guide, manage, and monitor the award and administration of grants and cooperative agreements made by the Foundation. Coverage includes the NSF award process, from issuance and administration of an NSF award through closeout. Guidance regarding other grant requirements or considerations that either is not universally applicable or which do not follow the award cycle also is provided.
OMB Uniform Guidance
Office of Management and Budget (OMB) Uniform Guidance establishes a set of principles for federal grants management determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project. The principles are designed to provide that the Federal Government bear its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law.
Uniform Guidance was drawn from and replaces OMB Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-122, and A-133. Please click here for the full text of the OMB Uniform Guidance.