SUBRECIPIENT COMMITMENT FORM
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7. Conflict of Interest (applicable to PHS & NSF funded projects or agencies that have adopted the federal financial disclosure
requirements)
Please check the appropriate responses below
a. Not applicable because this project is not being funded by PHS (NIH, CDC, AHRQ, etc.), NSF, or any other sponsor
that has adopeted the federal financial disclosure requirements. See
http://sites.nationalacademies.org/PGA/fdp/PGA_070596 for list of sponsors that adopted federal financial disclosure
requirements
For PHS Funded Projects ONLY:
b.1
Subrecipient Organization/Institution is listed on the FDP Clearinghouse (http://sites.nationalacademies.org/PGA/fdp/PGA_070596)
and certifies that it has an active and enforced conflict of interest policy that is consistent with the provision of 42 CFR Part 50,
Subpart F “Responsibility of Applicants for Promoting Objectivity in Research” and 45 CFR Part 94 “Responsible Prospective
Contractors.” Subrecipient also certifies that, to the best of Institution’s knowledge, (1) all financial disclosures will be made related
to the activities that may be funded by or though a resulting agreement, and required by its conflict of interest policy, and (2) all
identified conflicts of interest have or will have been satisfactorily managed, reduced or eliminated in accordance with subrecipient’s
conflict of interest policy prior to the expenditures of any funds under any resultant agreement and within a timely manner sufficient
to enable timely FCOI reporting.
b.2
Subrecipient will follow the Conflict of Interest Policy established and eforced by his/her institution. Subrecipient certifies that the
Conflict of Interest Policy established is consistent with the provision of 42CFR Part 50, Subpart F “Responsibility of Applicants for
Promoting Objectivity in Research” and 45 CFR Part 94 “Responsible Prospective Contractors.”
b.3
Subrecipient does not have an active and/or enforced conflict of interest policy and agrees to adopt the University of Maryland,
Baltimore’s policy located at http://cf.umaryland.edu/umpolicies/printPolicy.cfm?polid=382
c. By signing below, Subrecipient certifies that the required training will be completed by each investigator prior to engaging in any
resear
ch related to any PHS funded contract/grant. For those adopting University of Maryland, Baltimore’s policy, the training is
located online at http://www.umaryland.edu/oac/research/research-integrity-and-compliance/conflict-of-interest/
8. Debarment and Suspension
Is the PI or any other employee or student participating in this project debarred, suspended or otherwise excluded from or
ineligible for participation in federal assistance programs or activities? Yes No
(
if “Yes”, explain in Section D Comments below)
The Subrecipient certifies they: (answer all questions below)
Are Are not Presently debarred, suspended, proposed for debarment, or declared ineligible for
award of federal contracts.
Are Are not Presently indicted for, or otherwise criminally or civilly charged by a governmental
entity
Are Are not Within three (3) years preceding this offer, been convicted of or had a civil judgment
rendered against them for commission of fraud or criminal offense in connection
with obtaining, attempting to obtain, or performing a public (federal, state or local)
contract or subcontract; violation of Federal or State antitrust statutes relating to the
submission of offers; or commission of embezzlement, theft, forgery, bribery,
falsification or destruction of records, making false statement or receiving stolen
property.
Are Are not Within three (3) years preceding this offer, had one or more contracts terminated for
default by any federal agency
SECTION C – Audit Status
9. Audit Status
Subrecipient receives an annual audt in accordance with Uniform Guidance 2 CFR 200
Most recent fiscal year completed: FY
Subrecipient DOES NOT receive an annual audit in accordance with Uniform Guidance 2 CFR 200.
Subrecipient is a: Non-profit entity (
received less than $750,000 in federal assistance i.e. federal funds, grants or awards)
Foreign entity
For Profit entity
Governmental entity