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Monitoring may be accomplished through desk -based reviews on-site monitoring visits, <br />or both. Monitoring will involve the review and analysis of the financial, programmatic, <br />performance, compliance and administrative processes, policies, activities, and other <br />attributes of each Federal assistance award and will identify areas where technical <br />assistance, corrective actions and other support may be needed. <br />Conflict of Interest <br />To eliminate and reduce the impact of conflicts of interest in the subaward process, <br />recipients and pass-through entities must follow their own policies and procedures <br />regarding the elimination or reduction of conflicts of interest when making <br />subawards. Recipients and pass-through entities are also required to follow any <br />applicable state, local, or Tribal statutes or regulations governing conflicts of interest in <br />the making of subawards. <br />The recipient or subrecipient must disclose to the respective Program Analyst, in writing, <br />any real or potential conflict of interest as defined by the Federal, state, local, or Tribal <br />statutes or regulations or their own existing policies, which may arise during the <br />administration of the Federal award within five days of learning of the conflict of <br />interest. Similarly, subrecipients must disclose any real or potential conflict of interest to <br />the pass-through entity as required by the Recipient's conflict of interest policies, or any <br />applicable state, local, or Tribal statutes or regulations. <br />Conflicts of interest may arise during the process of DHS/FEMA making a Federal award <br />in situations where an employee, officer, or agent, any members of his or her immediate <br />family, his or her partner has a close personal relationship, a business relationship, or a <br />professional relationship, with an applicant, subapplicant, recipient, subrecipient, or <br />DHS/FEMA employees. <br />29 <br />FY 2015 HSGP NOFO <br />