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Commissioner Brown - Finance - To Modify the Uniform Guidance Conflict of Interest Policy which, in Conjunction with the Uniform Guidance Compliance Statement, is an Attachment to the Gaston County Purchasing Policies and Procedures in Order to Comply with Federal Procurement Requirements per 2 C.F.R. Part 200.
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STAFF CONTACT
Tiffany Murray - Finance Director - 704-866-3032
BUDGET IMPACT
budget
N/A
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BUDGET ORDINANCE IMPACT
N/A
BACKGROUND
Uniform Guidance (UG) sets standards for the award and expenditure of federal financial assistance (grants and loans) and is codified at 2 C. F. R. Part 200. Procurement standards are codified at 2 C. F. R. Subpart D (200. 317- 326). These federal requirements became effective July 1, 2018. In order to comply, Gaston County adopted a written compliance statement and a written conflict of interest policy relative to federal grant or loan funds based on the UNC School of Government template. Reference previous Board Action 2018-157.
The School of Government recommends modifying the conflict of interest policy by adding a definition of immediate family member. The definition is per 2 C.F.R. Subpart E (200.465(c)(4)). This is the only change to the attachment.
POLICY IMPACT
Uniform Guidance affects all federal funding (grants and loans) including federal funds passing through others to Gaston County, and passing through Gaston County to others. Noncompliance could result in de-obligation of funding.
ATTACHMENTS
Uniform Guidance Purchasing Policy Compliance Statement and modified Conflict of Interest Policy.