Val,

Check A-110, Procurement Standards 42. Codes of Conduct:  "...No
employee, officer, or agent shall paticipate in the selection, award, or
administration of a contract supported by Federal funds if a real or
apparent conflict of interest would be involved.  Such a conflict would
arise when the employee, officer, or agent, any member of his or her
immediate family, his or her partner, or an organization which employs
or is about to employ any of the parties indicaed herein, has a
financial or other interest in the firm selected for an award...."  In
my view, the spouse of one of the researchers in the Pis group would
trigger this prohibition.  Hopefully this helps.

Glen

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
Behalf Of Val Seaquist
Sent: Wednesday, March 24, 2004 2:56 PM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] Conflict of Interest with subcontractors

Good Afternoon,

I'm actually asking this on behalf of someone else and thought I would
go to the source of all knowledge.

Situation: A PI wishes to issue a subcontract (under a Federal contract)
to a qualified consultant who is the spouse of one of the researchers in
the PIs group. There is a good possibility that the researcher would be
in the position of supervising the consultant/spouse. The contract
people (State university) do not believe that this is proper and the PI
is requesting specific citations prohibiting this action.

If it was at this university, I would cite our university and State law
COI policies/regulations before I even got to the Federal level. Is
there a specific FAR clause that would prohibit this action or should
the contracts office fall back on their own State and university
regulations/policies?

Val Seaquist
Office of Sponsored Programs
The University of Alabama in Huntsville

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
subscription information and a web-searchable archive, are available
via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================