We, like the rest of the "world," have implemented new procedures to
address the Coflict of Interest policies for NSF/NIH.  In doing so, I
came up with a "new" twist.  One of our PI's called to say that he didn't
want to follow procedure because it created problems for him.  The
problem - his spouse works for a federal agency.  Several years ago he
also worked for that agency, then came to us on an IPA, and finally,
joined our faculty full time.  He says that the agency's regional office
told him a few years ago that he "technically" isn't eligible for federal
funding of any kind because of his wife's employment.  He neglected to
pass this information on to our office and has received several awards
from that agency.  (Apparently he accepted the advice that since the
award was made to the University and not him there wasn't a problem since
the link wasn't readily visible.)  Now, because of his wife's employment
status, of which we are aware, there is the 'appearance of a conflict'
which must be declared at the proposal stage (and, of course, resolved at
the award stage).

Do any of you know if, in fact, there is some statutory ineligibility for
federal funding (as the PI was told by the regional office) that is a
result of employment status?  Conflict of interest, in the real sense,
doesn't appear to be a problem....there is absolutely no way the spouse
can affect the review, selection, or award.  She has no "inside"
information which would influence the proposal, project or award.  And, her
own work, while in a related discipline, is in no way dependent upon
any results from the project.

If, indeed, there is something which prohibits the receipt of federal
funding from any or all sources, can you tell me where I can find the
regulations?  Obviously, we can go to the agency's national office for a
determination.  Here's the "but" - but that will take at least a couple
of weeks and we only have a week to get an omnibus proposal out of
here.  Several projects may be affected if we decide to leave his
project in and he is truly ineligible.  On the other hand, his project
is an excellent one which received excellent reviews and will be funded
along with the rest of the omnibus.  We don't want to elimnate his
project unnecessarily if there's an easy answer which won't jeopardize
the whole program.

Thanks for any assistance you can give.
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Rosemary Ruff
Proposal Officer
University of Alaska Fairbanks
Fairbanks, AK  99775-7220

VOICE:  (907)474-6735
FAX:    (907)474-7204