SNAPS is working with staff from Office of Strategic Planning & Management, in the Grants Management & Oversight (GMO) Division to bring our recipients into compliance with 2 CFR Part 200. Federal regulations (2 CFR part 200) and HUD's Notices of Funding Availability (NOFA) for discretionary funds require non-Federal entities receiving Federal assistance awards, excluding States, to develop and maintain written standards/codes of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest (2 CFR 200.318(c)(1)).
With the implementation of 2 CFR Part 200, we found that a majority of CoC Program recipients Codes of Conduct are not in compliance, which will require a new Code of Conduct submission that will undergo an extensive review. The Grants Management Office maintains a library of these documents and updates HUD’ Code of Conduct page at www.hud.gov on a quarterly basis. Submitting the document is only the first step to our recipients being compliant. HUD must review and certify that the Code of Conduct meets minimum standards set forth in 2 CFR Part 200.
Specifically, Codes of Conduct must:
· Be written on company letterhead that provides the name and title of the responsible official, mailing address, business telephone number and email address;
· Prohibit real and apparent conflicts of interest that may arise among officers, employees or agents, or any member of his or her immediate family, his or her partner or an organization that employs any of the indicated parties;
· If applicable, the standards must also cover organizational conflicts of interest;
· Prohibit the solicitation and acceptance by employees, of gifts or gratuities in excess of minimum value; and
· Provide for administrative and disciplinary actions to be applied for violations of such standards.
All CoC Program recipients and potential applicants intending to submit a project application in the FY 2017 CoC Program Competition MUST have a compliant Code of Conduct on file with HUD. Failure to provide a copy of the organizations Code of Conduct and/or notify HUD of potential conflicts of interest may prevent applicants from receiving HUD funds. SNAPS is working to address this NOW, rather than during the end of the application process to allow CoC Program recipients and applicants to update their Codes if necessary. All Collaborative Applicants and project applicants recently received an email from GMO asking them to submit their Code of Conduct to askGMO@hud.gov mailbox.
We understand this has led to confusion in our communities, so we want to assure recipients they should submit their Codes of Conduct to the mailbox. HQ SNAPs is also sending a message to all Collaborative Applicants and project applicants to let them know the request is legitimate and they should respond now to prevent issues during the CoC Program Competition award process.