Could an organization in the coalition be a Project Subrecipient if there is a conflict-of-interest policy in place?

Full Question

If we develop a conflict-of-interest policy and require recusal from evaluating or prioritizing projects where a conflict arises, would this allow EJ orgs to submit projects for funding even if they are getting paid to advise on the structure and process for the re-grant program and participation in evaluating and prioritizing projects submitted to the re-grant program?  

Answer

As a new federal granting program, it is important to minimize conflicts of interests to ensure a fair and equitable Project RFA that will build and sustain relationships with underserved communities. Coalition members cannot be Project Subrecipients. 

If selected as a Principal Recipient, applicants encountering potential conflicts of interest would consult with their EPA Project Officer.