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Financial Conflict of Interest in Sponsored Programs - Compliance with Federal & State Law

LMC Revised Date

Office of Origin: Human Resources, Finance
Date Adopted: 10-22-96
Date Reviewed: 11-22-08, 12-14-17
Last Date Modified & Approved: 12-14-17

Lake Michigan College (the College) shall protect Federal and State funded programs from any bias that can be expected to arise from the financial interests of College employees involved in projects funded by Federal and State grants. 

The College may not permit any person participating in a Federal and State funded program to use his / her position for a purpose that is or gives the appearance of being motivated by a desire for a private financial gain for that person or others. 

Employees may not be permitted to participate in decisions regarding a Federal and State funded program if:

  1. The decision is likely to benefit that person or a member of his / her immediate family.
  2. The person is a public official or has a family or business relationship with the grantee.  

Accordingly, and in accordance with Federal and State regulations, College employees involved in projects funded by Federal and State grants must sign the "Conflict of Interest Form" annually at the start of each project fiscal year.

  1. Definitions
    • Immediate Family of an individual includes his/her spouse and children.
    • A Financial Interest is anything above a deminimus value, including but not limited to commissions, consulting fees, honoraria, stocks, stock options, ownership interests, allowance, forbearance, forgiveness of debt, interest in real or personal property, dividends, royalties derived from the licensing of technology, rent, capital gain, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights).
  2. Mandatory Disclosures
    The non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Failure to make required disclosures can result in any of the remedies for noncompliance including suspension or debarment. (2 CFR part 200.113)

Responsibility: Executive Director, Human Resource; Chief Finance Officer


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