KS BoS CoC Conflict of Interest

Conflict of Interest:

Pursuant to §578.95 of the CoC Program Interim Rule, all members Kansas Balance of State Continuum of Care (KSBoSCoC) must sign a conflict of interest statement. This form serves as that statement. To read KS BoS CoC’s Conflict of Interest policy, please go here. The conflict-of-interest statement must affirm that that members of the KSBoSCoC, Steering Committee, and Standing Committees will not participate in, or influence, discussions or resulting decisions concerning the award of a grant or other financial benefits to the organization that the member represents.

Conflict of Interest & Recusal

It is the policy of the Kansas Balance of State CoC that a conflict, or the appearance of a conflict, between the members of the entire KSBoSCoC, Steering Committee, standing committees or any of its official committees and the organizations, which are receiving awards of grants or benefitting from other business items, shall in all cases be avoided. No member of the CoC (Steering Committee or standing committee, Member, Agent, or employee of Agent) shall vote or make recommendations on funding decisions concerning the award of a grant or other financial issues that:

• Directly benefit them as an individual, or an immediate family member.
• Directly benefit any organization in which they have a direct financial interest.
• Directly benefit any organization with which they are affiliated in an official capacity; or
• Directly benefit any organization from which they derive financial benefit, exclusive of stipends.

To that end, no Committee member whose organization is submitted in the HUD CoC application and ranked for that application may vote on ranking policies. Such members may participate in the development of performance targets and the evaluation tool. Persons with lived homeless experience who receive services from an organization that may directly benefit from a funding decision may vote or make recommendations on funding decisions.

Members of the CoC will disclose potential conflicts of interest that they may have regarding any matters that come before the Kansas Balance of State CoC in full session, Steering Committee or standing committees.

Procedure

• Annual disclosures: All members will make a full, written disclosure to the Steering Committee of interests, relationships, and investments that could potentially result in a conflict of interest. This written disclosure will be kept on file and be updated annually. If it is not entirely clear whether a conflict of interest exists, the member must disclose the circumstances to the Steering Committee to determine whether one exists.
• Meeting discussions: A member who knows he or she has a conflict of interest must not participate in the discussion except to share essential facts and to respond to questions. The person must not attempt to influence the committee’s action, either at or outside the meeting.
• Voting: A voting member who knows he, she, or they have a conflict of interest may not vote on that issue. The meeting Chair will announce upcoming votes in agendas, and a voting member who knows he or she has a conflict of interest must so disclose. Voting members are encouraged to contact the Steering Committee to disclose but may also disclose during the meeting. The disclosure must be reflected in the minutes of the meeting.