CGMS 100%

Study grouping: Grant Guidance

Lesson 9: Ethics and conflict of interest

NGMA's Code of Ethics, and two different conflict-of-interest rules in 2 CFR 200 · 14 practice questions

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Reading

Ethics shows up twice in a CGMS holder's professional life: as NGMA's own Code of Ethics and Professional Conduct, which binds anyone holding the credential, and as the federal conflict-of-interest rules in 2 CFR 200 that bind any organization handling federal grant funds, credential or not. This lesson gives NGMA's ethical standards their actual content and sets them beside the two federal conflict-of-interest rules that apply to the organization itself.

NGMA's Code of Ethics: four core values

NGMA's Code of Ethics and Professional Conduct for the CGMS credential is organized around four core values. Responsibility is the duty to take ownership for the decisions a practitioner makes, or fails to make. Respect is the duty to show high regard for oneself, for others, and for the resources entrusted to the practitioner, a grants manager handles other people's (and the public's) money, and the Code treats that trust as something to be actively honored, not just technically complied with. Fairness is the duty to make decisions and act impartially and objectively. Honesty is the duty to understand the truth and act in a truthful manner. The Code sorts its standards into aspirational ones, ideals a practitioner should strive toward, and mandatory standards, binding rules that carry real consequences for violation.

What the mandatory standards specifically prohibit

Among the Code's mandatory standards: it prohibits illegal conduct such as theft, fraud, corruption, embezzlement, and bribery; discrimination; abusive behavior; and deceptive communications, including misleading or false statements. It also requires a practitioner to report unethical or illegal conduct to appropriate management, and to inform themselves of and uphold the policies, rules, regulations, and laws that apply to their work, which for most CGMS holders means 2 CFR 200 itself, among other rules. On conflicts of interest, the mandatory standard says a practitioner must proactively and fully disclose any real or potential conflict. The Code does not say a practitioner can never have any conflict of interest at all, since real life makes that unrealistic; it requires that any conflict be disclosed rather than concealed.

What happens if a CGMS holder violates the Code

NGMA states that practitioners who do not conduct themselves in accordance with the Code are subject to disciplinary procedures before the CGMS Committee, and that failing to adhere to its ideals and values may result in revocation of the CGMS credential itself. This is worth internalizing precisely because the exam-and-renewal process makes CGMS feel like a one-time achievement followed by administrative upkeep (CPEs, a renewal fee); ethics is the one place where the credential can actually be taken away for conduct, not merely lapse for paperwork.

2 CFR 200.112: conflict of interest at the federal award level

Separately from NGMA's own Code, and separately from the procurement-specific conflict-of-interest standard in 200.318 covered in lesson 5, 2 CFR 200.112 sets a broader, award-level conflict-of-interest requirement. It requires federal agencies to establish conflict-of- interest policies for federal awards, and it requires recipients and subrecipients to disclose, in writing, any potential conflict of interest to the relevant federal awarding agency (or pass-through entity), in accordance with that agency's established policy. This is a proactive disclosure obligation, an organization is expected to identify and report a conflict itself, not wait to be asked about it or only address it if a procurement happens to trigger 200.318.

Why there are two separate conflict-of-interest rules, not one

200.318 is narrow and specific: it applies to procurement decisions, selecting a contractor or vendor, and the people whose interests it reaches are those directly involved in that procurement. 200.112 is broader: it covers any potential conflict of interest connected to the award generally, whether or not a procurement is involved, and it requires proactive written disclosure to the funder rather than only an internal written policy. A grants manager needs both: internal procurement standards of conduct satisfying 200.318, and a general practice of disclosing broader conflicts under 200.112, and neither one substitutes for the other.

Mandatory disclosures beyond conflicts of interest

2 CFR 200.113 extends the disclosure obligation further: an applicant, recipient, or subrecipient must promptly disclose, in writing, whenever it has credible evidence, in connection with the federal award, of a violation of federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the U.S. Code, or a violation of the civil False Claims Act. The written disclosure goes to the federal agency, the agency's Office of Inspector General, and the pass-through entity if there is one. Failure to make a required disclosure can result in any of the remedies in 200.339, which include initiating suspension or debarment proceedings (or, for a pass-through entity, recommending them), on top of whatever the underlying violation was. Silence about a known problem is its own separate compliance failure, not a neutral choice.

Two conflict-of-interest layers, plus NGMA's own Code Three parallel boxes: NGMA's Code of Ethics with its four core values, responsibility, respect, fairness, honesty, binding CGMS holders personally; 2 CFR 200.318, narrow, procurement-specific conflicts; and 2 CFR 200.112, broad, award-level conflicts requiring proactive written disclosure to the funder. NGMA Code of Ethics Binds the CGMS holder personally Responsibility Respect Fairness Honesty Violation risks credential revocation 2 CFR 200.318 Binds the organization Narrow: procurement only Written standards of conduct, prohibiting staff/board conflicts in contractor selection 2 CFR 200.112 Binds the organization Broad: any award-level conflict Proactive written disclosure to the awarding agency or pass-through entity
Three separate ethics obligations run at once: a personal one from NGMA, and two organizational ones from 2 CFR 200 that cover different scopes and never substitute for each other.

Practice questions

1. What are the four core values of NGMA's Code of Ethics and Professional Conduct?

  1. Responsibility, Respect, Fairness, and Honesty
  2. Integrity, Loyalty, Discretion, and Compliance
  3. Transparency, Diligence, Accuracy, and Speed
  4. NGMA's Code has no named core values

2. What is the most serious stated consequence for a CGMS holder who violates a mandatory standard in NGMA's Code of Ethics?

  1. A written warning only, with no other consequence possible under the Code of Ethics
  2. Automatic referral for criminal prosecution by NGMA, plus a permanent ban from receiving federal grant funds
  3. Disciplinary procedures before the CGMS Committee, potentially including revocation of the credential
  4. A one-time fine of $175, the same as a retake fee, with the credential left in place

3. Does NGMA's Code of Ethics prohibit having any conflict of interest at all?

  1. Yes, any conflict of interest, disclosed or not, is an automatic violation
  2. No; the Code requires practitioners to disclose real or potential conflicts proactively and fully, so disclosure, not mere existence, is the key
  3. Conflicts of interest are not addressed by the Code at all
  4. Only financial conflicts are covered; personal relationships are exempt

4. Which section of 2 CFR 200 requires federal agencies to establish conflict-of-interest policies for federal awards generally, and requires recipients to disclose potential conflicts in writing?

  1. 200.318
  2. 200.112
  3. 200.334
  4. 200.501

5. How does 2 CFR 200.318 differ in scope from 2 CFR 200.112?

  1. They are identical in scope; 200.318 simply repeats 200.112
  2. 200.318 covers all award-level conflicts; 200.112 covers only procurement
  3. 200.112 applies only to subrecipients; 200.318 applies only to direct recipients
  4. 200.318 is narrow, covering procurement-specific conflicts through internal written standards; 200.112 is broader, covering any award-level conflict through proactive disclosure to the funder

6. Does having internal procurement standards of conduct that satisfy 200.318 also satisfy the separate requirement in 200.112?

  1. Yes, satisfying one automatically satisfies the other, because both rules address the same conflicts of interest in the same way
  2. No, they are separate; an organization needs both written procurement standards and a practice of disclosing award-level conflicts
  3. 200.112 does not apply to any organization that already has written 200.318 standards of conduct in place for procurement
  4. Only nonprofit organizations must comply with both rules; for-profit organizations comply with 200.318 alone, whatever they receive

7. What must an applicant, recipient, or subrecipient disclose under 2 CFR 200.113?

  1. Promptly and in writing, any credible evidence of federal criminal fraud, conflict of interest, bribery, or gratuity violations, or civil False Claims Act violations, tied to the award
  2. Only the organization's annual budget
  3. Only the names of board members
  4. 200.113 covers nothing beyond conflicts of interest

8. What can happen if an organization fails to make a required disclosure under 200.113, independent of the underlying violation itself?

  1. Nothing; only the underlying violation carries any consequence for the organization or its officers
  2. The organization automatically loses its NGMA membership and any CGMS credentials held by its staff
  3. Failure to disclose can result in remedies under 200.339, including suspension or debarment proceedings
  4. The organization owes only a fixed late-disclosure fee set by the Office of Management and Budget, with no other remedy

9. Which of NGMA's four Code of Ethics core values specifically concerns handling public and organizational resources entrusted to a practitioner?

  1. Honesty
  2. Respect
  3. Fairness
  4. Responsibility

10. A GCHS staff member becomes aware of another staff member's undisclosed financial interest in a vendor being considered for a contract. Under NGMA's Code, what is expected of them?

  1. To report it to appropriate management, since the Code requires reporting unethical or illegal conduct, not only avoiding it
  2. Nothing; the Code binds only the person who holds the conflict, not colleagues who happen to notice it later on their own time
  3. To handle it privately with the colleague and never mention it to management or to anyone else in the organization at all, ever
  4. To wait until the next CGMS renewal cycle and then raise it on the renewal application form that NGMA sends out

11. Which continuing-education requirement applies to renewing the CGMS credential?

  1. 20 CPE credits per year, earned from any provider at all, including general ethics courses that are not specific to grants in any way whatsoever
  2. No CPE credits, since renewal requires only the renewal fee and a signed acknowledgment of the Code of Ethics each cycle
  3. 30 CPE credits per cycle, earned only from NGMA itself, on any professional topic the holder chooses to study
  4. 60 CPE credits during the three-year cycle, from NASBA-listed sponsors, on grants, financial management, audit controls, or grant-making

12. How does this course group ethics and conflict-of-interest content among NGMA's four domains?

  1. Under Grant Guidance, as cross-cutting standards for the whole lifecycle, though conflicts can arise at any stage
  2. Fiscal Management only, since conflicts of interest are chiefly a question of how the money is spent by the recipient
  3. Program Management only, since conflicts arise mainly when running day-to-day program operations and client services
  4. None; NGMA's blueprint lists Ethics as a fifth, separate domain that this course does not cover

13. To whom must the written disclosure under 2 CFR 200.113 be made?

  1. Only NGMA, which reviews the matter and then decides whether the funder needs to be told
  2. Only the organization's own board, which decides whether the matter is reported outside the organization
  3. The federal agency, its Office of Inspector General, and the pass-through entity if there is one
  4. The Internal Revenue Service, which then forwards the disclosure to the awarding agency

14. What triggers the disclosure duty in 2 CFR 200.113 for an organization's federal award?

  1. Only a conviction or civil judgment, since suspicion alone is never enough to require a disclosure of any kind under the rule, whatever the evidence
  2. Any late report or small budget variance on the award, however minor and however quickly it is corrected by the recipient
  3. A written request from the awarding agency's program officer asking whether the organization has any problems to report
  4. Credible evidence of a federal criminal fraud, conflict of interest, bribery, or gratuity violation, or of a civil False Claims Act violation

Glossary

NGMA Code of Ethics and Professional Conduct
NGMA's binding ethical standard for CGMS holders, built on four core values: responsibility, respect, fairness, honesty.
2 CFR 200.112
The Uniform Guidance section requiring federal agencies to set conflict-of-interest policies and recipients to proactively disclose potential conflicts in writing.
2 CFR 200.113
The Uniform Guidance section requiring prompt written disclosure of credible evidence of federal criminal violations (fraud, conflict of interest, bribery, gratuity) or civil False Claims Act violations connected to an award.
CGMS Committee
The NGMA body that hears disciplinary matters for alleged violations of the Code of Ethics, with authority up to revoking the CGMS credential.
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