1065 Conflict of Interest | Administration 5600 Manual
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Georgia Division of Aging Services |
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Chapter: |
1025 State Agency on Aging Operations |
Effective Date: |
10/01/2025 |
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Section Title: |
Conflict of Interest |
Reviewed or Updated in: |
MT 2026-04 |
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Section Number: |
1065 |
Previous Update: |
MT 2026-01 |
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Summary Statement
DAS staff, DAS contractors, AAA staff, and AAA Contractors must continually ensure no conflicts of interest exist. on the part of DAS, employees, and agents of the State who have responsibilities relating to Title III programs, including AAAs, governing boards, advisory councils, staff, and volunteers.
Basic Considerations
Anyone who works on programs funded by or receiving funding from the OAA must establish mechanisms to identify, avoid, remove, and remedy conflicts of interest in a Title III program at organizational and individual levels, including:
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Ensuring that DAS employees and agents administering Title III programs do not have a financial interest in a Title III program.
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Removing and remedying actual, perceived, or potential conflicts that arise due to an employee or agent’s financial interest in a Title III program.
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Establishing robust monitoring and oversight, including periodic reviews, to identify conflicts of interest in a Title III program.
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Ensuring that no individual or member of the immediate family of an individual involved in the administration or provision of a Title III program has a conflict of interest.
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Requiring that other agencies that operate a Title III program have policies in place to prohibit the employment or appointment of Title III program decision-makers, staff, or volunteers with a conflict that cannot be adequately removed or remedied.
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Requiring that a Title III program takes reasonable steps to suspend or remove Title III program responsibilities of an individual who has a conflict of interest, or who has an immediate family member with a conflict of interest, which cannot be adequately removed or remedied.
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Ensuring that no organization which provides a Title III service is subject to a conflict of interest.
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Prohibiting the officers, employees, or agents of the Title III program from soliciting or accepting gratuities, favors, or anything of monetary value from grantees, contractors, and/or subrecipients, except where policies and procedures allow for situations where the financial interest is not substantial, or the gift is an unsolicited item of nominal value.
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Establishing the actions DAS shall require a Title III program to take to remedy or remove such conflicts, as well as disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the Title III program; and
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Documenting conflict of interest mitigation strategies, as necessary and appropriate, when DAS or Title III program operates an Adult Protective Services or guardianship program.
Types of Conflicts
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One or more conflicts between competing duties;
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One or more conflicts between competing duties, programs, and/or services; and
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Other conflicts of interest identified in guidance issued by the ASA and/or by DAS policies.
Procedure
DAS Staff:
Upon hire and annually thereafter, all DAS staff who work on or oversee the work on the OAA programs shall complete the Georgia DAS Older Americans Act (OAA) Title III Program Conflict of Interest Training. This training will provide DAS staff with an understanding of Title III Program conflicts of interest (both individual and organizational), opportunities to disclose potential and real conflicts of interest, and guidance for remedying or removing conflicts of interest.
The trainings and responses will be documented in the Georgia DASDHS Learning Management System, and any conflicts of interest disclosed through the training will trigger a further review by DAS Management and Legal Team to evaluate the potential conflict and remedy the situation. DAS employees must complete the training and assessment at least annually.
Volunteers and Interns:
Georgia DAS staff shall also be responsible for assessing and reviewing actual, potential, or perceived conflicts of interest with DAS volunteers and interns. Upon completion of the Volunteer Application, program managers will be required to conduct a virtual interview with volunteer candidates in which conflicts of interest are discussed and reviewed. Program managers shall confer with their supervisors if a conflict of interest is identified for a volunteer candidate. For additional information on volunteer screening processes, refer to Volunteer Management Services, Manual 5600, Chapter 1075, Section 1084.
Monitoring AAAs:
Georgia DAS shall review a random sample of AAA Conflict of Interest policies and procedures, Organizational Conflict of Interest Assurance forms, and Individual Conflict of Interest Assurance forms to ensure the AAAs have established policies and procedures for identifying, remedying, and removing conflicts of interest and all AAA staff and individuals who have responsibilities relating to Title III programs adhere to these policies.
Additionally, Georgia DAS shall review a random sample of the AAAs monitoring of their board, advisory council, volunteers, and contractors to ensure they have monitored each of them for the same requirements. Review may also occur situationally or as needed.
References
Volunteer Management Services, Manual 5600, Chapter 1075, Section 1084.