EPA Renews Contractor Conflict-of-Interest Paperwork Without Major Changes
Published Date: 5/23/2025
Notice
Summary
The EPA wants to keep collecting info from contractors to spot conflicts of interest and is asking for public feedback before renewing this process. This affects contractors working with the EPA and helps keep things fair and transparent. Comments are due by July 22, 2025, and there’s no new cost or big changes—just a smooth renewal of the current rules.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
Mandatory COI disclosures for contractors
If you are an EPA contractor identified with a potential conflict, you must disclose any actual or potential conflicts of interest involving your employees, corporate affiliations, and business relationships. This disclosure obligation is mandatory under Federal Acquisition Regulation (FAR) subpart 9.5 and applies to all contractors seeking contract award who are identified with a potential COI.
Renewal continues existing burden and costs
EPA proposes to renew the existing Contractor Conflicts of Interest information collection with no change in overall estimated respondent burden. The ICR lists 61 respondents, a total estimated burden of 68,933 hours per year, and a total estimated cost of $5,029,174.34 per year; the number of required COI plans increased from 56 to 61.
Required business-relationship database and reporting
Contractors must maintain a database of their business relationships and report information to EPA either annually or when work is ordered under an Agency contract. The reporting frequency varies by contract, but the requirement to keep and submit this information is part of the renewed information collection.
Prior approval for certain future-contract restrictions
Under some EPA contracts, contractors must request written approval from the contracting officer before entering a proposed contract that is subject to EPA's Limitation of Future Contracting Clause (see CFR 48 1552.209-74). This is an additional approval step for affected contracts.
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