1. Purpose
Appalachian Insights and Analytics, LLC ('AIA') is committed to maintaining the highest standards of objectivity, integrity, and ethical conduct in all research, evaluation, and consulting activities. This Conflict of Interest (COI) Policy establishes procedures for identifying, disclosing, and managing actual or potential conflicts that could compromise the credibility or objectivity of AIA's work.
Federal regulations including 2 CFR Part 200 (Uniform Guidance) and agency-specific requirements mandate that organizations receiving federal funds have written conflict of interest policies in place.
2. Definition of Conflict of Interest
A conflict of interest exists when an individual's personal, financial, professional, or organizational interests could improperly influence their professional judgment or actions. Conflicts may be:
- Financial — personal financial interest in a client, funder, or entity being evaluated
- Professional — prior or current employment or leadership role with a client or evaluated entity
- Personal — family or close personal relationships with key stakeholders in a project
- Organizational — AIA receiving funding from an entity it is simultaneously evaluating
3. Disclosure Requirements
- All AIA personnel must disclose actual or potential conflicts of interest before beginning work on any project
- Disclosures must be made in writing to the other principal
- Disclosures must be updated promptly if a new conflict arises during the course of a project
- Federal grants and contracts require disclosure to the sponsoring agency — AIA will comply with all applicable federal COI reporting requirements
3a. Standing Disclosure — Academic Employment
Both AIA principals hold full-time faculty appointments at East Tennessee State University (ETSU), a Tennessee public institution. This standing employment relationship creates ongoing disclosure obligations that AIA manages as follows:
- Both principals have completed required outside employment and conflict-of-interest disclosures with ETSU in accordance with university policy.
- AIA does not contract with ETSU, other Tennessee state agencies, or entities where either principal's university role would create a direct conflict with AIA's independent consulting work.
- Engagement selection is reviewed against this constraint before any proposal or scope of work is initiated.
- If a prospective engagement raises questions about the principals' institutional roles, AIA will decline the work or seek formal written guidance from ETSU's conflict-of-interest office before proceeding.
- This standing disclosure is reviewed and reaffirmed annually alongside this policy.
4. Review and Management
Upon receipt of a COI disclosure, the non-conflicted principal will review the nature and extent of the conflict within five business days and determine whether the conflict can be managed, waived, or requires recusal. Management measures may include: recusal from specific project activities, enhanced oversight, or independent review of findings. Where a conflict cannot be adequately managed, AIA will decline or withdraw from the project.
5. Evaluator Independence
AIA is committed to evaluator independence. AIA will not:
- Conduct outcome evaluations of programs where AIA also provides technical assistance or program delivery
- Accept funding arrangements that tie payment to specific evaluation findings
- Alter evaluation findings, methods, or conclusions based on funder or client preference
6. Annual Affirmation
All AIA principals and personnel will sign an annual COI affirmation statement confirming they have read this policy, disclosed all known conflicts, and agree to comply with these requirements.