To answer this question, ask the PI. Unless you’re in a dean’s office and have been delegated COI responsibilities for the school by the dean, you won’t be able to access a PI’s COI disclosure. Therefore, ask the PI to confirm his/her COI status since he/she is in the best position to know what he/she disclosed, whether these activities relate to this proposal, and whether the disclosure is up to date.
In most cases no; the proposal may generally be routed and submitted as normal. At the award stage, however, if it is determined that the disclosed activities do relate to this particular proposal, Policy 216 requires that a COI management plan needs to be put in place before federal funds are expended.