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Enhancing the Health of Veterans through Research and Education

Accounting for Purchases & Expenditures

General Purchases and Expenditures

Purchases made through PVARF must be in support of VA research or education. All purchases must be in compliance with Internal Revenue Service (IRS) guidelines for non-profit corporations and applicable federal regulations. In cases where requests for payment do not have an obvious direct link to a research or educational project, a clear explanation of how the expense is related to the investigator's project must be provided, or there will be a delay in providing payment. Examples of such written justifications are:
 
A purchase order for a laptop computer- “This computer will be housed in the project office and will be used by the study's research assistant to maintain a log of enrolled patients, to enter study data into a database program, and to perform statistical analyses on study data using SPSS software."
 
A check request for purchase of a box of printer cartridges- “These are toner cartridges for the laser printer in the project office that prints the individualized questionnaire generated for each subject enrolled in the study."
 
A check request for postage expenses- “This payment covers postage fees for 300 mailed questionnaires at $0.78 per questionnaire."
 
Please contact the PVARF administrative office in advance if you have questions about the research justification of a planned purchase.Supplies, equipment, and needed services may be purchased on the open market. Any item over $10,000 must have at least three (3) bids unless sole source justification can be provided.

 
Purchases/expenses that are primarily of a personal nature cannot be paid through PVARF. Examples of such personal purchases/expenses include (but are not limited to): wedding or baby gifts, birthday parties, gifts or flowers to individuals, and contributions to other charities. Purchases for workplace refreshments, such as coffee, and soft drinks, will not be reimbursed.
 
Requests for disbursement of funds should be prepared on either a PVARF Check Request or Purchase Order.
 
Purchase Orders are used for vendors who will bill the PVARF at a later date. The numbered Purchase Order forms must be signed out from the PVARF administrative office and kept secured until used. Purchase Orders must have a full description of the product, quantity ordered, per unit price and extended price. If freight or transportation is billed as a separate item, freight bill must accompany invoice. The complete vendor address, and phone number must be included. Inform all vendors that all invoices must reference the purchase order. All items are to be ordered by the investigator. The Purchase Order should then immediately be sent to the PVARF administrative office. If a justification for how the order is related to the investigator's research is not included on the Purchase Order, an accompanying memo should provide this explicit justification. When the order is received, the packing slip or confirmation of delivery must be sent to the PVARF administrative office. “Blanket” Purchase Orders can also be set up with prior approval from the administrative office. “Blanket” Purchase Orders must be renewed every year.
 
Check Requestsare used to obtain reimbursement for items already purchased and paid for by an individual or when an immediate check is required. The Check Request form can be found on the PVARF website under “Forms”. Check Requests must be complete and have a description of goods purchased, the vendor address, individual's home address (if personal reimbursement), and an explanation of the research purpose of the expenditure. Invoices and other supporting documents must be attached. Reimbursements require original receipts or paid invoices supporting the payment. An authorized account signer must sign all check requests. It is essential that the research or educational purpose of each purchase be clearly stated in the section of the form that designates the justification for the purchase (see examples above). The justification can be explained in an accompanying memo if additional space is required. Check Requests that do not include a clear justification will be returned to the investigator before being processed.
 
Reimbursements will not be allowed for expenditures if there are insufficient funds in the account. Upon receipt in the PVARF administrative office, a Check Request will be reviewed for adequate fund balance, account restrictions and proper supporting documentation. Upon securing signatures of authorized foundation staff, the request will be processed within 7 business days.

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Recruitments and Relocations

PVARF funds may be used to support expenses associated with the recruitment of new investigators. Reimbursement may be requested for expenses incurred by an applicant and spouse for one interview trip, if the applicant is being recruited for a position that will enhance the research program of the Portland VAMC. Reimbursement for the applicant's spouse is acceptable since it provides an opportunity to survey the housing market and other local facilities. The payment of spousal expenses applies to only one interview trip. A maximum of five days of expenses will be reimbursed. Expenses will include coach air travel, meals, lodging, tips, telephone and car rentals. All expenses must be properly documented, and original receipts are required. The Travel Reimbursement form must be submitted for each traveler when requesting recruitment payments.

If equipment or supplies have been donated by another institution to aid an investigator in setting up a new research or education program at the Portland VAMC, then shipping these goods to the VAMC may be arranged using a PVARF Purchase Order or Check Request.

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Training of Employees and Investigators

Tuition payments or registration fees may be paid for courses that directly relate to the activities of an approved research or education project. Examples include courses on statistical analysis of research data or on programming computer databases. If the course is held at a distant site, the tuition was personally paid, and there were travel expenses, submit the reimbursement request using the travel reimbursement procedures described in Section 9 above. For tuition paid directly to the institution, submit the request using a Check Request form. As supporting documentation, include the original tuition statement and a written description of the relationship of the course to the approved research or education project.

This policy does not apply to general educational courses, such as coursework for attaining college degrees. Such expenses are the responsibility of the individual employee and are not reimbursable.

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Independent Contractors

At times, it may be necessary and prudent to utilize the services of an independent contractor. Independent contractors often provide skills, knowledge and professional expertise that are not readily available in the workplace. As a result, PVARF recognizes the need to enter into contracts and has established the following procedures that must be followed prior to entering into a contractual arrangement.

The IRS has specific guidelines regarding who may be considered an independent contractor. In order to determine whether a contractual arrangement falls within these guidelines, it is necessary for PVARF to receive an INDEPENDENT CONTRACTOR SELECTION form, an Independent Subcontract Agreement and a completed W9 at least five (5) working days prior to the commencement of the contract.

Please follow these steps:

      • Submit signed contract documents to the PVARF Executive Director five working days prior to commencement of the contract.

      • In the area designated “Scope of Services," you should indicate:

      • which project is involved,

      • what work the contractor will be doing,

      • how it affects the project, and

      • the deadline

      • PVARF will review the contract documents and authorize the contract. A copy of the approved contract will be returned to the investigator.

      • Upon completion of the contract, submit a Check Request for payment. The Check Request should refer to the assigned contract and should have an original invoice from the independent contractor attached.

If documents are not received in advance for PVARF review and authorization, payment may be refused.

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Consultants

Consultants are individuals who provide technical expertise needed for completing a research project or education program. While employees provide ongoing work on a project, consultants normally provide services on an interim or short-term basis. Criteria useful in determining whether to use a consultant rather than an employee to meet project needs include:

      • If the specialized skill, knowledge and resources to be provided by the consultant are not available within the Portland VAMC.

      • If the work cannot be done in a reasonable time with the investigator’s existing work force.

      • If an independent and impartial evaluation of a situation is required by a consultant with recognized professional expertise and stature in a field.

      • If it will be less expensive to perform the work with a consultant rather than with an employee.

The qualifications of an individual to serve as a consultant can be established by possession of an advanced scientific degree or documentation of prior work. This information needs to be documented via curriculum vitae or resume.

Refer to Independent Contractors Procedures when hiring a consultant. Include the consultant’s curriculum vitae or resume with the request. The payments are subject to IRS rules for reporting non-wage income.

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Business Meeting Expenses

The PVARF, as an independent non-profit research corporation, must be compliant with tax law and VA oversight policies and is constrained in the type of business meeting expenses that can be reimbursed. The following situations are acceptable for business meeting expense reimbursements:

      • Meeting expenses with applicants for advertised scientific positions at the Portland VAMC (limit $75 per person).

      • Meeting expenses with out-of-town visiting scientists to discuss research or education plans (limit $75 per person).

      • Minor refreshments for research planning or educational activities such as lectures or workshops. The dollar limit for the total cost of refreshments cannot exceed $7.00 per person.

      • Reimbursements for meals provided to employees when they are asked to work extra hours outside their normal tour of duty, such as working in the evening to finish urgent projects related to the approved research (limit $15 per person).

The number of meal attendees should be reasonable. For meetings with job applicants, attendees may include non-scientists who can provide important information about relocation to the Portland area. No alcohol will be reimbursed.

Any deviation from these guidelines requires prior approval from the PVARF Executive Director.

Reimbursement Procedure:

Complete and submit Business Meeting Expense Reimbursement form or submit an invoice from vendor (include purchase order number) with the following documentation

Requests for payments or reimbursements for business meeting expenses must have the following documentation:

        • Name and title of person(s) who attended

        • Purpose of meeting

        • Nature of discussions held at meeting

        • Date and duration of meeting

        • Place of meeting

        • Original receipts for all expenses for which reimbursement is requested.

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Housing Conferences and Expenses

Tuition and fee payments made by attendees may be deposited in PVARF accounts only when the following conditions are met:

The Portland VAMC is prominently identified as sponsor or co-sponsor of the conference.

      • The conference content includes either:

      • An education program previously approved by the VAMC Education Committee; or

      • Presentations of research findings and/or information about the application of research results to clinical practice, when the research results come from a project previously approved the VAMC R&D Committee.

Expenses for the conference may be reimbursed from the research or education account if appropriate original receipts or invoices are provided, along with an explanation of the relationship of each expense to the conference. Acceptable expenses include honorariums (not to exceed $750), rental of conference space, refreshments, and travel expenses. Requests for payment of expenses should be submitted on a Business Meeting Reimbursement Request form.

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License Fees

National VA policy prohibits use of PVARF funds to pay for professional licenses or fees for VA employees. License fees for employees who work exclusively for PVARF may be paid if such licensure is directly related to the activities of the approved project. Payments may be made for registration fees of continuing education or professional organization activities as long as the attendance is for a purpose directly related to the approved project.

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Subscription and Publications

PVARF is committed to fostering access to scientific information that allows VA and PVARF personnel to remain current in their fields and apprised of cutting edge developments for the benefit of VA research and education. This involves subscribing to journals as well as facilitating VA investigators’ full participation in scientific and educational organizations and conferences.

Personnel may request payment or reimbursement for the cost of subscriptions for research related publications and approved educational materials that provide a clear benefit for VA research or education. Subscription requests must indicate a VAMC business - not residential - address for delivery. 

If a membership is necessary to obtain the publication, or if it is cost-effective to pay for a membership in order to obtain the publication and/or to attend meetings at a significantly reduced rate, PVARF may pay the dues. However, the organization must have a research orientation as demonstrated by publication of research journal(s) and/or must hold scientific meetings of benefit to VA research. Prior approval of the Education Committee is required for educational subscriptions and/or memberships that have no research relevance.

Professional membership fees may be paid in a situation in which an employee of the Portland VAMC or the PVARF is required to join the organization to serve as the official representative of the VAMC or the PVARF to that organization.

Provide information about the journal and the dues on the Subscription and Publications form and submit to the PVARF office for payment .

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Oregon Health & Sciences Research Stores

Some research programs may require periodic purchases using Oregon Health & Sciences’ University (OHSU) research store. To accommodate these needs, OHSU permits creation of an account against which research purchases are made.

The purpose of a research store account is to facilitate purchases that otherwise cannot be made through the PVARF. Investigators who desire to set up an OHSU research store account should contact the PVARF Accounts Payable Department.

OHSU submits an invoice to PVARF on a monthly basis for charges to each account. After PVARF approval of the purchases, the invoiced amount will be deducted from the investigator’s PVARF account after receipt of each invoice, and a check will be issued to OHSU for that amount.

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Payments to Research Subjects

Investigators requesting payment to a subject for their participation in research activities must submit the name, and mailing address for each subject. If a research subject receives in total $600 or more in a calendar year, the PVARF must submit information on the payments to the IRS.

Payments to research subjects include honoraria for participating in studies and direct payments for expenses of study participation, such as travel reimbursements. A request for payment to research subjects is submitted on a Check Request form.

Documentation of the research project approval by the R&D Committee and the Institutional Review Board (IRB) for Human Subjects is also required before issuing payment to a research subject. Description and amount of payments to subjects are submitted to the IRB as part of the initial application process.

FAQ Clincard Reference Guide (.pdf)

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Petty Cash Funds

Petty cash funds may be established only when the investigator has established a compelling need. A request for a petty cash fund should be submitted via a Check Request accompanied by a written memorandum to the PVARF Executive Director. The memorandum should include an explicit description of how the funds will be used, why payments cannot be made through issuance of checks and a copy of the IRB Informed consent form outlining the proposed subject reimbursement. If the request is approved, petty cash funds may be used only for the purpose described in the memorandum of request. No more than $300 may be kept in petty cash funds. If additional funds are required following an initial approved request (i.e., to replenish the petty cash fund), the investigator must submit a new Check Request form along with a complete report of the use of the existing funds and original disbursement receipts. Each report must include:

    • PVARF Account Number and title of research project.

    • Name of each individual who received cash.

    • Original signature of each individual.

    • Date cash was received.

    • Amount of cash received.

    • Purpose of payment.

Petty cash funds will be issued via a check made payable to the investigator, who will have sole responsibility for administration and security of the funds. All cash is to be stored in a locked box or otherwise secure location.

By January 31 of the following year, a complete report on the status of the petty cash funds must be submitted to the PVARF administrative office. The report must include a description of how all funds were spent and the amount of remaining unspent funds. If this report is not submitted or is incomplete, the petty cash funds will be reported to the IRS as personal income to the investigator.

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Equipment Purchases

Equipment includes items that will be used in an ongoing basis in a laboratory or office, such as microscopes, machines, computer hardware, and some types of computer software. It does not include consumable supplies. If the relationship of the equipment to a research or education project is not readily apparent, the investigator should request prior approval from the PVARF administrative office.
 
The PVARF administrative office will maintain an inventory list for equipment purchases made from each account. For each equipment purchase greater than $5,000 and computer equipment valued at more than $1,500, a label will be affixed with an identifying number.. An inventory list will be maintained that records the asset features, serial numbers of each item and the location of the asset. . A physical inventory of these assets will be made once per year.
 
All equipment purchases should be made through checks issued to suppliers (rather than personal reimbursements). A Purchase Order and Asset Tracking form (rather than Check Requests) must be completed for equipment valued in excess of $1,500.
 
Prior authorization is needed for computer equipment and computer software that will be connected to or installed on the VA Network independent of the cost. Please fill out (Computer Hardware/Software Purchase Authorization Form) and submit to the PVARF Executive Director. The VA IT department will then review the information. Upon approval, the equipment or software can then be ordered. When the order is received, the VA IT department will provide installation services.
 
Equipment Transfer- The PVARF Board of Directors must approve transfer or sale of any and all capital equipment. Priority for transfer or sale is as follows: Principal investigators who purchased the equipment, other PVARF investigators, and other requestors.
 
Transfer of equipment may only be made to another not-for-profit institution. Correspondence to the receiving institution as well as their acknowledgement and acceptance must be retained for documentation. The party requesting the transfer of equipment (usually a PI) is responsible for the shipping of the equipment. The PVARF Executive Director and President must approve the sale of any equipment. Proceeds from any sales will be deposited to the PVARF corporate operating fund.
 
The PVARF may donate equipment to the VA, which will then maintain and inventory the equipment. Correspondence regarding the donation as well as the VA’s acknowledgement and acceptance must be retained for documentation.

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PVARF Support for Meetings and Conferences

Meetings, conferences, workshops, seminars, symposia, and other similar meetings are accepted features of conducting research and education. Additionally, certain events, such as retreats and board meetings as well as fundraising and public relations, are necessary for the conduct of business. Incidental to the business purpose of such meetings, it may be appropriate to serve meals or refreshments. What follows are the steps for to be followed for having such events approved and reimbursed. Note these steps are not necessary for reimbursement for refreshments for non-recurring meetings where a cost of less than $5 per person is anticipated (see Business Meeting Expenses section of these Policies and Procedures).

Various regulations, the federal ethics standards and the statute that authorizes the PVARF influence whether expenditures related to such events are appropriate for PVARF support. Consequently, in order to be considered for PVARF support Board of Directors of the PVARF has established the following policy.

  1. All requests must contain the documentation described in section 2 below and be approved in advance by the President of the PVARF (or the Chair of the Board of Directors if the President is not available) in order to be eligible for reimbursement.
  2. In order to be eligible for PVARF support, a meeting must have a documented research, education or PVARF business purpose. PVARF will not support purely social activities.
    • For a research related meeting: A request for PVARF support must include an explicit statement about the research rationale for the event; that is, its research related purpose and how it will further VA research. Accompanying documentation should include the program, agenda or topic of discussion, proposed budget and a roster of invited attendees. When appropriate, the request should tie the meeting to an approved research project.
    • For an educational program not related to research: The education activity itself must first be approved by the VAMC Education Division via their institutional approval process.
    • For other PVARF business events: A request must include an explicit statement of how the meeting will further the PVARF’s ability to facilitate research and education. Appropriate events include, but are not limited to retreats and board meetings, annual membership and investigator meetings as well as fundraising and events for public relations. Documentation should include the purpose, agenda, proposed budget, program or topic of discussion and a roster of invited attendees.
  3. The types and characteristics of meetings that may be eligible for PVARF support will vary. Factors to be considered when evaluating a request to support a meeting will include:
    • The topic presented by the speaker(s) and how it relates to research or education.
    • Whether there is a non-PVAHCS speaker and/or non-PVAHCS personnel are among the expected attendees.
    • The frequency of similar meetings that may involve the same personnel. Irregularly scheduled meetings and/or those that occur no more than monthly may be eligible for support; weekly meetings will receive closer scrutiny.
    • Whether support is requested for routine PVAHCS staff, committee or department meetings. Generally, PVARF will not support meal expenses for such meetings.
    • Whether the meeting involves at least one individual who is being recruited to conduct research or education at the PVAHCS.
    • Whether the meeting lasts more than two hours or extends through a normal mealtime.
  4. PVARF will provide direct payment or reimbursement for reasonable meeting costs based on the approved budget and submission of original receipts.

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