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Enhancing the Health of Veterans through Research and Education

General Policies

Source & Management of Funds

PVARF may accept funds in the form of grants, agreements or gifts from such sources as: Federal (non-VA) agencies or private nonprofit agencies; commercial organizations involved in the development of new medical materials and devices or in support of medical research and/or education; personal contributions; or from organizations or individuals to defray the costs of scientific meetings, teaching or other legitimate educational functions.

Funds donated in support of an educational activity may be expended only after the Education and Training Committee or its designated committee as detailed in PVAMC Education policy has approved the activity. PVARF may support education for VA employees and VA patients or their families. Funds received for specific projects or activities will not be commingled with other donations. Separate accounts for each research project and education activity will be established in accordance with  the appropriate OMB circular. At the end of a study, Investigators will follow close out procedures.

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Transfer of Funds and/or Equipment

Transfer of Active Projects to another Institution

If the PI is moving to an academic nonprofit or other nonprofit research institution to continue an ongoing VA-approved research project, funds received by PVARF attributable to that project may be transferred to that institution at the discretion of the Board of Directors. If such funds retain donor-imposed restrictions, PVARF may be required to return remaining funds to the donor. Equipment purchases with PVARF attributable to that project may also be transferred at the discretion of the Board of Directors. Sponsor notification and approval are usually required. The destination institution must request the transfer and agree in writing to accept responsibility for the project, funds and equipment.

Transfer of Active Projects within Institution

If a PI resigns before a project is completed, the member may request that another PVARF PI assume responsibility for research or education activities with PVARF funding. This request requires either R&D Committee approval or EC approval, the approval of the PVARF Board of Directors and if necessary, sponsor approval. The PI should submit a written request to the Board of Directors for review. This request should be sent through the Executive Director.

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Reporting Improper Activity

The Portland VA Research Foundation (PVARF) requires directors, officers, investigators and employees to observe high standards of business and personal ethics in the conduct of their duties. As employees and representatives of the PVARF, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. PVARF will not condone any activity that is illegal or improper, whether by an employee, investigator, board member, or administrative staff.

These guidelines are intended to encourage and enable employees and others to raise serious concerns within the PVARF prior to seeking resolution outside the PVARF.

Conduct that may fall into the category of improper activity includes fraud, theft, safety violations, misuse of funds intended for research or education, harassment, or retaliation.

Anyone filing a complaint concerning an improper activity must be acting in good faith and have reasonable grounds for believing the information disclosed indicates improper activity. No director, officer or employee who in good faith reports improper activity shall suffer harassment, retaliation or adverse employment consequences. An employee who retaliates against someone who has reported improper activity is subject to discipline up to and including termination of employment.

Guidelines for Investigating Improper Activity

PVARF has official policies about providing protection and due process for individuals who make reports of improper activities (known as the Whistleblower Protection Policy). This policy document is included in the PVARF Employee Manual. The following procedures are intended to define the process for investigating reports of improper activities.

  • All allegations of scientific misconduct should be reported to the ACOS for Research and Development at the Portland VA Medical Center. The procedure for reporting allegations regarding scientific misconduct should be filed in accordance with the procedure described in the Portland VA Research and Development Department “Policy on Research Integrity".
  • Allegations of financial misconduct or significant conflicts of interest should be reported to the management of PVARF. The PVARF Board of Directors will oversee the investigation of such allegations.
  • Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously to the Executive Director. If the concern involves the Executive Director, report the improper activity to the President (contact information for the President is listed in the front of the PVARF Employee Manual).
  • Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
  • A preliminary evaluation of the alleged improper activity shall be conducted by the Chairman of the Board of Directors and the President to determine whether there are sufficient grounds to warrant an investigation. It is expected that preliminary evaluations will normally be completed within thirty (30) working days of the receipt of a report of alleged improper activity.
  • All individuals involved in investigation of the complaint will keep the identity of individual(s) who allege improper activity and who cooperate in an investigation confidential to the maximum extent possible consistent with fact-finding and will make every reasonable effort to protect the privacy of all parties.
  • If there are sufficient grounds to warrant an investigation, the investigation shall be conducted by a committee determined by the Executive Committee of the Board of Directors. This special committee shall include at least three Board members, at least two of which shall be elected members other than the President.
  • If the alleged improper activity involves a member of the Board of Directors, the activity will be referred to VHA for further investigation.
  • If the Board Chairman and President do not recommend formation of an investigative committee, the individual who brought the complaint may appeal this decision to the full Board at the next regular or specially-scheduled meeting of the Board of Directors.
  • A confidential written report summarizing the results of the investigation shall be prepared by the investigative committee. The report shall be addressed to the Board of Directors and shall contain findings and recommendations resulting from the investigation. The investigative committee shall submit this confidential report within sixty days. The Board of Directors may then determine what further action, if any, is warranted.

Any employee who feels that adverse action has been taken toward him/her due to a report of improper activity should report this concern, as soon as possible, in writing to the Executive Director or the President

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Residual Research and Education (RE) Funds Policy

Funds received for active research and education (RE) projects are restricted for the duration of the study and will be used for the support of that RE project. After the completion of a RE project, all remaining funds (residual funds), if any, will be transferred to a General Purpose(GP) RE account if the donor has not specified any further restrictions on the use of these funds.

Funds from a GP RE account may be used to support ongoing RE projects and RE-related activities at the Portland VA Medical Center. All expenditures must be consistent with policies and procedures established by the Board of Directors and are subject to approval by the Executive Director.

In the event an investigator with a General Purpose RE account administered by PVARF terminates his or her appointment (staff, WOC, fee, or contract) at the Portland VA Medical Center, funds will be forfeited unless a written request is sent to the Board of Directors for the approval to transfer the remaining funds in accordance with PVARF’s Transfer of Funds and Equipment policy. Funds will be considered for transfer to another qualified 501 (c) (3) organization only when such funds are associated with an ongoing project. This request must be received within 30 days following termination of appointment.

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Conflict of Interest

This policy is intended to supplement, but not replace, federal and state laws governing conflicts of interest applicable to nonprofit corporations. It applies to board members and staff with significant decision-making authority. Persons covered under this policy, as well as their relatives and associates, are hereinafter referred to as "interested parties."

A conflict of interest may exist when the interests or concerns of an interested party may be seen as competing with the interests or concerns of PVARF. There are a variety of situations that raise conflict of interest concerns including, but not limited to, the following:

A. Financial Interests - A conflict may exist where an interested party directly or indirectly benefits or profits as a result of a decision, policy or transaction made by PVARF. Examples include situations where:

  • PVARF contracts to purchase or lease goods, services, or properties from an interested party.
  • PVARF offers employment to an interested party, other than a person who is already employed by PVARF.
  • An interested party is provided with a gift, gratuity, or favor of a substantial nature from a person or entity that does business or seeks to do business with PVARF.
  • An interested party is gratuitously provided use of the facilities, property, or services of PVARF.
  • PVARF adopts a policy that financially benefits an interested party.

A financial interest is not necessarily a conflict of interest. A financial conflict of interest exists only when the board decides a person with a financial interest has a conflict of interest.

B. Other Interests - A conflict also may exist where an interested party obtains a non- financial benefit or advantage that he/she would not have obtained absent his/her relationship with PVARF. Examples include where:

  • An interested party seeks to obtain preferential treatment by PVARF or recognition for himself/herself or another interested party.
  • An interested party seeks to make use of confidential information obtained from PVARF for his/her own benefit (not necessarily financial) or for the benefit of another interested party.
  • An interested party seeks to take advantage of an opportunity or enables another interested person or other organization to take advantage of an opportunity that he/she has reason to believe would be of interest to PVARF.
  • PVARF adopts a policy that provides a significant nonfinancial benefit to an interested party.

A conflict of interest exists only when the Board of Directors decides there is a conflict.

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