Reporting Improper Activity

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.