INITIATION AND APPROVAL
All educational activities to be administered by SIBCR must be approved by the VAPSHCS designated education committee. Please submit the Request for Review and Approval of Nonprofit Educational Activity form to SIBCR. SIBCR will review and approve before submitting for committee review. The recommendation for approval will be based on applicable VA Education Manual policies pertaining to conflict of interest and appropriateness to VA’s education and training missions as well as the definition of education and training established by the statute authorizing the VA-affiliated nonprofit corporations Title 38 §7362.
The activity may be a one-time event or an ongoing series. SIBCR will review the request, obtain additional information if necessary, clarify how it aligns with SIBCR and VA education mission and approve it before submitting to the committee.
An estimated budget for the program(s) must be included. The budget should have the most inclusive list of types of expenditures that may be made in support of the activity. In this way, once Committee approval is received there will be no need to file an amendment for approval of types of expenditures that were not included in the initial budget.
If funds to support the activity must be solicited from outside sources (including individuals, corporations, or other organizations), such solicitations may not be made by VA employees in their official position. SIBCR will make the request. A template request letter is available that may be appropriate for most programs. The request letter will be reviewed, signed by a designated SIBCR official and sent on SIBCR letterhead. If the template letter is not appropriate for a specific program or request, the requestor may provide details to SIBCR so that a letter tailored to the program can be sent.
For programs accredited either through VAPSHCS or the Employee Education System (EES), there are additional guidelines. If the sponsor requires a formal grant agreement, the agreement must meet the requirements of the accredited provider (VAPSHCS or EES).
Corporate sponsors will require formal agreements for educational grants, whether for CME or non-CME. Most corporate sponsors now have electronic application procedures. SIBCR will provide assistance in applying to corporate sponsors.
SIBCR works with both EES and VAPSHCS on accredited programs that have outside sponsors. Most corporate sponsors have agreed to follow certain guidelines for the support of educational programs that meet the standards required for accredited programs. These guidelines were published in 2002 and have been updated with an effective date of January 2009 as the “PhRMA (Pharmaceutical Research and Manufacturers of America) Code on Interactions with Healthcare Professionals.” Other relevant guidance can be found in the Federal Register dated December 3, 1997 (Volume 62, Number 232) page 64073-64100. The document is called “Final Guidance on Industry-Supported Scientific and Educational Activities.”
VAPSHCS staff should be aware of VA policies and guidelines relating to interaction with corporate sponsors.
Funds received in support of educational programs usually have explicit restrictions on their use.
Educational grants and activities will be tracked individually by SIBCR and will have a designated fund number and name. Monthly financial reports will be provided to the responsible member or designee.
The education committee may require an annual report on ongoing activities.
Funds received in support of an accredited program often have additional restrictions. If some funds remain after the initial approved activity, these remaining funds cannot be used in support of other similar accredited programs unless it is allowed for in the grant agreement.
As indicated above, educational grants are usually received with explicit instructions limiting expenditures to a particular program or activity. Therefore, funds remaining at the end of an activity may have to be returned to the sponsor or used only as allowed for education as in the original donation. If possible, SIBCR will include wording in all requests that will allow as broad usage as possible for educational activities.
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