These activities are approved under the Nonprofit Corporation Authorizing Statute, Public Law 106-117, codified as §38 U.S.C. 7361-7366. More information on this statutory authority can be found on the National Association of Veterans’ Research and Education Foundations’ website.
SIBCR will also need to review and sign any formal agreements required for education activities. For CME activities, these agreements must also meet the guidelines of the accredited provider (VAPSHCS or VA Employee Education System [EES]).
Please be aware that there are a number of important regulations and guidelines for interactions between VA personnel and industry representatives. For programs accredited through VAPSHCS or EES there may be additional guidelines.
Prior to expending project funds, all education activities must be reviewed and approved by the VAPSHCS designated review committee using the Request for Review and Approval of Education Activity form. The request should include a detailed budget and an explanation of the activity’s relevance to VAPSHCS’s mission.
For more information on SIBCR’s education policies, refer to the SIBCR Policy Manual on Education.
VA Policy Resources
There are significant legal regulations and strict guidelines governing interactions between VA personnel and representatives from the pharmaceutical and medical device industries. VA personnel are responsible for ensuring that all of their interactions with industry representatives are appropriate and allowed by VA regulations. General guidance on substantive government ethics matters such as gifts, conflicting financial interests, impartiality, misuse of position, outside activities and financial disclosures can be found on the Office of Government Ethics website, www.usoge.gov. Specific questions about VA or VAPSHCS policy should be directed to the VAPSHCS Regional Counsel.
Honoraria for Speakers
SIBCR may pay speakers' honoraria or travel expenses for participation in educational activities if those expenses are included in an approved budget. Honoraria are paid out of a member’s approved education account at SIBCR.
If the speaker is a non-resident alien, SIBCR must be advised in advance to determine if an honorarium can be provided.
To pay a speaker or provide travel reimbursement, complete a Check Request form and email it to SIBCR with the VA-approved education activity referenced, the event date, the speaker’s contact information and mailing address, social security or tax identification number and a basic resume (1-2 pages) to establish their credentials. Accounting will request approval from the PI or fund manager before issuing payment.
If the speaker is a VA employee, please also submit a decision tree to see if an honorarium should be paid.
Accounts Payable will issue a check within 10 business days of receiving a complete Check Request form. Checks will be mailed directly to the speaker unless specified otherwise.
SIBCR must file IRS Form 1099 for speaker fees and honoraria payments totaling $600 or more annually and must provide W-9s.
For more detailed information about honoraria please refer to the SIBCR Policy Manual.
The payment of travel expenses associated with this category follows the SIBCR policy for general travel by members, detailed here.
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