Meetings, conferences, workshops, seminars, grand rounds, town halls, symposia and other similar meetings are all 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. Meals and refreshments may be considered for support only if they are incidental to the business purpose of such meetings.
POLICY FOR SUPPORT
Various laws and regulations, the federal ethics standards and the statute that authorizes SIBCR control the extent to which expenditures related to such events are appropriate for SIBCR support. Consequently, in order for such costs to be considered for direct payment or reimbursement by SIBCR, the following policy has been established.
- In order to be eligible for SIBCR support, a meeting must have a documented research, education, or SIBCR business purpose. SIBCR will not support "entertainment" expenses such as social activities, parties, ceremonial occasions, or those that provide amusement.
- For a research-related meeting: A request for SIBCR 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 and a roster of 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 VAPSHCS designated review committee. Documentation should include an explicit statement of the purpose and how the program will further the VA's education and training mission. Please complete the Education Approval Request form to submit through SIBCR for committee review.
- For other SIBCR business events: A request must include an explicit statement of how the meeting will further SIBCR's ability to facilitate research and education. Appropriate events include, but are not limited to, retreats, board meetings, annual membership meetings and investigator meetings, as well as fundraising and public relations events. Documentation should include the purpose, agenda, program, or topic of discussion and a roster of attendees.
- Factors that SIBCR will consider when evaluating a meeting for support include:
- Whether at least one speaker makes a research presentation or presents educational instruction.
- Whether there is a non-VA or non-VAPSHCS speaker, or non-VA or non-VAPSHCS personnel are among the expected attendees.
- The frequency of similar meetings that may involve the same personnel. Irregularly scheduled meetings, that is, meetings that are not recurring on a regular schedule, may be eligible for support.
- Whether the meeting involves at least one individual who is being recruited to conduct research or education at the VAPSHCS.
- Whether the meeting lasts more than two hours or extends through a normal mealtime.
- Regardless of the type of meeting, the documentation required above is a prerequisite for SIBCR support.
- Requests for SIBCR support will be reviewed and approved by the individual designated by the Board, generally the Executive Director or the Executive Director's designee. SIBCR will provide direct payment for reasonable meeting costs, or reimbursement based on submission of original receipts. In the event of disagreement, the request may be referred to a designated member of the Board of Directors or to the full Board as appropriate.
- SIBCR encourages meeting organizers to obtain pre-approval of SIBCR support for meetings. Such approval is not mandatory, but events lacking pre-approval may be denied support or may receive only partial support. For meetings of significant size or cost, prior discussion and authorization by SIBCR management is highly recommended.
- Only actual, reasonable costs will qualify for reimbursement.
- SIBCR does not pay for alcoholic beverages.
- Refreshments may be paid as part of a non-routine research or education meeting if incidental to the meeting. SIBCR will not pay for refreshments for regular staff meetings.
- Lunch or dinner expenses for a meeting with only VA staff cannot be reimbursed.
- Please note that luncheon or dinner meetings with invited speakers or research collaborators may be an appropriate expense in some cases for reimbursement through SIBCR. Such an event should be reviewed prior to the event to make sure it is eligible for reimbursement.
When members are providing honoraria, speaker fees, or travel reimbursement to invited guest lecturers, the following apply:
- Check Request form must include the Social Security or Tax Identification Number and the address of the guest lecturer.
- Sufficient credentials should be provided to show the expertise of the speaker as the basis for providing an honorarium. For example, part or all of the speaker's CV.
- If the speaker is a VA employee, the decision tree in the following section must be filled out and provided to SIBCR before an honorarium can be paid.
- If the invited speaker is a non-resident alien, SIBCR must be advised in advance in order to determine if an honorarium can be provided.
- SIBCR must file IRS 1099 Misc forms for speaker fees and honoraria payments totaling $600 or more in a single tax year.
- The payment of travel expenses associated with this category follows the same policy as for general travel by members (see Chapter 10 of this Policy Manual for more information on travel).
HONORARIA AND SPEAKER FEES
VA-affiliated nonprofits such as SIBCR are often asked to pay honoraria and speaker fees or to accept donations of honoraria. To assist the nonprofits to work through the sometimes complex issues related to compensation for outside speaking, writing and teaching, NAVREF offers the decision tree in determining when honoraria and speaker fees may be paid to VA employees without putting the employee at risk of violating federal ethics regulations.