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NAVREF UPDATES – June 12, 2008
TO: NAVREF Members
FROM: Barbara West, Executive Director
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Should NPCs Add the VA Central IRB to their FWAs?
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May NPCs Continue to Accept IPA Reimbursements from VA
Medical Centers?
- Are You Ready for the New IRS Form 990?
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NAVREF Session During the 2008 VHA Senior Management
Conference
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NAVREF Annual Conference Extended to Accommodate Workshop
on Indirect Cost Negotiations
According to Lynn Cates, MD, director of the ORD Program for Research
Integrity Development & Education (PRIDE), the answer to this question
is that it is not necessary at this time. The process can be
completed within a couple of weeks, so an NPC can add the VA Central IRB
to its FWA if and when the need arises.
Background:
The VA Office of Research and Development (ORD) has established the "VA
Central Institutional Review Board (IRB)" to 1) enhance human subject
protections in VA-funded multi-site human research projects; and 2)
enhance the efficiency of IRB reviews. At this time and for the
foreseeable future, the Central IRB will review only multi-site ORD
projects, such as Cooperative Studies Program (CSP) projects.
Guidance on the VA Central IRB web site states:
Each VA
facility that plans to use the VA Central IRB must add the VA Central
IRB to its Federalwide Assurance (FWA) and sign a Memorandum of
Understanding (MOU) with the VHA Central Office (VHACO) Human Research
Protection Program (HRPP). The MOU will clearly delineate the respective
roles and responsibilities of each entity. The local VA has ultimate
responsibility for its HRPP.
This
guidance has prompted NPCs to ask whether they need to add the VA
Central IRB to their own FWAs. For the present, it appears that
the only time the VA Central IRB may be a factor for an NPC is if the
NPC received non-VA government (e.g., DoD or NIH) or private sector
funds in support of studies (e.g., some CSP projects) that will be
reviewed by the VA Central IRB. If your NPC encounters this
situation, please contact Dr. Cates for guidance. Phone:
202-254-0282 or
Lynn.Cates@va.gov
NPCs
will recall that the recent IG report on five NPCs and VHA oversight
included the finding that “NPCs inappropriately received reimbursements
for services from VA medical centers” pursuant to Intergovernmental
Personnel Act (IPA) assignments. As a result, NPCs are asking
whether they may continue to participate in IPA assignments that involve
reimbursement to NPCs using VA-appropriated funds. In response to
this question, Renée Szybala, Associate General Counsel, Professional
Staff Group III, replied:
We are
aware of the issue and of the need for a clarifying opinion out of this
office. While this OIG audit was ongoing, we assisted the NPCs in
providing documents to the OIG on the guidance out of OGC on this issue,
and it became clear that there was no specific guidance either way.
We have agreed to provide an opinion to VHA. In the meantime, we
are not suggesting that the practice of VAMC reimbursement of the NPC
for personnel detailed under the IPA authority be stopped.
NPCs
should also be aware that in order to resolve any uncertainty about the
allowability of such IPA reimbursements going forward, NAVREF included
specific authority for them in S. 2926, the bill proposed to update and
clarify NPC authorities. It states:
`(2) A
Department medical center may reimburse the corporation for all or a
portion of the pay, benefits, or both of an employee of the corporation
who is assigned to the Department medical center if the assignment is
carried out pursuant to subchapter VI of chapter 33 of title 5.
NAVREF
remains cautiously optimistic that Congress will enact this legislation
during the current legislative session thereby obviating the need for an
OGC opinion. As always, NAVREF urges NPCs to ensure that each IPA
assignment fulfills all the requirements of the IPA authority. For
guidance go to
http://www.navref.org/library/IPA_main_page.htm
In 2009
the IRS will begin requiring many nonprofits to use the new, completely
re-designed IRS Form 990. The form itself has been available on
the IRS web site since December 2007 (see
http://www.irs.gov/charities/article/0,,id=181089,00.html) and the IRS
expects to publish the final instructions shortly.
All
NPCs should take the time now to get to know the new form, which is
significantly different from the old form in format and content, and
should discuss it with their accountants. Clark Nuber, the
Seattle-based CPA and consulting firm, has graciously allowed NAVREF to
make available to its members two excellent articles about the new 990.
These are posted at:http://navref.org/newsletter/pdf/Clark_Nuber_Spring_2008_NFP_Newsletter.pdfhttp://navref.org/newsletter/pdf/Clark_Nuber_Winter_2007-8_NPF_Newsletter.pdf
Among
other new items, the re-designed Form 990 asks each nonprofit to
describe its process for board review of Form 990, for monitoring and
enforcing its conflict of interest policy, and for determining
compensation of key employees. NPCs should begin developing these
now in order to be able to respond “yes” to questions asking whether it
has these processes in place.
During
the bi-annual VHA Senior Management Conference being held August 25-28,
NAVREF will conduct a session for the medical center directors and
chiefs of staff who serve on NPC boards. Please encourage your
board members to register for this session.
Date:
Wednesday, August 27
Time: 12:00 noon to 1:30 pm (This will be a lunchtime “Soundbites” session)
Title: Keeping in Tune with Managing your Non-Profit
Description:
Attend this session for discussion of the recent OIG report on its
review of five VA-affiliated nonprofit research and education
corporations (NPCs). Learn how S. 2926, the "Veterans Research and
Education Corporations Enhancement Act of 2008," responds to the
findings as well as NAVREF plans for NPC training. Then hear from
David O. Renz, Ph.D., a nationally known educator on nonprofit
governance leadership. Leave with practical advice on fulfilling
your NPC board member oversight responsibilities among the many other
demands on your time."
Please
note that NAVREF has invited Dr. Renz to speak during the 2008 NAVREF
Annual Conference (October 19-22). If he accepts, NPC executive
directors and other staff who attend also have an opportunity to hear
his presentation.
Many
thanks to all who replied to the recent NAVREF survey conducted to
assess interest in training on indirect cost negotiations and the best
timing. The level of interest exceeded our expectations so this
training definitely will be offered in conjunction with the 2008 Annual
Conference. Also, the responses were overwhelmingly in favor of
holding the training mid-week, after the regular Annual Conference
program ends.
Plans
for the conference are beginning to firm up. Please watch for
future emails, but for those eager to make their travel plans, the
general program is provided below.
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Where and When
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Hotel Accommodations and Meeting Sessions
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Marriott Crystal City at Reagan National Airport
1999 Jefferson Davis Highway, Arlington, VA 22202
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For reservations and the main switchboard, dial 703-413-5500
For reservations only: 1-800-228-9290. Identify yourself
as a “NAVREF 2008 Annual Conference” attendee when making
reservations
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Airports
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Ronald Reagan Washington National Airport (DCA) – 1 mile; Metro
$1.35
Washington Dulles International Airport (IAD) – 25 miles; Taxi
~$65.00
Baltimore Washington International Airport (BWI) – 55 miles;
Taxi ~$70.00
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Date
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Time
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Function
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Sunday, Oct. 19
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3:30 pm
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Registration Opens
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4:30 pm
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Special Session for New NPC Executive Directors and Board
Members
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5:00 pm to 6:30 pm
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NAVREF Committee Meetings
Government Affairs Committee
Non Government Affairs Committee
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6:00 pm
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Meet and Mingle with the NAVREF Board of Directors
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6:30 pm
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Annual Membership Meeting and Dinner
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Monday, Oct. 20
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7:00 am
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Registration and Continental Breakfast
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8:00 am to 5:00 pm
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General Sessions
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5:30 pm to 7:00 pm
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Networking Reception
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Tuesday, Oct. 21
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7:00 am
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Continental Breakfast
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8:00 am to 5:00 pm
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Workshop: Financial Policies and Procedures (Part I)
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8:00 am to 3:00 pm
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Breakout: VA Attorneys only
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Wed., Oct. 22
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7:00 am
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Continental Breakfast
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8:00 am to 1:00 pm
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Workshop: Financial Policies and Procedures (Part II)
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1:00 pm
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Annual Conference Program Concludes
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Special Workshop
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1:30 pm to 5:00 pm
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Special Workshop: Indirect Cost Rate Negotiations (Part I)
– Add-on fee $450.00
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Thursday, Oct. 23
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7:00 am
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Continental Breakfast
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Special Workshop
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8:00 am to 1:00 pm
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Special Workshop: Indirect Cost Rate Negotiations (Part
II) – Add-on fee
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1:00 pm
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Special Workshop Concludes
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Questions or comments about this Update may be directed to:br>
Email:
navref@navref.org
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Phone: 301-656-5005 |
Fax: 301-656-5008 |
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