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Noteworthy Policies: Conflict of Interest
As part of the performance of official functions, each AREF employee is subject to Federal Conflicts of Interest. Each employee shall sign a “Standards of Ethical Conduct and Related Responsibilities of Employees” at the beginning of their work with the Foundation.
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Policies & Procedures


Purpose of the Corporation

The purpose of the Atlanta Research and Education Foundation is to facilitate and support research and education activities at the Atlanta VA Medical Center. AREF has been incorporated as a nonprofit corporation under the laws of the State of Georgia and shall comply with all local, state and federal laws and with the common ethical principles of academic medicine. Although AREF is a private corporation, it is also subject to certain forms of federal oversight (38 U.S.C. 7361, 7362).

AREF Personnel

The Executive Director is responsible for overseeing the day-to-day management of the Foundation. Such duties may include, but are not limited to:

  • reviewing contracts, agreements or collaborations between the Foundation and other entities for compliance with federal, VA and nonprofit guidelines;
  • establishing, with appropriate professional assistance, necessary and appropriate internal accounting and management control systems;
  • maintaining appropriate fiscal and management records of all research activities in the Foundation offices, and submit regular reports to the Board of Directors for their review;
  • submitting an annual budget to the Board of Directors for review;
  • providing oversight of all appropriate reports and annual filings are made to State, Federal and VA authorities (annual filings with the Secretary of State, Annual Report to the VA, Federal IRS 990, RDIS Annual Report, and reports to Regional Counsel).

Administrative and/or Accounting Staff may be hired by the Executive Director as needed to effectively carry out the operations of the Foundation. Such staff will be managed by and be responsible to the Executive Director. Accounting staff will handle the day-to-day financial operations of the Foundation including, but not limited to, depositing of funds, maintenance of all necessary Foundation accounts, processing of all bills, purchase of all equipment and supplies, writing appropriate checks for signature by the Executive Director and/or appropriate official, and monthly reconciliation of accounts. Administrative staff will handle the day-to-day administrative operations of the Foundation, including, but not limited to, reviewing and revising contracts as necessary, maintenance of administrative and Board files, arranging for quarterly Board meetings and taking minutes at same.

Equal employment opportunity will be provided to all staff and applicants without regard to race, color, religion, disability, sex, age, or national origin.

Disclosure of Public Records

It is the policy of the Atlanta Research and Education Foundation, Inc. that members of the general public requesting records which are subject to the Georgia Open Records Act, O.C.G.A. 50-18-70, et seq., such as the IRS Form 990, Request for Tax-Exempt Status (IRS Form 1023),  IRS Exemption Determination Letter (IRS Letter 947) etc., will be provided copies. Requests must be made to the Foundation’s Executive Director, Board President, Controller, or Grants Manager.

The Atlanta Research and Education Foundation, Inc. will provide copies of the most current three years of the IRS Form 990 filed as well as copies of other requested records which are subject to the Georgia Open Records Act.

Requests Made in Person
It is the policy of the Foundation that members of the general public requesting records in person will receive requested records by close of business on the day of request. Appropriate photocopying expenses must be paid before the documents are released.

Requests Made in Writing
It is the policy of the Foundation that members of the general public requesting records in writing will be provided the documents upon reimbursement of photocopying expense and postage expense within the required 30-day period.

Source & Management of Funds

AREF may accept funds in the form of grants, agreements or gifts from such sources as: Federal or private nonprofit agencies; commercial organizations involved in the development of new medical materials and devices or in support of medical research and/or education; personal contributions; or from organizations or individuals to defray the costs of scientific meetings, teaching or other legitimate academic functions. The Foundation may administer government grants and contracts.

Funds donated in support of a research project can be accepted only if the Principal Investigator holds an appointment at the VA Medical Center and funds related to a project may be expended only after the VA Research and Development Committee approves the research for activation. All checks must be made payable to the ATLANTA RESEARCH AND EDUCATION FOUNDATION (AREF). If a donor letter does not accompany the funds, AREF will send an acknowledgement letter that outlines the intended use for the funds.

Funds donated in support of an educational activity can be accepted and may be expended only with the Education and Training Committee or its designated committee as detailed in VAMC Atlanta policy has approved the activity.

Funds received for specific projects or activities should not be commingled with other donations. Separate accounts will be established in accordance with FASB 116-117 and appropriate OMB circular. At the end of a study, Investigators will follow close out procedures.

Transfer of General Post Funds

38 U.S.C. Section 4162 allows funds donated to the VA Medical Center’s General Post Funds for general VA research purposes to be transferred to the Foundation. Funds donated to the General Post Funds for a specific research project may be transferred to the Foundation with the consent of the donor. The R&D Committee must approve all such transfers. The Foundation shall document any such transfer of funds to appropriately account for all funds received and the purpose to which such funds will be applied.

Transfer of Government Grants from VA to Foundation

If the VA is currently administering a Government Grant, two letters must be sent to the granting agency. One letter from the VA stating that they are willing to release the grant to the Foundation, and one from the Foundation stating that they are agreeable to administering the grant. Indirect costs will be determined by the Board of Directors.

Indirect Cost Rate

Effective January 1, 2011, the Foundation’s indirect cost rate to be applied to federal grants is 19%. At the conclusion of the fiscal/calendar year, an actual cost list must be completed. The actual percentage costs will be the Provisional Indirect Cost Rate for the following fiscal/calendar year. Each year a new Indirect Cost Rate must be calculated.

Foundation Research Activities

Project Approval: All research projects must receive a formal approval by the VA R&D Committee and other appropriate committees and subcommittees prior to any funds being expended by the Foundation. Such committees and subcommittees may include: R&D Committee, Internal Review Board for Human Subjects, the Subcommittee on Animal Studies, Radioisotope Committee, and the Biohazard Committee.

Principal Investigators: The Principal Investigator for each project/activity must hold a VA appointment. The Principal Investigator for each project/activity is responsible for providing candidates and supervising personnel for their research activity. The Foundation will pay research personnel from the appropriate research account funds only upon request and approval from the appropriate Principal Investigator.

Research Personnel: The Principal Investigator for each research project or activity is responsible for managing personnel involved in research. AREF will pay said personnel on request from the Principal Investigator from appropriate funds.

Equipment: All equipment purchased with Foundation funds belongs to the Foundation.

Insurance

The Foundation shall purchase and maintain Directors and Officers Liability Insurance, also known as “errors and omissions” insurance.

The Foundation shall purchase and maintain General Property and Liability Insurance to cover Foundation property, equipment and personnel.

Research Agreement and Project Initiation

Animal and Laboratory Studies: Research agreements with sponsors must be submitted for review to the AREF Senior Grants Manager.

Clinical Trials: Effective March 15, 2006, the VA's Clinical Trial Cooperative Research and Development Agreement (CT CRADA) template will be used during negotiations with collaborators for clinical trials conducted at the Atlanta VA Medical Center.

The Investigator should not sign nor finalize negotiations on any portion of the agreement until concurrence is achieved by all parties.

The following information will be needed for each agreement:

Sponsor's Name
Business Address
Contact Person
Telephone and Fax Numbers
E-mail Address
Title of Study/Project
Copy of Study Budget
(must include AREF administrative overhead fee)

If study/project involves human subjects, the Investigator is required to provide the AREF Grants/Contracts Administrator with a completed Assessment of Clinical Impact form, which outlines the obligations of the study to the Atlanta VA Medical Center.

Research & Development Committee submission packets/forms may be obtained via the internet at: https://www.atlaref.org/forms/vamc.cfm or in the Science Information Office (5A117). If you have any questions regarding the submission process, please contact the Science Information Officer at 404.728.4827 or sio@atlaref.org.

Prior to initiating an AREF administered study/project or accepting project related funds the following criteria must be met:

  1. Fully executed agreement between AREF and sponsor
  2. VA R&D Committee and subcommittee (IRB, IACUC and Research Safety) approval

Clinical Trial Budget Review

Budgets associated with clinical trial studies must be submitted to the AREF office for review and approval as part of the clinical trial agreement concurrence.

The Principal Investigator and/or Clinical Coordinator must schedule an appointment with the AREF Clinical Trials Financial Analyst, 404.321.6111, ext: 7288, to review the protocol and the medical procedures involved in conducting the study. This is done to determine procedures considered above the standard of care and reimbursement of costs to the Atlanta VA Medical Center.

Please prepare and provide the following information, which will be discussed during the meeting:

  1. Completed Assessment of Clinical Impact form
  2. Listing of procedures involved (including CPT codes)

Project Closeout Procedures

When a project is finalized or terminated, it must be closed with the VA Science Information Office and the AREF Controller. 
 
Investigators should follow these steps to move any funds to an unrestricted account:

  1. Close the project with the VA Science Information Office
  2. Inform the AREF Senior Grants Manager that the project is terminated or finalized
  3. If the project is a clinical trial, complete Clinical Trial Closeout Checklist
  4. Provide the Controller with any pending bills or commitments
  5. Certify that VA has been reimbursed for any ancillary tests
  6. Certify that no funds are due the Sponsor

Any remaining funds may be transferred to an unrestricted account. 

Transfer of Equipment and/or Funds

Transfer of Principal Investigator
If the Principal Investigator transfers to another VA and wishes to transfer his/her research project(s) and related funds to another VA-affiliated nonprofit corporation (NPC), the project sponsor must first approve the request as outlined in the study agreement. If approved by the project sponsor, a letter must be received from the new NPC requesting the transfer and advising that they will accept responsibility for the research project(s), funds and equipment (if applicable). In some situations, such as clinical trials, it is common for the parties (project sponsor, NPC, and VA) to identify and agree to an alternative principal investigator. This process of identifying an alternative principal investigator must also be adhered to as outlined in the study agreement. Any and all transfers of funds greater than $10,000 and/or equipment must be reviewed and approved by the Board of Directors. When a Principal Investigator leaves the VA, becomes employed by a for-profit institution, or retires, the distribution of any and all remaining project funds and equipment will be determined by the Board of Directors.

Transfer of Equipment or Funds
All equipment and funds remain with the Foundation until the Board determines their appropriate distribution. Transfer of funds and/or equipment may only be made to another VA-affiliated nonprofit corporation and must benefit VA research or education. No funds or equipment will be transferred to a for-profit organization. The Principal Investigator is responsible for the shipment of any equipment to the new corporation. Sale of any equipment must be approved by the Board of Directors. Proceeds from any sales will be deposited to the AREF corporate operating fund.

Off-Site Loan of Equipment

With the approval of the Executive Director, any equipment purchased by AREF may be loaned to the Principal Investigator or another entity, to be housed at an off-site location if it is in support of the research project. Loans must be renewed and approved on an annual basis. When the loan period is complete, the loanee may request an extension or must return the equipment to AREF.

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