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Related Information
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

Purchasing Overview

Supplies and expenditures in support of research activities such as chemicals, animal, laboratory supplies, etc. may be requested by the Principal Investigator by submitting the appropriate paperwork to the Foundation staff. All purchase requests must be submitted on Foundation purchase order forms, not VA forms. The Accounting Assistant reviews paperwork to ensure all items are filled in properly. The Executive Director reviews and approves all purchases over $500. The Accounting Assistant orders all items; the Principal Investigator reviews orders upon receipt and then returns the packing slips to the Accounting Assistant as verification of receipt. Payments are made after an original invoice is received.

If the Foundation staff reviews a proposed expenditure and deems it inappropriate, the Principal Investigator may seek review by the Board of Directors for final disposition.

NOTE: All disapproved requests will be retained in the AREF Research File as evidence of review and disapproval for future audits.

All expenditures over $500 must be requested by the Principal Investigator and approved by the Executive Director.

Supplies, equipment, and needed services may be purchased on the open market. Any item over $5,000 must have at least three (3) bids unless sole source justification can be provided.

All equipment items purchased for permanent, long-term use, valued over $5,000 are to be capitalized.

Credit Card Policy (Effective October 2002)

Credit cards may be issued to the Executive Director, Board President, and Controller to be used for legitimate Foundation business. This includes, but is not limited to, travel and approved purchases.

Purchase Orders

The Foundation’s Purchase Order form must be submitted when requesting an order. The form has a series of boxes that must be completed:

  • PO Date (date of request)
  • Project Number (specify account)
  • Investigator Signature (certifies the purchase as necessary to the project)

Journal Clubs, Seminars, & On-Site Research Meetings

The dissemination of research results and planning is an important research activity. Regular laboratory meetings are part of the day-to-day operations of any program; however, seminars/journal clubs and irregular meetings are important mechanisms of dissemination of research results and developing collaborations. Due to the nature of the business, these activities may occur with light refreshments and/or appropriate meals. The meals/refreshments (non-alcoholic) must be secondary to the activities. In conjunction, AREF may reimburse for such irregular activities when they are secondary to a research or educational activity. AREF must also be cognizant of its role as an entity supporting research conducted with or at a federal agency and the impact of the Federal Standards of Ethical Conduct. Accordingly, AREF must review all requests for business meetings, which may include meals as secondary activities, prior to the activity occurring.

The types of meetings that may be eligible for AREF support are too numerous to list and the characteristics of appropriate meetings may vary. However, factors that AREF will consider when evaluating a meeting for support include:

  • Whether at least one speaker makes a research presentation or presents educational instruction.
  • Whether a non-VAMC speaker and/or non-VAMC personnel are among the expected attendees.
  • The frequency of similar meetings that may involve the same personnel. Irregularly scheduled meetings and/or those that occur no more than monthly may be eligible for support; weekly meetings generally will not.
  • Whether support is requested for routine VAMC staff, committee or department meetings. Generally, AREF will not support meal expenses for such meetings.
  • Whether the meeting involves at least one individual who is being recruited to conduct research or education at the VAMC.
  • Whether the meeting lasts more than two (2) hours or extends through a normal mealtime.

Procedures for reimbursement are listed below.

Prior To Activity

  1. Purchase order must be submitted at least one (1) week in advance.
  2. Attach agenda or meeting announcement.
  3. Obtain purchase order number after approval from Accounting Assistant.

After Activity

  1. Complete and submit Reimbursement of Personal Payment for Project form or submit invoice from vendor (include purchase order number).
  2. Attach signature list of attendees.
  3. Attach original receipts.

Cellular Phone Policy (Effective July 2004)

AREF acknowledges the need for cellular phones to conduct research and/or education-related business. The use of AREF-provided cellular phones to make or receive personal calls is discouraged, although it is understood that personal calls may be necessary in emergency or travel situations. On a monthly basis the Controller or accounting staff will review bills for overage. Any unjustified expenses exceeding the service plan accrued by the employee for personal calls shall be the responsibility of the employee and will be charged accordingly.

Documented Review of Monthly Charges

  1. If personal use does not exceed the negotiated plan, no reimbursement is necessary.
  2. If personal use exceeds the plan minutes, then employee will be assessed at the rate of the excess-minute rate for personal calls. This reimbursement will be applied to the amount of personal use or the amount of excess minutes used, whichever is less. Roaming charges will be determined on a case by case basis.

Periodic Review of Billing Options
AREF shall periodically review the choice of billing options, considering:

  1. the demonstrated need for a cellular telephone for each specific user;
  2. the most economical billing option for each specific user; and
  3. documented review of personal use and business use that is reconciled on a monthly basis.

Reimbursement Policy

The reimbursement form is to be used for reimbursements to individual staff members for expenditures made for small (“odds-and-ends”) supplies necessary to a particular project. These expenditures should not be in excess of $100 and all original receipts must be attached to the reimbursement request.

If it is more practical to make a purchase individually (such as by credit card) and the amount will be over $50, a purchase order must be prepared and approved before making the purchase. This number would then be entered on the reimbursement request form.

Subscription & Membership Policy

Expenditures for continued education, including scientific books, conference and registration fees, society memberships, etc., specifically relating to a research activity may be requested by submitting the appropriate paperwork to the Foundation. Subscriptions or professional association dues, with the exclusion of license fees, may be paid from appropriate research or general operating funds upon approval by the Executive Director. All dues and subscriptions must list the address of the VA.

Everything paid for by the Foundation on behalf of an Investigator must support approved research programs or education activities. If the fund account indicated is a general donation, the investigator must certify that the expense is within the scope of the donor’s intent.

Organizational memberships cannot be paid for by Foundation funds unless that membership is necessary to receive the organization’s journal or publications.

Everything that is ordered and paid for by the Foundation must come directly to the VA facility. This means that subscriptions to journals and other publications cannot be sent to the investigator’s home or to another location. If the address information is different from the VA facility, all changes must be made by the investigator. Any incomplete requests will be returned to the investigator. Renewals can only be made for one year at a time.

The investigator must complete a copy of the attached payment request indicating in what way the particular publication or subscription impacts on the specific research project.

Patient Payment Guidelines

Principal Investigators requesting payment to a subject for their participation in research activities must submit the name, mailing address and social security number for each subject. In any case where any subject receives in total $600 or more in a calendar year, the Foundation must submit such year-end information to the IRS and the subject.

Attached are four (4) related forms to be used by you when making payments to any person or institute related to subject/patient participation in your research project(s).

  1. Assessment of Clinical Impact form is used to reimburse the Medical Center for patient care costs incurred specifically for the research project, such as Inpatient Medicine, Outpatient Services, etc. using rates agreed upon by the VA and AREF. Effective February 1, 2002, a clinical impact form must be completed prior to initiating the protocol.
  2. Study Subject Payment Request Form is used to pay the subject/patient for any agreed upon payment for his/her total participation in the study.
  3. Study Subject Cash Payment Form is used if a cash, out of pocket payment of $20 or less is made at the time of visit to the subject/patient to cover per diem expenses (i.e. lunch, car fare). The subject/patient must sign the bottom, Receipt of Payment portion, before reimbursement can be made to the person named in the top portion.
  4. Petty Cash is for the support of subject reimbursement for patients participating in studies. It is allowed only when it is necessary to provide care reimbursement. The amount is limited and requires logs.

Consultant Services

A Consultant is an individual that has been contracted to complete a specific and necessary aspect of an authorized project with definitive closure, i.e. such as a report, or data collected for X number of patients.

When retaining an individual’s services, a contract must be completed between the consultant and the PI. This contract must be submitted to the Foundation for approval before work can begin.

In the area designated “Scope of Services," you should indicate:

  1. which project is involved,
  2. what work the contractor will be doing,
  3. how it affects the project, and
  4. the deadline

To receive payment upon completion of the contract, or part of the contract,

  1. the Consultant submits a bill to the investigator with a progress report
  2. the Consultant is required to turn in a report to the investigator along with the invoice
  3. the investigator in turn attaches the invoice and progress report to the Foundation’s Payment for Contractual Services Form.

IRS Guidelines for Defining a Consultant

  1. A person required to comply with instructions about when, where, and how work is to be done is usually an employee.
  2. If an experienced employee trains an individual, the individual is ordinarily an employee. Independent contractors generally use their own methods and receive no training.
  3. When the success of a business depends to a considerable extent on the way in which certain services are performed, the persons performing the services are considered to be subject to control in the business and thus employees.
  4. If services must be performed personally and it is of concern to the employer who performs them, it indicates the employer is interested in performance methods as well as results, and points to employee status.
  5. If a worker hires, supervises, and pays other workers under a contract to provide a given result, the worker is generally an independent contractor.
  6. A continuing relationship between an individual and someone for whom the individual provides services is indicative of an employee-employer relationship.
  7. Establishment of specific hours for performance of a job is indicative of employee status.
  8. If an individual is required to be devoted full-time to the business of the employer, the individual is probably an employee.
  9. If the work is performed on the premises of the employer, that fact implies a certain amount of control by the employer and lends credence to the determination of employee status.
  10. If services must be performed in a prescribed sequence, this implies control and lends support to classification of the person performing the services as an employee.
  11. If a worker must submit regular reports, it implies control and an employee status.
  12. Hourly, weekly, or monthly compensation implies control and employee status, independent contractors generally are paid by the job.
  13. Payment of a worker’s business and traveling expenses indicates control and an employee status.
  14. If tools and materials are provided, it indicates control and an employee status.
  15. If a person makes a significant investment in facilities (equipment or premises), it implies independent contractor status.
  16. A person who can realize a profit or suffer a loss dependent on his or her services is usually an independent contractor.
  17. If a person’s services are made available to the public, as show by advertising, telephone listings, and signs, the person is generally considered an independent contractor.
  18. If an individual can be fired, it is indicative of an employee-employer relationship; an independent contractor generally can’t be fired as long as the results of services performed measure up to the contract specifications.
  19. An employee can terminate a relationship with an employer at any time without incurring liability; an independent contractor is usually responsible for satisfactory completion of a job.
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