The statute that authorizes the NPCs provides that NPC employees are subject to federal ethics regulations pertaining to conflict of interest. Acceptance of donations to support travel may raise conflict of interest concerns. Therefore, NPC administrators should be aware of federal conflict of interest ethics regulations in order to assist both VA and NPC employees. A brief summary of these regulations follows.

1. The Standards of Ethical Conduct for Employees in the Executive Branch apply to federal employees and state that federal employees may not use their public offices for private gain.

2. Federal employees are prohibited from soliciting or receiving gifts from entities that conduct business with the government.

3. An exception to the gift prohibition allows gifts of travel and related expenses to federal agencies when the purpose of the gift is to “facilitate the agency's mission.” Unless the payment comes from a 501(c)(3) organization, the gift must be directed to the agency, not to an individual.

4. Acceptance of travel support is allowed to facilitate attendance at

• an event in which the employee is a speaker or panel participant, including presentations regarding the employee's official duties or policies, programs or operations of the agency;
• an educational event to receive training other than promotional vender training, or to present or exchange substantive information concerning a subject of mutual interest;
• an event at which the employee will accept an allowable award or honorary degree consistent with the employee's official duties.

Acceptance may be appropriate in other circumstances. Conversely, acceptance may be inappropriate due to extenuating circumstances. Consult VA ethics officials or regional counsel for additional details.

A nonprofit may provide reimbursement for travel conducted on "off duty" status (annual leave) as well as "on duty" status (official absence, authorized absence, administrative leave) provided that the purpose of the travel supports an allowable activity as described above.

5. If the primary purpose of a meeting is marketing of products or services, acceptance of nonfederal travel support is inappropriate. However, if the purpose is training in the use of products or services previously bought by the agency, accepting the gift may be allowable.

6. Generally, payments for acceptable travel must be in-kind such as airline tickets and pre-paid hotel accommodations; employees may not be provided with cash. However, if an otherwise acceptable payment comes from a nonprofit organization, both cash and in-kind payments are allowable.

7. Federal employees are not restricted to federal per diem rates when travel is paid by a non-governmental organization. However, both VA and IRS regulations prohibit extravagance.

8. Travel support may not be accepted if the authorized agency official determines that acceptance would undermine the integrity of the agency programs or operations.