Dissemination of the memo signed by the leadership of the Office of Research and Development (ORD) and the Office of Research Oversight (ORO) has prompted a number of inquiries to the NAVREF office.

 Background:  Reviews of some NPCs initiated by some ORO personnel and facility research compliance officers (RCOs) appeared to overlap with the oversight responsibilities of the Nonprofit Program Office (NPPO).  The combined oversight load was imposing a considerable burden on NPC staff of the affected NPCs.  Also, there were questions about the appropriateness of some of the review requests made by ORO personnel and RCOs.

 This became a topic of discussions between NAVREF, ORD and NPPO Administrator Kim Collins.  Kim sought clarification of ORO and RCO roles in regard to NPCs.  As noted in the resulting memo, most of the documents pertinent to research oversight clearly within the purview of ORO and RCOs are available from VA sources.  When appropriate, NPC records may be reviewed by ORO or an RCO. The memo clarifies that NPCs have the right to request justification for an ORO or RCO review request.  In the event of a dispute, an NPC may seek adjudication by the NPPO or if necessary, up the VHA chain of command all the way to the Secretary.

 NAVREF anticipates that there will be few disputes about access to NPC records.  However, we appreciate that the memo clarifies NPCs’ right to request justification; provides a resolution process; and also urges research overseers to be respectful of the burden their review requests impose on NPC staff, particularly when the response may be more appropriately handled by the facility Research Administration Office.

 NPCs should be reassured that the memo simply clarifies respective roles and rights; it was not prompted by a need to investigate some particular aspect of NPC management.

Click here for Memo re ORO and RCO Roles - 7-26-2010