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FEDERAL ETHICS AND STATUTES REGULATIONS
Discussion
In 2010, the clause in the NPC authorizing statute that invoked federal
conflicts of interest rules for NPC board members,
officers, and employees was replaced with a requirement that each NPC must have
its own conflict of interest policy. However, NPCs exist in a
federal environment and many of their employees have VA without compensation
appointments so it is important that NPC personnel be familiar with federal
conflict of interest rules.
Although the NPC authorizing statute and its legislative history specify only
conflicts of interest, VA General Counsel has determined that NPC employees with
VA without compensation appointments meet the definition of a federal employee for purposes of
conduct in the performance of the work they perform under their WOC
appointments. Therefore they are subject to federal conduct regulations as well as
conflicts of interest in the performance of their duties. The definition of a
federal employee can be found at 5 U.S.C. part 2105
http://www4.law.cornell.edu/uscode/5/2105.html.
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