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VA EMPLOYEES AS BOARD MEMBERS
Discussion
The statute that authorizes the VA nonprofit research
and education corporations mandates that the affiliated medical center
director, chief of staff and associate chiefs of staff for research and
education serve on the board of any nonprofit established under this
authority. Therefore, these personnel are not at risk of violating
conflict of interest laws contained in 18 USC, Part I, Chapter 11,
Section 208, Acts affecting a personal financial interest.
However, other VA personnel - such as physicians and
PhD investigators - serving on the board of a research and education
corporation are at risk. The Office of General Counsel has determined
that service by VA employees in their personal capacities on non-federal
boards is acceptable and does not invoke the criminal conflict of
interest statute. However, such personal business must be conducted
during personal time.
To clearly delineate official and personal capacities,
NAVREF recommends that board meetings and other board business involving
VA personnel be conducted outside normal VA duty hours; that is, before
8:30 a.m., after 4:30 p.m. or during a normal lunch break (30-60 minutes
consistent with local medical center policy).
Compliance with NPC Statute and VA Requirements >
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