Not content to rely solely on income generated by grants, a number of NPCs are beginning to conduct fund raising activities to obtain additional research funds and to cover administrative expenses.

A General Counsel advisory dated June 28, 1993 confirms that NPCs have broad authority to do fund raising, may engage in fund raising activities and may hire professional fund raisers. Further, the advisory states that VA employees acting in their official NPC capacities may engage in fund raising activities and may solicit funds even from usually prohibited VA sources such as drug companies.

VA employees, however, must be aware that they are subject to the fund raising limitations contained Standards of Ethical Conduct for Employees of the Executive Branch, 5 CFR 2635.808.  Generally, these prohibit federal employees from soliciting funds in an official capacity except for the Combined Federal Campaign or where a law would permit otherwise. Therefore, any professional fund raising activity for an NPC may not include in the fund raising process VA employees who have no NPC affiliation. Further, anyone involved in fund raising for an NPC should explain what the NPC is and how it is separate from VA.

NPC representatives should be extremely cautious in approaching vendors who do business with VA. It would be prudent to ensure that those making VA purchasing decisions are not involved in fund raising solicitations. The NPC should not be construed as part of VA, though an explanation of how the NPC supports VA research is entirely appropriate. Finally, do not use the VA logo or the photographs and names of key VA administration personnel in any promotional materials.

Questions regarding fund raising activities by VA employees should be directed to the appropriate local ethics official.