In order to diversify revenue sources, a number of NPCs are entering into fund raising activities to obtain additional research and education funds or to cover administrative expenses.
VHA Handbook 1200.17, 12. (4), states that NPC Directors, officers and employees may engage in fundraising activities under the following conditions:
Statutory VA Directors may engage in fundraising in their official VA capacities as board members. Other VA employees, including those VA employees serving on the Board in official capacity other than the Statutory VA Directors, may participate in NPC fundraising activities in their personal capacities to the extent permitted by applicable Federal and state law, regulations, and VA policy. All are encouraged to seek advice from a VA Government Ethics official before engaging in such activities.
No solicitation of VA employees is permitted outside of approved Combined Federal Campaign activities.
No solicitation of research subjects whose identity or contact information is learned as part of administering a VA research study is permitted.
An NPC may hire a professional fundraiser to assist with fundraising activities.
VA employees must be aware that they are subject to the fundraising 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, fundraising activity for an NPC may not include VA employees, other than Statutory VA Directors, in the process. Further, anyone involved in fundraising 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 fundraising 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 fundraising activities by VA employees should be directed to the appropriate local ethics official.
The web site of the Association of Fundraising Professionals (AFP) provides useful information about working with a professional fundraiser.