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VHA Policy

VHA Handbook 1200.17 provision 8.c. provides "An NPC may employe individuals to carry out its purposes and may determine their compensation.  NPC employees who are given a VA Without Compensation (WOC) appointment in accordance with subparagraph (2)(a) to provide research or education services for VA must be supervised by VA Employees while providing such services to VA." 

(2) VA WOC Appointments for NPC Employees

(a)  WOC Appointments.  NPC employees who are directly or indirectly involved or engaged in approved VA research or education and training activities, and who perform such duties under the supervision of VA personnel, must have a VA WOC appointment.  If performing such duties the NPC employee must sign a VA Intellectual Property Agreement prior to performing such work.

(b)  VA Employees.  VA employees who work for the NPC during their non-VA duty hours, and who are assigned to VA to work on research projects or education and training activities during those NPC hours, must have a WOC appointment.  Such work must be different from the VA employee's official VA duties. 


A VA without compensation (WOC) appointment confers upon the appointee many privileges and responsibilities. A WOC appointment is a personnel appointment by which an individual contributes effort to VA activities but receives no monetary compensation or employee benefits from VA. While other agencies may have different interpretations of what a WOC appointment entails, VA considers WOCs to be federal employees for most purposes except pay and benefits.

A VA WOC appointment allows VA to accept donated services from individuals who are not paid by VA. A WOC appointment also limits VA liability for acts committed by WOCs to judgments under the Federal Tort Claims Act (FTCA).  Click here for additional information on FTCA.

WOCs are subject to federal conduct and conflicts of interest regulations in the performance of their official duties; must comply VA requirements pertaining to job qualifications and training; and VA can require them to assign to VA any rights to intellectual property that they may develop using VA resources.  Click here for the VHA Handbook 1200.18 on Intellectual Property; and click here for the VA Intellectual Property Agreement Form.

At the same time, subject to certification by the Attorney General, WOCs are protected by the Federal Tort Claims Act from personal liability in the performance of their official duties; may receive immunizations necessary to perform their work; and have access to VA employee assistance and training programs.

WOC Appointments for VA-Paid Employees

The VHA Office of Human Resource Management has confirmed that a VA-paid employee who performs NPC-paid work outside their VA tour of duty should have a WOC appointment to ensure FTCA coverage during the time worked for the NPC.

WOC Appointments for Non-VA NPC Employees

Before beginning work, each NPC employee who will be working on VA-approved research or education must obtain a VA without compensation (WOC) appointment.  The WOC appointment may be processed through the Research and Development office, the administrative service that will responsible for supervising the employee, or the human resource department depending on local policies. 

NPC Execution

Generally, for each new employee who will work on VA-approved research or education the NPC should provide a WOC appointment request letter to the VA office that processes WOC appointments. An agreement must be generated that at a minimum includes the following points:

  • Identity of the employee
  • VA service where work is to be performed
  • Nature of service
  • Inclusive dates of service (start date and termination date, or in lieu of a terminal date, a statement such as “for an indefinite period”)
  • A waiver of all claims to monetary remuneration
  • A provision to cancel the agreement by either party upon written notification
  • Statement of authority [38 U.S.C. 213]
  • Signatures of the appointee and the VA appointing official

Source: VA Handbook 5005, Part II, Chapter 1, 4. Types of Appointments, (c) WOC (Without Compensation) Appointments, [5 CFR 304.102(h)].

Other information may be requested such as:

  • Social Security number
  • Date of birth
  • Home address
  • Position title
  • Position description

An NPC employee may not begin work until an approved WOC appointment has been obtained. An ID badge, parking permit, etc., may not be issued prior to approval.

VA Execution

The VA must process necessary paperwork to ensure that the WOC appointment process has been completed properly. To assist the VA in processing WOC appointments, NPCs should be familiar with the VA process.

Required Documentation

WOC appointees must complete the following documentation. To assist in this process, the NPC may want to have these forms available to give to new employees.

Required VA-WOC Documentation

OF 306 Declaration of Federal Employment http://www.opm.gov/forms/pdf_fill/of0306.pdf
OF 612 or resume or CV Optional Application for Federal Employment http://www.opm.gov/forms/pdfimage/sf61.pdf
SF85 Questionnaire for Non-Sensitive Positions http://www.opm.gov/forms/pdf_fill/SF85.pdf
VA VA-WOC Appointee Intellectual Property Agreement http://www.research.va.gov/programs/tech_transfer/policies/default.cfm
VA Fingerprinting Card Consult VA

After the documentation has been completed, NPCs should try to ensure that each NPC employee has completed all required training and continues to undergo training on an annual basis.

WOC Imposed Training

A WOC appointment allows NPC employees to have access to VAMC facilities and to certain benefits provided to VA employees. It also imposes mandatory VA orientation and training requirements including orientation to the mission, policies, and functions of VA and the particular facility where the WOC will work (VA Handbook 5005, Part II, Chapter 1). Since NPC employees work in a VA facility, certain accrediting organizations require that these employees receive the same mandatory yearly training required of VA employees. Accordingly, NPCs should insure that NPC employees attend all required training as a condition of their continued WOC appointment at the VAMC.

Failure to meet mandatory VA training requirements such as orientation, safety, animal use, radiation, etc. could result in termination of an employee’s WOC appointment, which would result in their immediate termination from an NPC.

The following may not be a complete list.  Consult local VAMC officials for current VA and local requirements.

VA Training and Tests for WOC Appointees (Required)

Category Types of Training or Tests Required by
Computer Access and Security Awareness Video, Test All employees
VA Safety Training Facility Emergency Procedures (fire, call-backs, spills, etc.) All employees
Violence in the Workplace Video, Test All employees
Occupational Health Screening TB, and other Immunizations All employees
Infection Control  CBT, Test All employees
OTHER as may be required by the facility or current VA policy        

VA Training and Tests for WOC Appointees (As needed)

Category Types of Training or Tests Required by
Animal Use Employee Health Program (as applicable to animal contact), Test As needed
Biological (Bacterial/viral): Specify Agents:_________     As needed
Bio/Clinical Safety Presentation, Test As needed
Bloodborne Pathogens Survey, CBT, Test As needed
Chemical Hygiene Plan (i.e, Flammable, Carcinogenic, Noxious, etc.)   As needed
Electrical Hazards    As needed
Freezing Hazards (Ultra-low temperature freezers)    As needed

Human Studies Credentialing  

  As needed
Material Safety Data Sheet (MSDS) Location and use As needed
Radiation Safety (i.e., Radioisotopes)  Video, Presentation, Test     As needed
OTHER as may be required by the facility or current VA policy     


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