Advancing Discovery for Those Who Served

What member sites are reporting

Two years into VA Human Resources Modernization of Research Hiring, timelines have not meaningfully improved — including for renewals of current staff. The Human Resources Operations Office (HROO) continues to operate with staffing levels insufficient for current request volumes, and new policy requirements often roll out without adequate training, creating uneven understanding and prolonged review cycles.

NPCs receive no status updates on where candidates sit in the process, leaving them unable to support candidates or meet their legal obligation to keep applicants informed. Hiring practices are inconsistent across sites — some candidates in the same job title are required to complete drug or physical testing, while others are not — creating real legal and compliance exposure.

Impact on Veterans and the research enterprise

Section 208/209 — A Waiver Crisis That Did Not Exist Two Years Ago

In October 2023, the U.S. Office of Government Ethics issued a new interpretation of 18 U.S.C. § 208, the federal conflict-of-interest law. Research projects that were previously viewed as two parts — the science conducted by VA and the business of the grant managed by the affiliate — are now treated as a single "particular matter." Any VA investigator with a dual appointment at an NPC or university affiliate is presumed to have a conflict of interest, even if their only role is conducting the research. The interpretation interacts directly with 18 U.S.C. § 209, which restricts supplementation of federal salaries, compounding the burden on dually appointed investigators.

The result: an estimated 3,500 to 4,000 individual COI waivers per year just to apply for research funding. The administrative burden falls on researchers, medical center directors, and leadership — and risks deterring top scientists from pursuing VA research at all. NAVREF and FOVA have urged a narrow legislative fix to restore the prior workable standard for public service scientists, in joint letters to the House VA Committee (Sept. 9, 2024) and to the White House (Dec. 4, 2024).

Indirect Costs — NPCs Are Not Universities

Federal discussions about indirect cost recovery often assume a research environment anchored by universities with tuition revenue, endowments, and clinical margins to subsidize infrastructure. That model does not describe VA-affiliated NPCs. NPCs exist solely to support VA research and have none of those revenue cushions. Indirect cost recovery is the primary mechanism that sustains the administrative, compliance, and research infrastructure that allows VA research to operate safely and in compliance with federal regulation.

NPCs already recover indirect costs at roughly half the rate of large academic institutions. A proposed 15% cap would fall well below what is required to maintain federally mandated infrastructure: IRB and human subjects protections, regulatory compliance and reporting, data security and IT, grants administration, and the coordinator and analyst staffing required to keep studies enrolling. Because NPCs operate at a smaller scale with concentrated funding streams, even modest reductions can destabilize the entire network.

For perspective: VA-affiliated NPCs received approximately $114.6 million from NIH in 2023 — about 0.25% of NIH’s total budget. A cap aimed at the largest federal research recipients would do disproportionate damage to a small, mission-specific network that exists only to serve Veteran-focused research.

What is at stake if indirect cost recovery is cut