
NAVREF is the 501(c)(3) membership organization of VA-affiliated nonprofit research and education corporations (NPCs), authorized by Congress under 38 U.S.C. §§ 7361–7366. Our 75+ member sites provide the flexible, non-federal infrastructure that keeps VA research moving — managing grants, hiring research staff, and enabling public-private partnerships without new federal structures.
Hiring is currently the single most immediate threat to VA research. Reform WOC and IPA hiring delays, protect clinician-scientists’ research time, and fix the Section 208/209 waiver burden. Research is only as strong as the people doing it — and current rules are eroding the enterprise. If these deficiencies are not addressed, the damage to the VA research enterprise will be generational.
NAVREF’s ask: a 30-business-day onboarding standard, funded and enforced.
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. OPM limits, Office of General Counsel delays, FTCA coverage questions, and not-to-exceed appointment constraints compound at every step.
The domino effect: one delay costs one trial, which costs one scientist. Lost Principal Investigators mean lost grants, lost affiliate confidence, less funding, and fewer staff.
A VA clinician-scientist’s paid VA schedule is divided: most of it treating Veterans, a defined share dedicated to research. Both halves are VA work, on VA time, for VA patients. That research share is what allows an already-funded study to actually run.
It is not time away from patient care. Much of the research happens inside the clinical encounter — evaluating how a treatment performs during a visit, enrolling a Veteran in a trial at a regular appointment. Remove the protected share and the same physician still sees patients, but the study stops.
It is VA’s recruiting advantage. Physician-scientists can treat and investigate in the same job. Academic medical centers offer the same deal — so when VA cuts protected time, the physician leaves, and the grants, the staff, and the studies leave with them.
Research generates financial and operational value for VA medical centers. Grants, clinical trials, and industry partnerships bring resources into the medical center; research activity can contribute to VERA funding, and VA studies can identify effective, lower-cost alternatives to expensive drugs and therapies.
GAO has documented this. Its March 2025 review found that protected research time helps VA attract and retain clinician-scientists, that medical centers with staffing shortages struggle most to provide it, and that VA does not centrally track how it is allocated — so system-wide effects cannot be assessed. GAO-25-107360, Information on Protected Research Time for Clinician-Scientists.
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. Related statutes compound it: 18 U.S.C. §§ 203 and 205 cannot be waived at all, and are triggered when an investigator tries to serve as Principal Investigator at both VA and the affiliate on the same project.
VA’s Office of Research and Development built VAEDA-COI, a web-based tool that produces a completed OGE Form Alt-450 and auto-drafts waivers for straightforward dual-appointment cases, routing more complex cases to ethics counsel. It is useful triage — but every waiver still requires the medical center director’s personal signature, with no delegation permitted. A tool cannot repeal a statute.
Protect and grow the Medical and Prosthetic Research Program, add VA research to advance appropriations, and continue the indirect cost protections before they lapse. Research money that arrives late, or arrives short, does not simply slow a study down — it ends it.
Every continuing resolution freezes research at last year’s level and blocks new starts, which in practice means enrollment stops and multi-year studies lose their cohorts. Rescissions do the same lasting damage: a clinical trial cannot be paused and restarted like a construction contract. The Veterans enrolled do not wait.
The Friends of VA Medical Care and Health Research (FOVA) Coalition respectfully urges the Subcommittee to provide the full requested levels for:
$1.2 Billion for Medical and Prosthetic Research. Supports VA’s core research operations — investigator-initiated studies, clinical trials, and translational science — sustaining the research workforce, the investigator pipeline, and Veterans’ access to emerging therapies.
$200 Million for Major and Minor Construction. Addresses longstanding research infrastructure deficiencies, modernizes laboratory and clinical research space, corrects Priority 1 health and safety deficiencies, and brings facilities up to contemporary standards for biomedical research.
$55 Million for Research Information Technology. Supports dedicated modernization of VA’s research IT infrastructure — data storage and security, cloud computing, interoperability with academic and industry partners, and the digital tools required for modern clinical trials. The Million Veteran Program depends on secure, scalable data systems; without IT investment, the data VA has collected over decades cannot be fully used.
The Consolidated Appropriations Act, 2026 (H.R. 7148, signed February 3, 2026) blocked agencies from imposing a flat indirect cost rate: Division B, Title II, § 224 bars NIH from developing or implementing a modified approach to its rate-setting provisions, and Division A, Title VIII, § 8146 does the same for DoD, which must continue applying negotiated rates under 2 CFR 200.414. Separately, NIH’s proposed 15% cap was enjoined in April 2025 and remains blocked following the First Circuit’s January 2026 ruling.
The protection is not permanent. Those provisions are appropriations riders carried on FY26 funds. They lapse at the end of the fiscal year unless the same language is written into the FY27 bill. Continuing that protection — not the original fight — is the live ask. There is also no VA-specific equivalent; NPCs are covered only through the NIH and DoD awards they administer.
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 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.
That compliance infrastructure is not optional, and it is already accountable. NPCs operate under statutory oversight at 38 U.S.C. §§ 7361–7366, VA Inspector General authority at § 7366(b), VHA Handbook 1200.17 governance requirements, independent annual audits, state nonprofit law, and an annual VA report to Congress — plus scrutiny from every federal and state agency whose funds they administer.
Research runs on three kinds of infrastructure: the systems it operates in, the legal authority that defines what NPCs may do, and the programs that keep VA at the frontier of Veteran care. All three are lagging at once.
Research workflows — patient flagging, trial data capture, investigational drug orders, and consent — are not built into VA’s new electronic health record. When a site goes live on EHR Modernization, research capability can regress overnight. Research requirements need to be designed into the system, not retrofitted after each deployment.
VA research space carries real deferred maintenance, including Priority 1 health and safety deficiencies. This is what the $200 million major and minor construction request addresses.
VA’s SAIL scorecard does not measure research, so research is squeezed first when a medical center is under pressure. Adding research indicators — trials offered, enrollment, funding secured, and facility condition — would make the research mission visible in the same system that drives facility priorities, and give Congress a way to see which sites are protecting it.
NPC authority was established in 1988 for research (Pub. L. 100–322) and broadened in 1999 to cover education as well (Pub. L. 106–117). It has not been broadened since. Technology transfer, commercialization, and public-private partnership models all sit outside it. Without licensing authority, VA inventions do not reach Veterans at scale, and royalties do not flow back into VA research to fund the next discovery.
The GLP-1 story started exactly this way — a VA discovery that became a class of drugs now used by millions. Expanding NPC authority is how VA captures the next one on behalf of the Veterans who made it possible.
On July 28, 2026, VA opened recruitment for the Cessation or Reduction of Alcohol Consumption in Veterans (CRAVE) trial, testing whether semaglutide — a GLP-1 receptor agonist — reduces drinking in Veterans with moderate to severe alcohol use disorder. It is the closing of a 34-year loop: the GLP-1 class traces to a 1992 VA discovery, and VA is now running one of the first large randomized tests of that class against addiction.
The trial follows VA’s own evidence base: a March 2026 analysis of VA health records covering 606,434 Veterans with type 2 diabetes found GLP-1 use associated with lower substance use disorder risk and fewer addiction-related hospitalizations. More than 400,000 Veterans carry an alcohol use disorder diagnosis. That sequence — national VA data generating the hypothesis, a VA multi-site trial testing it — is a study design no other health system in the country can run. VA news release.
VA currently runs roughly 20 psychedelic-assisted therapy trials. A VA-HHS five-year memorandum of understanding signed July 13, 2026 fast-tracks that work — expanding trials, training clinicians, and sharing data with the FDA.
We can connect your office with NPC Executive Directors and staff to learn more.
Contact NAVREF Visit navref.org![]() 1717 K ST NW Suite 900 Washington, DC 20006 admin@navref.org 703-202-8113
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