INTRODUCTION

Mission

The main mission of the Loma Linda Veterans Association for Research is to support VA-approved research. The Veterans Health Administration (VHA) is required to conduct a program of medical research (including health services and rehabilitation research and development) in order to carry out more effectively its primary function of providing a complete medical and hospital service for veterans and to contribute to the Nation's knowledge about disease and disability.

SEPARATE EMPLOYERS

LLVARE employees work in various physical locations, including off-site locations, but, as LLVARE employees, their employment always relates to a VA-approved activity.

In order to perform their jobs with LLVARE, all LLVARE employees are required to have an active Without Compensation (“WOC”) appointment at the Pettis VAMC/Loma Linda VA Healthcare System (LLVAHS). Such appointments provide LLVARE employees some of the benefits and responsibilities of employment at the Pettis VAMC. Accordingly, although LLVARE employees report to and are subject to the control of LLVARE as their employer, when LLVARE employees work at the Pettis VAMC (including off-site locations), they are also required to follow the VAMC institutional policies relating to personal conduct, safety, and the conduct of research activities.

LLVARE employees often work side by side with employees of Loma Linda University and the Pettis VAMC/Loma Linda VA Healthcare System. Work policies of these employers differ slightly from LLVARE. If questions arise in the course of your employment because of differences in treatment of employees, please refer these questions to the LLVARE Human Resources Department.

CONFIDENTIAL INFORMATION

As a LLVARE employee, you will at some time or another come to possess or have access to confidential information. This may include study data, patient identifiers, results, access to VA computer records or databases or another company’s proprietary information. It is your responsibility to keep this information confidential even if you are no longer employed at LLVARE. An employee who discloses confidential information will be disciplined up to and including termination and may expose themselves to legal action. If inquiries are made from outside LLVARE/VA LLHS, you should direct all questions to your supervisor or the Executive Director of LLVARE or the Administrative Officer of the Office of Research Administration.

STANDARDS OF CONDUCT

We expect each employee to contribute to the quality and reliability of LLVARE within the scope of his or her job responsibilities. Failure to meet this standard of performance may be the basis for adjustment in compensation or disciplinary action, up to and including discharge. All LLVARE employees are subject to federal statutes and regulations applicable to federal employees with respect to conflicts of interest in the performance of official duties. At the time of hire, and annually thereafter, each employee signs and submits to LLVARE a "Standards of Ethical Conduct and Related Responsibilities of Employees" statement certifying awareness of, and compliance with, these laws and regulations.

38 U.S.C. § 7366 (c)(2) requires that each employee must certify that he or she will comply with the federal laws and regulations applicable to Federal employees with respect to conflicts of interest, and receipt of such certification is a condition of employment with LLVARE. The Standards of Ethical Conduct are codified in 5 CFR Part 2635 and a synopsis of these standards is contained in this document as Appendix D.

Employees may not accept meals or other gifts of more than a nominal value from salespeople, vendors, suppliers, or any other solicitors.

We expect employees to avoid situations that may cause their personal interests to conflict with the interests of LLVARE or to compromise its reputation or integrity. A conflict of interest, or the appearance of one, occurs when you or a member of your immediate family uses your position with us for personal benefit through an investment, association, or business relationship that interferes with your ability to exercise independent judgment on our behalf. Disclose any unavoidable conflicts of interest to your supervisor.

We will take appropriate action based on the seriousness of the situation and the circumstances. Discipline less than termination may take the form of an oral warning, a written warning, probation, or suspension. Which of these options is chosen, or whether any of them is used prior to termination, will depend on the situation. The evaluation of the facts will be made by supervisors and LLVARE’s Executive Director.

COMBINATION EMPLOYMENT AT LLVARE AND THE VA

Any LLVARE-paid work must be performed outside the VA tour of duty and documented as such. The work performed by the LLVARE employee must be outside the scope of the federal employee’s government-paid work.

If there is a question about this complicated issue, please contact the LLVARE Manager of Human Resources.

EMPLOYMENT AND REGULATORY REQUIREMENTS

LLVARE employees must be in good standing with all compliance requirements of the VA. This includes anything necessary for ongoing WOC appointments, specialized training in the area of research, and any new requirements that may be needed. This must all be completed, updated, or renewed within the time frame required by the VA or the employee will be terminated. Reinstatement is not guaranteed but could only occur after all the VA compliance requirements have been met and this can be verified. In addition, federal projects or pharmaceuticals may have additional requirements relating to compliance. For a LLVARE employee to work on any of these projects the compliance requirement must have been met prior to his/her involvement on the project.

We are governed by the LLVARE Board of Directors but receive our authority to work on projects through the R&D Committee approval process. No LLVARE employee may participate in any study, project, etc. that has not been approved by the VA R&D Committee. Should a project involve human studies, IRB approval and R&D approval is necessary for a project to begin. In cases where the LLVARE employee is working administratively to initiate a project, the date of submission to the IRB Committee, IACUC, and R&D Committee is required. While paperwork is required to initiate a project through the committees, that will be the only acceptable work done until all committee approvals are obtained. Should the project approval expire, all work on the project must cease until a continuation has been granted by the VA R&D Committee. Should the VA change the requirements for a project to be approved or for approval to continue, all projects under LLVARE and all employees of LLVARE would then be required to follow any new procedure.