Policy on VMRF Fund Administration for Research, Education, Donations, and Transfer Funds

A. Background
VMRF serves as a funding mechanism for VA research and education activities and collects appropriate Indirect Costs (IDC) for infrastructure support and administration at the Veterans Affairs San Diego Healthcare System (VASDHS). Indirect costs are general costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project activity or other institutional activity.  The VASDHS Research & Development committee must approve all research projects administered by VMRF before research funds can be released; the VASDHS Education committee must approve all education activities administered by VMRF before education funds can be released. In addition, VMRF entered into an Affiliation Agreement with the University of California, San Diego establishing certain policies for grant administration.  VMRF was established as a 501 (c) (3) organization and is authorized to accept outside funding in its own name, including from other Federal sources and maintains an appropriate internal controls and compliance environment.  VMRF is not an agent or instrumentality of the VA.   

B. VMRF Funds

1. VMRF funds can only be allocated to support VA approved research projects and/or education activities, or activities necessary to support the VMRF business functions, which may include fundraising expenses.  The VASDHS R&D committee must approve all research projects independent of the funding source even if self funded through VMRF donation or transfer funds.  Investigators should contact the VA Research Service Intake Desk for specific information on how to request VASDHS R&D approval for each of their research projects.

 

2. VASDHS R&D must also approve projects transferred from other VA Not for Profit Corporations (NPCs), even if those projects were previously VA R&D approved at their previous VA location.

 

3. On an exception basis, and at the financial risk of the individual principal investigator, researchers may wish to spend expected funds for “preparatory expenses”.  This usually refers to staff expenses to offset effort spent on compliance processes to formally start the project’s activities.  Permission for “preparatory expenses” must be requested in writing from the CEO and are different from what the National Institutes of Health (NIH) consider “preaward spending”.  For more information, investigators are encouraged to contact their assigned VMRF C&G administrator.

 

4. VMRF acceptance of restricted and unrestricted funds transferred from UCSD, a UC Foundation or any other NPC are subject to VMRF IDC collection contingent upon the nature of the transfer.  Transfer of funds from a different institution to VMRF require at a minimum a formal statement from the transferring institute to VMRF, requesting VMRF acceptance of these funds.  The formal request may be sent to the VMRF CEO for consideration.

 

5. All VMRF projects will be charged the prevailing VMRF indirect cost rate.  The Board approved indirect cost rates are periodically updated at http://www.vmrf.net/services/cg/ref-sheet-grants.html.  VMRF’s cognizant agency is the Department of Health and Human Services (DHHS), which is the organization with which VMRF negotiates its Federally approved Indirect Cost Rate.  VMRF’s indirect cost rate is assessed on a Modified Total Direct Cost (MTDC) basis.  Exceptions to the IDC rate applied to a project must be requested in writing from the VMRF CEO.

 

6. The Principal Investigator is the individual with responsibility for the technical, administrative, and fiscal management of a project. The investigator should review the account ledgers to certify that all costs charged to a contract or grant specifically benefit the project being charged. Without VMRF approval, in the event of overdraft, the investigator must identify unrestricted funds to cover the overdraft or provide a personal check payable to the corporation.

 

7. Bona fide private donations may be accepted up to $1,000 without IDC, and at 4% for all funds over $1,000 per year.  Donations will be reviewed by the CEO so appropriate recognition is given to the donor and all compliance steps are made in the most expedited and customer friendly manner.  A gift-donation must be accompanied by a letter from the donor indicating that the check represents a gift to be used by VMRF or the investigator in support of research programs. Further, the letter should indicate that the gift is irrevocable and does not impose contractual requirements on the corporation beyond the reporting of research results. VMRF will provide acknowledgment of receipt of the gift by letter to the donor.  VMRF reserves the right not to accept a donation made to VMRF.

 

8. VMRF cannot accept donations in lieu of honoraria, consulting fees, expert witness fees, or editorial/writer’s fees.  

 

9. All checks must be made out to the VETERANS MEDICAL RESEARCH FOUNDATION. The federal tax identification number is #33-0189397.  All checks accepted for deposit represent corporate income and are not to be used for personal benefit of any investigator or VMRF staff. All interest earned remains with the corporation.

 

10. If an investigator looses qualification  as a VMRF investigator, or resigns from VMRF, all unrestricted funds remaining after all outstanding obligations have been met will revert to the corporation. Restricted funds (e.g. ongoing projects) are bound by contractual regulations with the sponsor which will determine the fate of the funds (e.g. transferability or naming of a new PI).  For transfer, the investigator must provide documentation from the new organization verifying their tax exempt status, the investigators affiliation and qualification as an investigator, and the funding organization (sponsor) must approve transfer.

Approved by the VMRF Board of Directors: September 30, 2010