General Guidance
The Executive Director, President, or designee and the Treasurer of the Board are the only officials authorized to commit the expenditure of VBRI funds.
If it is unclear whether any item or service should be paid by VBRI, the Executive Director will determine the appropriateness of the request. Disagreement can be appealed to the Board of Directors.
Purchases considered to provide personal benefit are not allowed. Please note that some of the IRS rules in this area are not intuitive. VBRI will try to provide guidance, but final authority for payment rests with the Executive Director or President. Please review this section for guidance or discuss the proposed purchase with VBRI before ordering.
Purchases that may give the appearance of a conflict of interest are not allowed.
The following requirements apply for all purchases:
1. Sufficient funds must be available in the requester’s account to cover costs.
2. A research rationale must be provided for each research-related purchase, or for education activities the expense must be within the scope of the proposal as approved by the EC.
3. Professional licensure payments are not allowed. Costs of CME credits cannot be paid.
Payment or Reimbursement Details
1. Investigators may give signature authority to designated individuals on their VBRI accounts. The authorization may include dollar limits on the purchasing authority. VBRI will periodically review the signature authority on investigators’ accounts.
2. All Check Request and Travel Reimbursements must be accompanied with original receipts. Photocopies or facsimiles are not acceptable.
3. All requests for payment or reimbursement should be made in a timely manner. NOTE: VBRI reserves the right to deny payment for invoices held for more than 90 days.
4. VBRI is exempt from state sales tax. If sales tax is charged, VBRI is not allowed to pay unless extenuating circumstances persist.
Specific Guidelines
- It is recommended that purchases greater than $25,000 be submitted for competitive bid. Competitive bids are required for purchases of $100,000 or more.
- Subscriptions must indicate a business, not a residential, address for delivery, or a credible explanation be provided.
- Certain memberships and dues may be paid/reimbursed through VBRI. For research oriented memberships, the organization must have a research focus demonstrated by provision of a research journal(s) and/or scientific meetings. Payment of such memberships and dues is predicated on the membership providing a journal or other subscription that would be at a much higher cost to non-members possibly in excess of the total membership if purchased separately. In some cases, organization journals are not available to non-members. Alternatively, a relevant research membership may provide access to the annual research meeting at a significantly reduced membership rate to justify membership as the prudent business decision.Unless the membership/subscription is obviously beneficial to the approved education projects, prior approval of the Education Committee is required for educational memberships/subscriptions without research relevance. Educational subscriptions must show a benefit to VA or VBRI employees or to VA patients
If the subscription rate or annual meeting costs are not sufficiently reduced, VBRI may not be able to pay for these expenses.
- No expenditures will be authorized for donations to organizations engaging in general charitable or other philanthropic activities unrelated to research conducted at the VANJHCS.
Individual Expenditures Exceeding $25,000
An investigator’s request for expenditure of funds for amounts greater than $50,000 during any 30-day period shall require 60 days’ prior notification and VBRI approval.
Exceptions may be granted in an emergency by the concurrence of the Executive Director and the Treasurer.
Funds for payroll costs (including properly executed personnel agreements) are excluded from this policy.
Furthermore, an approved transfer of funds for continuing research projects or educational activities in excess of $25,000 from VBRI to another 501(c)(3) organization may require a longer period of time to complete. Depending on the specific situation, transfers may be made on a quarterly basis.
Purchasing Procedures
Orders may be placed by either Principal Investigators, or an authorized designee.
Appropriate forms, i.e., Purchase Requisition forms, Purchase Order numbers, and Signature Authority can be obtained from the VBRI Administrative office.
A VBRI purchase order (PO) is required for all purchases made using VBRI vendor accounts. VBRI maintains accounts with many vendors. A list of current vendors is available from the accounting office and on the VBRI website.
The VBRI accounting office will establish and approve new vendor accounts in advance of the purchase. Please contact the accounting staff with the vendor information. You will be contacted once an account has been set up with the new vendor.
An authorized signer on the VBRI account must sign the PO. The signed PO serves as authorization for payment by VBRI upon receipt of the invoice from the vendor. Fax the completed, signed order request to the VBRI office at 973-677-7683, and provide the original form to the VBRI office as soon as possible.
Receipt of incoming packages must be verified, inspected for damage, defects or errors and identified by the information available on the packing slip included in the order. The packing slip must be endorsed and sent to the VBRI accounting office. Please note discrepancies or damaged items on the packing slip. This process will serve as documentation to verify discrepancies between items ordered and items shipped.
If a packing slip is not provided, a Packing Slip Replacement form must be completed.
VBRI will issue payment for the order upon receipt of the vendor invoice matching the authorized PO and packing slip or Packing Slip Replacement form.
Purchase Reimbursements
A completed, signed Check Request Form should be submitted to VBRI to initiate payment to a vendor in cases when a purchase order is not appropriate. All Check Request Forms must be accompanied with original receipts.
Credit Card Procedures
Business credit cards are to be used for Veterans Bio-Medical Research Institute business purchases only and are not for personal use. Use of the card for charges other than official, research or education related business is a direct violation of this contract and is misuse of a VBRI- issued card.
It is the sole responsibility of the business credit card holder to provide the office of VBRI with any and all receipts pertaining to card use in a timely manner. Any receipts not received can result in the card holder having to reimburse VBRI for the amount of the item for which the receipt pertains.
Users must ensure project accounts have the necessary funds available in order to cover any purchase made using this card. Any purchases over $2,500 require advance approval by the Executive Director or Board President.
Any finance charges and/or late fees arise due to negligence on the card holder’s part, are the responsibility of the card holder.
Unallowable expenses include, but are not limited to the following:
- Video purchases/rental not related to research/education
- Clothing, boots, shoes, accessories not related to research/education
- Alcohol, tobacco and firearms
- Personal prescriptions
- Tires, automotive repairs and maintenance for personal vehicle
- Gasoline charges for personal vehicle
- Personal gifts
- Department store charges for personal items
- Cell phone accessories not business-related
- Household products, goods and decorations not related to research/education
VBRI business credit cards are institutional property and must be used with good judgment. Card holders agree to accept responsibility for safekeeping of the credit card and that theft or loss of the card, or fraudulent charges, will be reported to the VBRI office immediately.
Use of VBRI business credit cards can be revoked at any time if card holders do not comply with VBRI credit card policy.
Supplies
Laboratory supplies (including animals) and research office supplies may be purchased with research rationale provided.
Supplies purchased for an educational activity must be within the scope of the activity as approved by the Education Committee.
Laboratory Animals
The Animal Research Facility (ARF) supervisor or the Veterinary Medical Officer (VMO) must approve in advance any animal orders that are to be delivered to the VA. Approval must be obtained before the order is placed with the vendor. This policy is to assure that only animals for which there is an Animal Care Committee approved protocol are ordered; that an acceptable vendor is used; that space and caging are available; and that, should an expected order not arrive, it can be immediately investigated.
To obtain approval, you may send an email message to the VMO or ARF supervisor. An approval response will be sent back to you. You may also contact the VMO or ARF supervisor by phone for approval. However, leaving a voice mail message is not sufficient. An email message and response will provide confirmation that the order is approved.
The request must include the following information:
- Principal Investigator
- Protocol number (IACUC number)
- Species of Animal
- Strain
- Quantity
- Age or Weight
- Sex
- Vendor
- Source of Funds (VBRI)
- Any special housing or care instructions
- Date of Arrival
- Contact person/phone number
- VBRI purchase order number
Please contact the ARF Supervisor if you have any questions about this policy.
Radioactive Materials
The preferable method for purchasing radioactive substances is to order through the VANJHCS.
In those cases where VBRI is used, the following should be done:
- The radioactive material must be under the site license. Check with the Radiation Safety Officer (RSO) prior to ordering any material to verify.
- Clearly note on every order that delivery should be to the RSO.
- The investigator name should appear as user so the RSO will know where to send the supplies after the material is checked.
- The RSO must be notified by telephone whenever radioactive material is ordered. Notification must include the PI’s name, isotope, quantity, and expected delivery date.
- Please inform the RSO that this order is for VBRI and supply the RSO with a VBRI purchase order number.
Electronic Devices
VBRI funds may be used to purchase desktop and notebook computers for use in or support of VA-approved research. Purchase in support of an educational activity must be within the scope of the proposal as approved by the Education Committee for all education activities.
All computers purchased must be shipped to the VBRI Office c/o the investigator. Once received the equipment must be tagged by IRM with the appropriate VA form completed as above before it is released for use.
Computers purchased with VBRI funds may in turn be donated to the VA for use unless this is specifically forbidden by the sponsor. Forms for this donation would indicate “equipment put in VA use” on the VBRI website. Specifically, this can not apply for items purchased with Federal Funds.
VBRI funds may not be used for the purchase of cell phone equipment unless specifically approved by the Board of Directors. In general it is not allowed.
Other specialty devices or electronic items such as digital cameras may have a valid research rationale, but due to the potential personal use should be pre-approved before purchase and with written justification.
Policy on Portable Computing Devices
VBRI funds may be used to purchase portable computing devices (such as laptops, netbooks, notebooks and electronic pads) for use in support of VA-approved research and/or education. To purchase a portable computing device, a specific rationale that explains the business need must be provided. Purchase in support of an educational activity must be within the scope of a project as approved by the Education Committee for all education activities.
VBRI-purchased computing devices must either be 1) encrypted and managed on a VA Equipment Inventory List (EIL), in compliance with VA Handbook 6500, or 2) managed through VBRI policy and may not be used to store VA data or linked to the VA network.
VA-managed devices: VA requirements for information security outlined in VA Handbook 6500 apply to non-VA purchased and non-VA owned IT equipment used for VA research purposes if the equipment will be used to store VA-sensitive information or may connect to a VA network. Portable computing devices, such as laptop computers, used to store VA sensitive information or that may be connected to a VA network, must be encrypted in compliance with VA Handbook 6500.
VBRI-managed devices: VBRI-purchased portable computing devices will be managed only on the VBRI inventory list and do not require VA encryption if the following requirements are maintained:
- The device will not store VA data
- The device will not be connected physically to the VA network. The device may be connected via Citrix Access Gateway (CAG) Virtual Private Network (VPN) connection to the VA network remotely, with appropriate authorizations.
- The device will not connect directly to a VA computer/equipment.
Portable devices purchased by VBRI are the property of VBRI. They do not become the property of the investigator for whose use it is purchased. Funding for requests for purchase of portable computing devices to support research or education activities must be derived from available grant or other funds held in VBRI and must be an allowable charge on active grants. All users must submit a signed certification of the appropriate use of portable computing devices indicating understanding of relevant VBRI and VA policies and procedures and commitment to comply.
VBRI will track, inventory and manage portable devices and they will be subject to regular physical inventory and content review.
When an individual no longer requires the use of a VBRI-owned device or leaves the facility, the device must be returned to VBRI. Obsolete and non-functioning equipment also must be returned to VBRI.
Certification by User of Requirements for Portable Computing Device
User Name:______________________________ Date: ________________________
Description of Equipment/Device: _________________________________________
All users of VBRI-purchased portable computing devices must complete and sign this certification indicating understanding of relevant VBRI and VA policies and procedures.
- I agree to use the equipment/device for VA-related research or education purposes only. Examples of this could include: Non-business hour VA work locally or during travel by connecting device to VA network via CAG VPN Travel to research-related or educational meetings requiring the need to access presentations or other materials while connected to VA through CAG VPN or using VA-approved and encrypted USB drive
- I will ensure that the equipment/device will not contain any VA sensitive data, will not connect physically to the VA network on VA grounds, and will not connect directly to VA computers/equipment.
- I understand the equipment/device is subject to recall by VBRI on 24 hour notice for inspection and content review.
- I understand the equipment/device will remain the property of VBRI.
- I understand I am responsible for all activities related to the use of this device and personally liable for any misuse or unapproved use.
- I have reviewed VA Handbook 6500 on VA Data Security, and VBRI’s policy and certification on Portable Computing Devices and I agree to the terms within.
Donation of Animal Purchases and Expendable Supplies to VA New Jersey Health Care System
The mission of VBRI, established under Public Law 100-322 dated May 20, 1988, is to facilitate research carried out as a part of the Veterans Health Administration for the medical care and treatment of veterans and includes biomedical research, mental illness research, prosthetic and other rehabilitative research, and health-care services research. To this end, VBRI utilizes the facilities and the review and reporting mechanisms of the VANJHCS to comply with the law.
Research and development activities supported by funds administered by VBRI may involve the use of animal subjects. The VANJHCS Animal Care and Use Committee established in accordance with Federal law reviews all such studies. Only studies approved by this committee and its parent VANJHCS R&D Committee are conducted. The animal research program and facilities are accredited by the American Association for the Advancement of Laboratory Animal Care (AAALAC); a current Assurance is on file with the NIH Office for Laboratory Animal Welfare; the program is appropriately registered with the US Department of Agriculture.
Within the requirements of the law, and in order to eliminate duplication of registration, review and reporting activities, it is VBRI policy that any animals purchased by VBRI for the purposes of research are immediately upon receipt donated to, and become the property of, VANJHCS.
Within this framework VBRI also utilizes VANJHCS resources for such activities as handling and removal of medical and laboratory waste, including radioactive materials and other hazardous or controlled materials. In order to ensure conformance with requirements of the law and to eliminate duplication of activities, it is VBRI policy that all expendable supplies purchased by VBRI that are to be used in VA research laboratories for VA-approved research and educational activities are immediately upon receipt donated to, and become the property of, VANJHCS.
SUBJECT PAYMENTS
Subject payments and reimbursements to patients and volunteers for their participation in a study must be issued in accordance with the IRB and the R&D Committee approvals for the project.
For all such participation payment or reimbursements, appropriate language must be in the human subjects consent form or Health Insurance Portability and Accountability Act (HIPAA) addendum to notify the participant that the individual’s Protected Health Information (PHI) will be released to VBRI in order to process such payments. If the study will require release of PHI to VBRI in order to pay for diagnostic tests not available at VANJHCS and obtained from outside vendors for the participant, the consent form should also include this information.
Subject participation payments are taxable income. Individuals receiving payments of $600 or more in a given calendar year will be sent an IRS 1099-MISC form. VBRI therefore requires the Social Security Number and permanent mailing address of each individual to whom subject payments are made.
NOTE: The $600 threshold does not include reimbursement of costs (e.g., travel) to study participants.