The document, published by the Council on Governmental Relations in 2010, provides a comprehensive analysis of the complexities associated with faculty joint appointments between academic medical centers (AMCs) and the Department of Veterans Affairs (VA). The report emphasizes the mutual benefits of such affiliations, noting that they foster research innovation, enhance medical education, and improve patient care for both veterans and the broader public. However, it highlights significant administrative and regulatory challenges, particularly regarding compensation, effort reporting, dual compensation concerns, and differing standards for workload measurement between universities and the VA. Central to these issues is the dichotomy between the VA’s hours-based workweek (typically 40 hours) and universities’ reliance on percentage-based effort reporting, as prescribed by federal cost principles such as OMB Circular A-21.
The document details the federal guidance governing joint appointments, particularly in relation to compliance with NIH funding requirements, and underscores the importance of Memoranda of Understanding (MOUs) to clarify responsibilities and prevent conflicts of interest or dual compensation. While the paper acknowledges improvements in clarity—such as NIH’s policy adjustment for career development awards that allows primary reliance on the appointment at the applicant organization—it also points out inconsistencies and ongoing ambiguity in federal expectations, especially as they pertain to different types of NIH grants. The Council advocates for flexible, institution-specific approaches to defining reasonableness in joint appointments, and calls for ongoing, constructive dialogue between federal agencies and research institutions to ensure administrative practices align with both regulatory requirements and the practical realities of academic medicine. The report concludes that effective management of university-VA joint appointments is crucial to the continued success of the nation’s research and healthcare missions, and cautions against imposing rigid administrative burdens that could discourage participation in federally funded research programs.
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