This document, authored by the Council on Governmental Relations, examines the complexities and federal policy considerations involved in joint faculty appointments between universities—particularly academic medical centers (AMCs)—and the Department of Veterans Affairs (VA). The report outlines challenges associated with compensation, effort reporting, and compliance when faculty hold appointments at both a university and a VA medical center. A significant issue addressed is the inconsistency between universities’ use of percentage-based effort metrics and the VA’s preference for hours-based reporting, which can result in confusion and administrative burden, especially in the context of federal research grants (notably from the NIH). The report emphasizes the essential role of clear, regularly updated Memoranda of Understanding (MOUs) to document responsibilities and effort allocations, and reviews the relevant federal regulations, including OMB Circular A-21 and NIH Grants Policy Statements, which mandate that university effort and compensation be managed according to university-defined practices, not combined with external entity requirements.
The document further discusses the implications of dual compensation rules, the use of clinical practice plans, organizational relationships with non-profit VA research institutes, and the application of these principles across various grant mechanisms. Notable is the recommendation to base effort commitments and compensation solely on university appointments, except where federal policy explicitly dictates otherwise—arguing that a flexible, institution-specific approach to “reasonableness” is required. The historical context of VA-university affiliations is also presented, detailing their legislative foundation and the extensive collaboration between academic and VA institutions. The report concludes by advocating for continued constructive dialogue between federal agencies and universities, with the aim to harmonize policy interpretation and administrative practices, minimize unnecessary barriers to joint appointments, and ensure that the nation’s interests in high-quality research, education, and veteran healthcare are best served.
