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Doing Research at the VA

 

Background

UC Irvine has signed an agreement with the Southern California Institute for Research and Education (SCIRE), the nonprofit research foundation established at the VA Long Beach Healthcare System (VALBHS), to recognize and encourage research endeavors at the VA facility. A key provision of this agreement allows SCIRE to administer grants and contracts when the research conducted in VA facilities is responsible for more than 50% of the direct costs.

This agreement establishes new requirements for proposal review and reporting that should not unduly delay the submission of proposals, however, it does require coordination among staff from the involved School of Medicine departments, the School of Medicine Dean's office and the Office of Research Administration -Sponsored Projects. The agreement provides for SCIRE to issue Personnel Assignment Agreements to UCI in order to continue salary and benefits for UCI employees who will perform research at the VA; this process involves the Academic Personnel office.

Summary

The VAMC Long Beach has established the Southern California Institute for Research and Education, a non-profit public benefit corporation, to "accept gifts, contracts and grants from and enter into contracts with individuals and public and private entities solely to facilitate approved biomedical, prosthetic, rehabilitative and other health-care services research and education conducted by the VA Long Beach Healthcare System." On April 2, 2003, UC Irvine and SCIRE signed an agreement covering research relationships of their personnel. This agreement approves an exception to the December 15, 1994, UC policy requiring UCI employees to submit proposals through and have awards received by UCI regardless of where they are working. Additionally, the agreement requires UCI faculty and staff holding VALBHS appointments to direct certain research and education funding to SCIRE as a condition of using VALBHS space and facilities.

Key Points of the April 2, 2003, agreement:

Unlike the existing affiliation agreement with the VALBHS covering educational activities and the placement of medical students at the VA site, the April 2, 2003, agreement between UCI and SCIRE governs research activities and should be used regardless of whether or not students are involved.

SCIRE will administer projects that have the majority of activities conducted in SCIRE assigned space. This determination will be made by the parties based upon the expenditure of more than 50% of the project's direct costs, excluding equipment. Documentation of this determination will be maintained by SCIRE. If primary location of the work changes during the project period, SCIRE will relinquish the project to UCI if requested and as approved by the sponsor. Subawards will be used by the parties if a substantial portion of the work is to be conducted independently by an investigator at the other site.

Each UCI employee working on a SCIRE project will receive a Without Compensation appointment from VALBHS. When agreed upon by UCI, SCIRE and the employee, a Personnel Agreement may be used for SCIRE's payment of a UCI employee's salary and benefits, plus overhead.

UCI will continue to administer:

  • existing research awards until renewal
  • all NIH "K" awards
  • all training grants
  • program project components conducted at UCI
  • awards restricted to academic institutions
  • awards conducted >50% at UCI
  • clinical trials conducted >50% at UCI
  • gifts designated for UCI and the UCI Foundation

Memorandum of Understanding Under NIH Awards

Under National Institutes of Health (NIH) policy, a Memorandum of Understanding (MOU) is required of all investigators who hold joint appointments at a VA and an affiliated university (UCI) in order to obtain research or training awards from NIH. The MOU documents the amount of the appointment at each institution, the responsibilities of the proposed investigator, and the percentage of effort available for research. The joint VA/UCI appointment constitutes 100% of his or her professional responsibilities.

The form must be updated and signed annually by representatives from the VA and UCI, even if one of the appointments is a Without Compensation (WOC) basis, and is required when the NIH grant is received by UCI. VA foundations, such as the Southern California Institute for Research and Education, are not required to file a MOU for grants they submit to NIH. More information on this requirement can be found in the NIH Grants Policy Statement, Part II, Subpart B.

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