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3.3 Workplace Points of ContactAdditional information regarding when and how to reach out to these points of contact can be found in Points of Contact(Section 7).TOPICStandards of Ethical Conduct forEmployees of the Executive BranchPrivacyDiscrimination, Harassment andDispute ResolutionOccupational Safety and HealthPOINT(S) OF CONTACTSECTION LOCATIONOGC Ethics Specialty Team7.1Privacy Officer, VHA Office of PrivacyHarassment Prevention ProgramCoordinator (HPPC), EEO Managers,Office of Resolution ManagementOccupational Health Services7.67.37.103.4 Workplace Questions and AnswersExample scenario regarding harassment:Bill sometimes makes comments to his administrativeassistant Ann Smith about how attractive she is. She neversays anything when he makes these comments. One day,Ann requests a raise. Bill says that he will consider herrequest and suggests that the two of them go for drinksand to dinner after work. Ann makes it clear that shewants to keep their relationship purely professional andwould therefore prefer not to go out with him. Bill saysthat he understands. Two weeks later, Bill informs Annthat he has denied her request for a raise. She asks Bill5DEPARTMENT OF VETERANS AFFAIRSfor an explanation, and he says that if she would be more“cooperative” with him, then her chance for a raise wouldimprove. Ann asks what does cooperative mean? Bill smilesand says, “You figure it out.”

SPEAK UP AND LISTEN UP3.4 Workplace Questions and AnswersQ: The other day, a co-worker told me a joke that hadmild sexual content. I was not offended by it, and we bothfound the joke funny. Today, we both got a memo from oursupervisor telling us that our conduct was inappropriateand a potential violation of VHA’s sexual harassment policy.Was the joke harassment?A: While one joke alone may not be harassment, it couldbe perceived as part of a hostile work environment. In thissituation, you need to remember that the question is notwhether you or the employee who told the joke was offended,but whether a "reasonable person" would find it offensive.Another employee must have overheard you and found thejoke offensive enough to report it, causing your supervisor tosend the memo. Not everyone you work with will share yoursame opinion as to what is or is not offensive. Be more carefulabout what you say at work.Q: One of the organization’s best workers has approachedyou with a problem. She is being hit on by her departmentsupervisor, but she doesn’t want you to do anything. Shejust wants it to be on record that she told someone. She ishandling the situation, and she asks you to promise not todiscuss the matter with anyone.A: Talk with an HR representative. You can promise that you willtry to keep the investigation as confidential as possible, but youcannot promise complete confidentiality.Q. Why might I contact a resource in health care ethics?A. Ask for a review of a document or proposal from an ethicsperspective. Ask for clarification or interpretation of ethicalaspects of a policy. Ask questions about topics in health careethics. Ask questions if they are not sure what is the ethicallyright thing to do.CODE OF INTEGRITY6

4.0 Integrity in Care for Veterans and in Conduct of Research4.1 General ConsiderationsIt is of the utmost importance that VHA follow ethical,scientific and clinical standards and comply with theapplicable laws, regulations and policies in delivering careto Veterans and in conducting research. Patient safety andpatient care rights are of paramount importance in decisionmaking. Additionally, VHA must protect the privacy andsecurity of personal information that is collected, usedor that is entrusted, respect the safety and quality of thecare provided to Veterans and monitor the research beingconducted. VHA must comply with all requirements forreporting adverse events.Acting with integrity when delivering care for Veterans or inconducting research, especially research involving Veteransas subjects, means understanding, modeling and honoringthe applicable laws, regulations and policies regarding thefollowing: 7Quality of CarePatients’ RightsPrivacy of InformationResearch & Scientific IntegrityCriminal Conflict of Interest LawsStandards of Ethical Conduct for Employees of theExecutive BranchStop the Line for Patient Safety InitiativePatient SafetyDEPARTMENT OF VETERANS AFFAIRS

SPEAK UP AND LISTEN UP4.2 Relevant Laws, Regulations and PoliciesNote that this list is not all-inclusive, as there may beadditional laws, regulations or policies that apply. VHA Directive 1004: National Center for Ethics in HealthCare VHA Handbook 1004.01, Informed Consent for ClinicalTreatments and Procedures VHA Handbook 1004.02, Advance Care Planning andManagement of Advance Directives VHA Handbook 1004.03, Life-Sustaining TreatmentDecisions: Eliciting, Documenting and HonoringPatients’ Values, Goals and Preferences VHA Handbook 1004.04, State-Authorized PortableOrders VHA Handbook 1004.05, iMedConsent VHA Handbook 1004.06, IntegratedEthics VHA Handbook 1004.07, Financial RelationshipsBetween VHA Health Care Professionals and Industry VHA Handbook 1004.08, Disclosure of Adverse Eventsto PatientsVHA Office of Research & Development 1200 SeriesPoliciesVHA Directive 1058.01: Research Compliance ReportingRequirementsVHA Directive 1058.02: Research Misconduct VHA Directive 6066: Protected Health Information (PHI)and Business Associate Agreements ManagementVHA Directive 1605.01: Privacy and Release of Information VHA Handbook 1605.03: Privacy ComplianceAssurance ProgramVA Directive 0009: Ensuring Quality of InformationDisseminated by VACriminal Conflict of Interest Laws, 18 U.S.C. §§ 201-209Standards of Ethical Conduct for Employees of theExecutive Branch, 5 C.F.R. Part 2635Limitation on Certain Physician Referrals, 42 U.S.C.1395nnHatch Act, 5 U.S.C § 7323 (Office of Special Counsel HatchAct Website)Guide to Government Ethics - Summary of the Laws andRules for VA Employees (for VA Employees only)CODE OF INTEGRITY8

4.3 Care for Veterans and Conduct of Research Points of ContactAdditional information regarding when and how to reach out to these points of contact can be found in Points of Contact(Section 7).TOPICPOINT(S) OF CONTACTStandards of Ethical Conduct forEmployees of the Executive Branch and OGC Ethics Specialty TeamCriminal Conflict of Interest LawsVA Police, VA Office of InspectorCriminal MattersGeneralVA Medical Facility ResearchResearch Non-ComplianceCompliance Officer, VHA Office ofResearch OversightLocal Ethics Point of Contact, NationalHealth Care EthicsCenter for Health Care EthicsPatient Safety Manager, The JointPatient Safety and Quality ConcernsCommissionPrivacyPrivacy Officer, VHA Office of PrivacyInformation SecurityInformation Security Officer9DEPARTMENT OF VETERANS AFFAIRSSECTION LOCATION7.17.27.87.97.57.67.7

SPEAK UP AND LISTEN UP4.4 Care for Veterans and Conduct of Research Questions and AnswersQ. What kinds of questions can ethics consultation helpanswer?A. An ethics consultation can help address situations like these: The Veteran’s family is confused and upset. They do notagree about what is the right thing to do for the Veteran’scare. Can VA help? The Veteran is too sick to make her own decisions. Howshould the surrogate decide what is best for the Veteran?Q. Can I have an ownership interest in the company that willcommercialize my invention(s) and engage in VA researchor outside research that would affect the marketability ofthose inventions?Q. I am researcher at a VA facility and have a question aboutVA research policy and VA research funding. I also havea concern about potential noncompliance involving thereview and approval of research at my facility. Who should Icontact?Q. I have an academic appointment at the affiliatedteaching hospital. Can I sign-off on the affiliate’s grantapplication to NIH?A. If you feel comfortable raising your question and concernlocally, you can reach out to research administrative personnelat your facility or follow local requirements for reportingresearch concerns. If you are concerned about reaching outlocally, questions about VA research policies and funding maybe directed to the VHA Office of Research & Development.Concerns about potential noncompliance involving VA researchmay be reported to the VHA Office of Research Oversight.Q. I am a principal investigator, co-principal or otherinvestigator on VA research. How do I disclose intellectualproperty rights or other financial interests which might beaffected by the research?A. Such interests are reported on a Research Financial Conflictof Interest Statement (VA Form Alt 450), which is submitted tothe Research & Development Committee.A. No, but you may assist in the commercialization of yourinvention under a Cooperative Research and DevelopmentAgreement.A. No, you may perform research on behalf of the affiliate andprovide updates to the affiliate regarding the progress of thatresearch, but you may not sign-off on the grant application.Doing so would violate criminal conflict of interest law becauseyou would be representing a non-Federal party before aFederal agency in connection with a matter in which the UnitedStates is a party and/or has a direct and substantial interest. 18U.S.C. §§ 203, 205.Q. Do I need to report all my inventions to VA?A. Yes, you must report it to the Technology Transfer Programand any other programs referenced throughout this document,even if the invention did not result from your VA research,regardless of when and where you made the invention.CODE OF INTEGRITY10

5.0 Integrity in Financial Matters and Asset Protection5.1 General Considerations5.2 Relevant Laws, Regulations and PoliciesVHA’s property, assets and confidential and proprietaryinformation must be protected. All employees areresponsible for safeguarding this information. It is essentialto complete accurate financial records that fairly representthe work you perform. While there are multiple controls inplace to protect and preserve financial integrity and assets,VHA employees must be diligent to maintain the trust andconfidence of Veterans and other beneficiaries. Acting withintegrity in financial matters and asset protection meansunderstanding applicable laws, regulations and policiesregarding the following:Note that this list is not all-inclusive, as there may beadditional laws, regulations or policies that apply. 11Coding and Billing for ServicesAccuracy of RecordsFalse Claims ActFinancial Reporting and RecordsUse of Time, Equipment and Proprietary InformationProtection of Confidential InformationFraud, Waste and Abuse (FWA)Use and Security of VHA AssetsStandards of Ethical Conduct for Employees of theExecutive BranchCriminal Conflict of Interest ProhibitionsDEPARTMENT OF VETERANS AFFAIRS VA Directive 6300: Records and Information ManagementVHA Directive 1030: Compliance and Business IntegrityOversight ProgramVHA Directive 1733: VHA Finance Quality AssuranceReviewsVA Directive 6001: Limited Personal use of GovernmentOffice Equipment Including Information TechnologyVA Directive 6500: Managing Information Security Risk:VA Information Security ProgramVHA Handbook 1004.07: Financial Relationships BetweenVHA Health Care Professionals and IndustryCriminal Conflict of Interest Laws, 18 U.S.C. §§ 201-209Standards of Ethical Conduct for Employees of theExecutive Branch, 5 C.F.R. Part 2635Hatch Act, 5 U.S.C § 7323 (Office of Special Counsel HatchAct Website)Guide to Government Ethics - Summary of the Laws andRules for VA Employees (for VA Employees only)Procurement Integrity Act, 41 U.S.C. §§ 2101-2106, 48C.F.R. § 3.104, Subpart 3.104

SPEAK UP AND LISTEN UP5.3 Financial Matters and Asset Protection Points of ContactAdditional information regarding when and how to reach out to these points of contact can be found in Points of Contact(Section 7).TOPICPOINT(S) OF CONTACTStandards of Ethical Conduct forEmployees of the Executive Branch and OGC Ethics Specialty TeamCriminal Conflict of Interest LawsVA Police, VA Office of InspectorCriminal MattersGeneralVHA Revenue Cycle Financial andIntegrity and Compliance Officer,Business OperationsOffice of Integrity and CompliancePrivacyPrivacy Officer, VHA Office of PrivacyInformation SecurityInformation Security OfficerLocal Fiscal Officer, Finance OfficerFinanceor Financial Manager or VHA ChiefFinancial OfficerSECTION LOCATION7.17.27.47.67.77.11CODE OF INTEGRITY12

5.4 Financial Matters and Asset ProtectionQuestions and AnswersQ. An employee performing a financial review identifiesthat the results of the review were not accurately reportedbased on the findings. What should the employee do?A. The employee should first discuss the finding with hisor her supervisor and the VISN financial quality assurancemanagers for corrective action. The employee may also reportthe incident to the Office of the Inspector General. Matters offraud, waste and abuse can also be reported to the Office ofSpecial Counsel and Office of Accountability and WhistleblowerProtection.Q. An employee has questions related to appropriationslaw or financial policies regarding purchases such as Awardceremonies, travel and purchase cards. Where should theemployee look for assistance?A. Refer to VA Financial Policies Website, GovernmentAccountability (GAO) ("Red Book") or the local fiscal officer.13DEPARTMENT OF VETERANS AFFAIRS

SPEAK UP AND LISTEN UP6.0 Integrity as a Federal Employee6.1 General ConsiderationsPublic service is a public trust. Government officials must putthe public’s interests before their own interests. The publicmay lose confidence in the integrity of the Government if itperceives that an employee's Government work is influencedby personal interests or by payments from an outside source.An executive branch employee's Government work mayhave the potential to benefit the employee personally, affectthe financial interests of the employee's family or involveindividuals or organizations with which the employee hassome past, present or future connection outside of theemployee's Government job. Hence VHA employees mustavoid situations where personal interests might or mightappear to, impact their objectivity in performing theirofficial duties. Conflicts of interest occur when an employee’spersonal financial interest or outside activity or theinterest of another, such as a spouse or outside employer,interferes—or appears to interfere—with the employee'sability to do our work in an impartial manner. Employeesare encouraged to proactively disclose actual or perceivedconflicts of interest.Acting with integrity as a Federal employee meansunderstanding applicable laws, regulations and policiesregarding the following: Procurement IntegrityStandards of Ethical Conduct for Employees of theExecutive BranchCriminal Conflict of Interest ProhibitionsHatch Act (Political Activity)CODE OF INTEGRITY14

6.2 Relevant Laws, Regulations and PoliciesNote that this list is not all-inclusive, as there may beadditional laws, regulations or policies that apply. VHA Handbook 1660.03: Confli

laws applicable to all Federal employees, the Code of . Integrity is specific to VHA employees. The Code of Integrity consolidates applicable policies, laws and regulations in a single document for easy reference. It further demonstrates the commitment to integrity in interactions w