As most of you know, folks with relationships with for profit educational institutions (including simply taking classes) but also including receiving gifts, wages, other services, or owning stock must file a waiver to continue to pursue these relationships. As you also know, the law changed on 9/29/2018, and therefore all educational resources, products, waiver algorithms and training materials are in the process of being updated.
The national workgroup has devised a very efficient mechanism of trying to determine whether any person in VA must file a waiver.
The process (starting likely March 2019 or thereabouts) will be as follows:
- A short survey about relationships with for profit educational institutions will be appended to the Government Ethics TMS training. This will be part of the required annual Government Ethics curriculum.
- Every employee will take annual Government Ethics training when due, and will take the short survey. From there, every employee will know if they need to file a waiver in the Waiver Portal.
- There will be links to additional educational materials and also to the main waiver portal from the survey.
- VHA, VBA and OGC have all approved this plan to go forward.