|
Academic Affiliations Disbursement Agreements
Department of Veterans Affairs
Veterans Health Administration
Washington, DC 20420 |
VHA DIRECTIVE 98-031
July 6, 1998 |
1. PURPOSE: This directive clarifies Veterans
Health Administration (VHA) policies and procedures on disbursement agreements contained
in Department of Veterans Affairs (VA) manual M-8, Part II, Chapters 1 and 5. Public
Law 104-262, Section 345 amends Title 38 United States Code (U.S.C.) Section 7406(c)
and authorizes VA disbursement agreements to cover residents and interns training
in any VA medical facility furnishing hospital or outpatient care, including independent
outpatient clinics.
2. BACKGROUND: The purpose of disbursement agreements is to provide
VA with a mechanism to achieve equity in residents’ salaries and benefits
with the affiliated institution. VA may pay residents either directly through the
VA payroll system or indirectly through disbursement agreements with medical schools
or other affiliated hospitals. A disbursement agreement is an alternative payroll
mechanism by which VA allows an affiliated institution to administer salary payments
and fringe benefits for VA residents in training. The primary purpose of disbursement
agreements is to achieve equity in payments of resident stipends and fringe benefits.
Disbursement agreements standardize compensation and may cover stipends and fringe
benefits (full agreements) or fringe benefits only (fringe benefits agreements).
Issues addressed in this directive apply only to residents paid under a disbursement
agreement. All resident supervision and work limit standards are to be observed.
3. POLICY: It is VHA policy to develop disbursement
agreements with hospitals, medical schools, or medical institutions participating
with VA in the training of residents, when appropriate, in order to achieve equity
in payment of residents’ stipends and fringe benefits.
4. ACTION
a. Appointment Process
(1) Appointment Procedures and Records. All residents training
at a VA facility and paid under a disbursement agreement must have intermittent
VA appointments. A sample appointment letter
has been created for this purpose. A copy of this letter and a completed Standard
Form (SF) 61, Appointment Affidavits Form, will serve as the appointment documentation
for residents with no prior federal service. These documents may be filed per local
facility policy consistent with Privacy Act and Freedom of Information Act (FOIA)
requirements. Residents with prior federal service should be directed to the servicing
Human Resources Management Office for any additional processing that might be necessary.
Do not establish an Official Personnel Folder for, or process into the Personnel
Accounting Integrated Data (PAID) system residents covered by a full disbursement
agreement unless the individual has prior Federal service and Civil Service Retirement
System (CSRS) retirement coverage.
THIS VHA DIRECTIVE EXIRES July 6, 2003
(2) Pay for Actual Time Rendered. VA will only pay for resident
training and related services actually documented as received and cannot pay by
the number of resident positions allocated to VA.
(3) Compensable Resident Activities. In order for physician
residents in training to receive compensation through a disbursement agreement they
must be in a VA facility. Current interpretation of the law governing disbursement
agreements prohibits VA’s paying a resident for an educational and/or training
experience in a non-VA facility. Relief from this restriction is currently being
sought.
(4) Alternative Duty Week. In some residency programs, especially
in advanced subspecialties, residents routinely work a customary 5-day a week clinical
schedule. Current disbursement payment practices state that residents are supposed
to be on VA duty 7 days a week. The local VA facility shall have the option to apply
the 5-day or 7-day resident duty week as the cost basis in the agreement. The facility
should elect to apply the duty week that more accurately reflects the normal and
customary clinical schedule followed by the affiliate and best represents equalization
of the work of residents at VA and the affiliate.
(5) Prorating Costs for Less than Full-time Coverage. In some
specialty program rotations, residents split their time on a daily or weekly basis.
Program rotations and assignments should clearly establish and quantify the levels
of coverage being provided to the VA facility. The estimate of VA's pro rata share
of the costs of resident training should be supported by documentation certified
by the service chief and should show the standard duty week or other period for
the program or rotation, the amount of VA coverage, and the pro rata determination.
This should be done at the beginning of the academic year and whenever schedule
changes require it. Pro-ration of resident reimbursement shall be applied and based
on the calculation of the share of VA duty, as indicated on the actual work schedule
time accounts certified by the service chief, if less than full-time coverage of
the VA facility is provided.
(6) On-Call Coverage. In some subspecialty programs, a resident
may be on-call for the VA and at one or more affiliated hospitals at the same time.
In these instances VA and the affiliated medical facilities should divide the payment
responsibilities for on-call coverage among the affiliated institutions in an equitable
manner.
(7) Rotation and Assignment Schedules. The affiliated institution
shall provide VA with accurate and complete resident rotation and assignment schedules
by postgraduate level. Whenever a resident paid under disbursement agreement listed
for VA rotation is not available at the time originally scheduled, another resident
is expected to provide the required VA rotation. The names of the actual residents
rotating to the VA for training should be used. Complete, accurate schedules are
necessary both for management of clinical activities and for billing purposes. Resident
rotation and assignment schedules by level must be provided on a timely basis by
the affiliate and adhered to by the residents who are assigned duty at the VA.
(8) Attendance Records. Accurate time and attendance records
of resident training at the facility must be maintained by the VA facility, although
time cards per se for individual residents are not mandated. VA shall maintain records
that accurately document resident rotation and assignment schedules. If the basis
for VA duty reimbursements is properly established and certified as accurate by
the supervising official, such as the service chief, then individual timecards and
attendance records will not be mandated, though the VA facility may choose this
as its preferred method. The VA facilities with automated systems for time keeping
may use such systems to document resident rotation and assignment schedules as a
basis for VA duty reimbursements.
b. Process for New Agreements. At least 3 months prior to the
effective date of any new disbursement agreement, a draft agreement and appendix
in the appropriate format and a copy of the documents used to estimate the proposed
cost will be sent to the Chief Academic Affiliations Officer (144) for review and
coordination with Human Resources Management and, if necessary, for concurrence
by the Office of the General Counsel. Approved standard formats have been developed
for full agreements and for fringe agreements (see M-8, Pt II, Ch. 5, Appendices
5B and 5C). After this review is completed, the draft will be returned to the facility
for any revisions. An original of the revised disbursement agreement, signed by
the VA facility director and the authorized representative of the affiliated institution,
will be submitted to the Chief Academic Affiliations Officer for formal approval.
Signed agreements with approved rates will be returned to the VA facility Director
for distribution to the disbursing agent, personnel and fiscal services, and any
other staff involved in the disbursement process.
c. Process for Rate Changes. Upon notification by the affiliated
institution of proposed rate changes, a mock up of the existing rates in the Appendix
and a copy of the documentation used to estimate these rate changes will be forwarded
to the Chief Academic Affiliations Officer (144) for review and coordination with
Human Resources Management. After review by Headquarters is completed, the Appendix
will be signed and returned to the VA facility director. Copies should be given
to the disbursing agent, personnel and fiscal services, and any other staff involved
in the disbursement process.
5. REFERENCES
a. Public Law 104-262.
b. Title 38 U.S.C. Section 7406(c).
c. M-8, Part II, Chapters 1 and 5.
6. FOLLOW-UP RESPONSIBILITY: The Chief Academic Officer (14) is
responsible for thee contents of this directive.
7. RESCISSION: This VHA Directive will expire July 6, 2003.
Kenneth W. Kizer, M.D., M.P.H.
Under Secretary for Health
Attachment
DISTRIBUTION:
CO: E-Mailed
FLD: VISN, MA, DO, OC, OCRO, and 200-FAX
EX: Boxes 104, 88, 63, 60, 54, 52, 47 and 44-FAX
| 
