Office of Oversight, Risk and Ethics

Code of Integrity - Introduction and Responsibilities

Veterans Health Administration (VHA) is committed to the highest standards of integrity and ethics. The Code of Integrity reinforces that we are a principles-based organization; these principles, which protect and promote integrity, are applicable to all VHA employees.

This page covers the Introduction and Responsibilities of the Code of Integrity. More information is available on the following pages:

• Introduction and Responsibilities
• Integrity in Care for Veterans and Their Caregivers
• Integrity in the Workplace
• Integrity in Financial Matters and Asset Protection
• Integrity in Conduct of Research
• Integrity in Health Care Personnel Education and Training
• Points of Contact

Introduction

• The Code of Integrity provides guidance to ensure that work at VHA is accomplished not only in accordance with all applicable laws, regulations, and policies, but also with the spirit of these laws, regulations, and policies. All VHA employees are responsible for being familiar with this Code of Integrity and complying with the laws, regulations, and policies that apply to their work.

• As a minimum standard, VHA employees are expected to comply with all applicable laws, regulations, and policies. The Code of Integrity demonstrates the commitment to I CARE values in the workplace and to the ethical values that guide what should be done, beyond what must be done. The Code of Integrity emphasizes VHA employees’ responsibilities to operate with integrity and the highest ethical standards. It is a consolidated document with various references and points of contact for specific matters of integrity.
• More than technical compliance with the laws and regulations, integrity means having the sort of character where behavior and actions are trusted to be ethical, reflective of agency values, without the intent or effect of being false or misleading and beyond minimal compliance with laws, regulations, and policies.

• While there are Standards of Ethical Conduct for Employees of the Executive Branch and criminal conflicts of interest 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 with fellow employees, treatment of Veterans and their caregivers, research conducted, healthcare personnel education and training, financial matters, and asset protection.

• The Code of Integrity applies to all VHA employees.

Responsibilities

• All VHA employees are responsible for being familiar with this Code of Integrity and complying with the laws, regulations, and policies that apply to their work. Please review the reference links in each of the sections, as they will lead you to the relevant source information for each concept.

• Obligation to Report:
  • Employees have a legal obligation to report violations of criminal law to their supervisor, VA Police, and/or the Office of Inspector General. Federal regulations provide the following guidance regarding an employee’s duty to report: All VA employees with knowledge or information about actual or possible violations of criminal law related to VA programs, operations, facilities, contracts, or information technology systems shall immediately report such knowledge or information to their supervisor, any management official, or directly to the Office of Inspector General (38 C.F.R. 1.201).
  • Moreover, Federal regulations provide the following guidance regarding reporting fraud, waste, and abuse: Employees shall disclose waste, fraud, abuse, and corruption to appropriate authorities (5 C.F.R. 2635.101(b)(11)). Employees are also encouraged to seek guidance regarding concerns and ask questions to prevent, identify, and remediate suspected misconduct at VHA.
• Non-Retaliation
  • Federal employees who act as whistleblowers and expose and report certain kinds of agency misconduct are protected (5 U.S.C. §2302(b)(8)). This whistleblower protection extends to disclosures that an employee reasonably believes constitutes a violation of any law, rule, regulation or gross mismanagement, gross waste of funds, abuse of authority, or a substantial and specific danger to public health or safety. A Federal employee authorized to take, direct others to take, recommend, or approve any personnel action must not take, fail to take, threaten to take, or threaten to fail to take any personnel action against an employee because of protected whistleblowing. No disciplinary or punitive action will be taken against staff or visitors who report patient safety and/or quality of care concerns to The Joint Commission (APR 09.02.01, The Joint Commission).
• Whom to Contact with Questions or Concerns
  • VHA has several resources available to assist with raising and reporting concerns. Managers and senior leadership in the facility or program office are available to address concerns and answer questions, as they are familiar with laws, regulations, and policies that apply to employees’ work. Apart from an employee’s duty to report actual or possible criminal violations as well as complying with Standards of Ethical Conduct for Employees of the Executive Branch, employees are encouraged, but not required, to first discuss their questions or concerns on compliance and integrity issues with their immediate supervisor. If an employee feels they are unable to resolve their questions or concerns, employees are encouraged to escalate to the facility management or local points of contact. For questions or concerns related to specific matters of integrity outlined in the sections below, please contact the appropriate points of contact listed.
• Decision Making Guidance Regarding Integrity in the Workplace
  • When considering where to speak up about your concerns, ask yourself:
    • Do I have a concern about a possible violation of applicable laws, regulations, or policies?
    • Do I have a concern that certain practices or actions are inconsistent with the I CARE values?
    • Do I have a concern that certain practices or actions may harm Veterans, other beneficiaries, or VHA staff?
  • If the answer to any of the questions above is “yes”, you are encouraged to discuss your concerns with your immediate supervisor. You may approach facility management, local points of contact, or national points of contact (when an issue is not local in nature or cannot be resolved locally) regarding your concerns.
  • Please note that the Office of General Counsel, the Office of Special Counsel, the Office of Accountability and Whistleblower Protection, the Office of Inspector General, and offices identified in the Points of Contact section may be contacted at any time.

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