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ContentsGET TO KNOW YOUR COMPLIANCE DEPARTMENT ______________________________________2THE 14 GENERAL PRINCIPLES OF ETHICAL CONDUCT ___________________________________ 3COMPLIANCE COMPONENTS ELEMENTS WHEEL ______________________________________4FRAUD WASTE & ABUSE ___________________________________________________________6HATCH ACT ______________________________________________________________________9WHO IS COVERED BY THE HATCH ACT? _______________________________________________9WHO IS FURTHER RESTRICTED? ____________________________________________________10ON DUTY OR IN THE WORKPLACE PROHIBITION: ______________________________________10WHAT IS POLITICAL ACTIVITY? _____________________________________________________10WHAT HAPPENS IF I VIOLATE THE HATCH ACT? _______________________________________11GIFTS FORM OUTSIDE SOURCES ___________________________________________________11WHAT IS A GIFT?_________________________________________________________________11WHAT IS NOT A GIFT? ____________________________________________________________11THE BASIC RULE _________________________________________________________________ 11GIFTS OF FREE ATTENDANCE ______________________________________________________12SEEKING ADVICE ________________________________________________________________13GIFTS BETWEEN EMPLOYEES ______________________________________________________13THE GENERAL PROHIBITIONS ______________________________________________________ 13SOME EXCEPTIONS TO THE GENERAL PROHIBITIONS __________________________________14SPECIAL, INFREQUENT OCCASIONS _________________________________________________14WHISTLEBLOWER PROTECTION ACT ________________________________________________15REPORTING ____________________________________________________________________16DUTY TO REPORT ________________________________________________________________19VA HELP LINES __________________________________________________________________20Compliance / Page 1

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GET TO KNOW YOUR COMPLIANCE DEPARTMENTGidgetti D. Greathouse, Integrity Compliance Officer. Worked for Veteran Health Administration for 28 ½ years. Gidgetti has served in several different areas: Medical Records Technician, Lead Medical Record Technician, Health Information Management Auditor, Compliance and Business Integrity Compliance Specialist, Facility Revenue Manager, Medical Records Administrator, Vera Coordinator, Chief Health Information Manager. Gidgetti is a Veteran and feels that she is once again serving. Gidgetti states “of all the government agencies VHA has the best mission “Honor America’s Veterans by providing exceptional health care that improves their health and well-being.” She is a mother of three adult children and 2 fur babies. She enjoys, movies and sewing the fabulous clothes she wears to work.Gidgetti.Greathouse@va.gov / Office Phone – 843-789-7718James (Jim) E. Hampton, Integrity Compliance Auditor. Jim is a proud Veteran of the United States Air Force. He has over 24 years in Healthcare Management in both stateside and overseas Military Health Systems (MHS), Public Hospitals, and currently with the Veteran Health Administration. Jim has worked in many different areas and held several key positions in his career: VA Compliance Office, Facility Records & Information Officer, Privacy/FOIA Officer, Family/Pediatric clinic, Medical Facility Education & Training Manager, Release of Information Manager, Patient Services, Medical Emergency Management, and Patient Access. He continues to serve and help fulfill President Lincoln’s promise to take care of those who have served. When Jim is not at work, he is an outdoorsman, enjoys spending time with family, traveling, and wood working. James.Hampton@va.gov / Office Phone – 843-789-7718Brittany Bell, Health Systems Specialist and Technical Career Fields Trainee. Working out of the Office of Integrity and Compliance at the Ralph H. Johnson VA Medical Center, Brittany has provided bedside patient care for over 11 years in various healthcare settings. Brittany believes her path and career successes have been led by her passion as a nurturer. She has been working at the RHJVA since May of 2019 where she especially appreciates the Code of Integrity and ICARE Values that are upheld by personnel. When Brittany is not at work, she enjoys spending time with her family and loved ones. She especially looks forward to having more stamps added to her passport. Brittany.Bell@va.gov / Office Phone – 843-789-7882Compliance / Page 2

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THE 14 GENERAL PRINCIPLES OF ETHICAL CONDUCT5 C.F.R §2635.101 (b) The following general principles apply to every employee and may form the basis for the standards contained in this part. Where a situation is not covered by the standards set forth in this part, employees shall apply the principles set forth in this section in determining whether their conduct is proper.1. Public service is a public trust, requiring employees to place loyalty to the Constitution, the laws, and ethical principles above private gain.2. Employees shall not hold financial interests that conflict with the conscientious performance of duty.3. Employees shall not engage in financial transactions using nonpublic Government information or allow the improper use of such information to further any private interest.4. An employee shall not, except as permitted by subpart B of this part, solicit, or accept any gift or other item of monetary value from any person or entity seeking official action from, doing business with, or conducting activities regulated by the employee’s agency, or whose interests may be substantially affected by the performance or nonperformance of the employee’s duties.5. Employees shall put forth honest effort in the performance of their duties.6. Employees shall not knowingly make unauthorized commitments or promises of any kind purporting to bind the Government.7. Employees shall not use public office for private gain.8. Employees shall act impartially and not give preferential treatment to any private organization or individual.9. Employees shall protect and conserve Federal property and shall not use it for other than authorized activities.10. Employees shall not engage in outside employment or activities, including seeking or negotiating for employment, that conflict with the official Government duties and responsibilities.11. Employees shall disclose waste, fraud, abuse, and corruption to the appropriate authorities.12. Employees shall satisfy in good faith their obligations as citizens, including all just financial obligations, especially those—such as Federal, State, or local taxes—that are imposed by law.13. Employees shall adhere to all laws and regulations that provide equal opportunity for all Americans regardless of race, color, religion, sex, national origin, age, or handicap.14. Employees shall endeavor to avoid any actions creating the appearance that they are violating the law, or the ethical standards set forth in this part. Whether circumstances create an appearance that the law or these standards have been violated shall be determined from the perspective of a reasonable person with knowledge of the relevant facts.Compliance / Page 3

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Risk Assessment and Management - One-stop-shop for guides, tools (i.e., VHA OIC Risk Management Portal) and collaboration opportunities related to Risk Assessments and Risk Management practices.Policies and Procedures - VHA Directive 1030 and Compliance Program Standards provide authority to the Compliance Officer and define roles, individual/organizational responsibilities, and how the program functions.Communications - Routine weekly recap emails and ad hoc communications from VHACO OIC are archived here, as well as posters and Compliance Alliance newsletters.Training and Education - Mandatory Training Resources, the National Training and Education Plan Template, Evaluation Methods, and Competency Model information can be found on this page.Auditing and Monitoring - Causation and Corrective Action Reports (CCAPs), Government Sanctions List, tools (i.e., ReDPro, SchedPro), templates, and worksheets.Investigation and Response - CIRTS resources to assist in the investigation and response of a compliance allegation, inquiry, or failure, including fact finding and Administrative Investigation Boards (AIBs), the List of Excluded Individuals and Entities (LEIE), and the System for Award Management (SAM). Includes CIRTS usage and installation guidance as well.Resolution Enforcement and Discipline - Resources to support the Compliance Officer’s role in resolution, enforcement, and discipline activities.Compliance Resources, Officer, and Committee - Resources that support compliance functions and establishment and management of a local compliance committee. Compliance / Page 5

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FRAUD WASTE & ABUSEAccording to the U.S. Government Accountability Office (GAO), fraud is attempting to obtain something of value through willful misrepresentation; waste is squandering money or resources even if not explicitly illegal; and abuse is behaving improperly or unreasonably or misusing one’s position or authority.Your local Compliance Team assist with establishing FWA prevention and detection processes and procedures. We also provide oversight and support through training, education, assessment, monitoring, fact-finding, investigations, and reporting.Fraud is the act of making false representations of material facts whether by words or conduct, by concealing information, or by making misleading statements in order to obtain some benefit or payment that would otherwise not exist. These acts must have been committed knowingly, willfully and intentionally.Waste is spending money or using resources on goods or services in excess of actual need. Waste does not necessarily produce a benefit for the individual, but is an act of poor management of funds.Abuse consists of practices that cause unncecarry costs to the Department of Veterans Affairs. Abuse can be similar to fraud, except that it is not possible to prove that abuse was performed knowingly, willfully and intentionally.FRAUD WASTE ABUSEFraud, Waste, Abuse and Addressing OIC ConcernsWhat is fraud, waste and abuse?Compliance / Page 6

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Fraud prevention is a continuous fight that we can win. Each of you are central to the fight against fraud, waste, and abuse on behalf of the Department, our nation’s Veterans, and taxpayers. Remember VA’s core values and how important it is for us to embody them in our everyday actions.You are the first and best line of defense VA has against fraudulent activity. Be vigilant, think like a fraudster to identify vulnerabilities, and as always, if you see something, say somethingAsk QuestionsLook for any breakdown or gaps in controls, suspicious behavior, or weaknesses1Know Your Internal ControlsIf you notice a potential weakness in a process, ask yourself ‘can a criminal take advantage of this?’Follow Fraud TrendsAsk yourself, ‘is VA vulnerable to these activities?’Report Suspicious BehaviorInform your supervisor or other leader or concerns, report potential fraud incidents to OIG.23 4What Can I Do?Compliance / Page 7

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HATCH ACTThe Hatch Act, a federal law passed in 1939, limits certain political activities of federal employees. The law’s purposes are to ensure that federal programs are administered in a nonpartisan fashion, to protect federal employees from political coercion in the workplace, and to ensure that federal employees are advanced based on merit and not based on political affiliation.WHO IS COVERED BY THE HATCH ACT?The Hatch Act has two categories of employees.WHAT MAY ALL EMPLOYEES DO?• Register and vote as they choose.• Contribute money to political parties, campaigns, or groups.• Attend political rallies, meetings, or fundraisers.• Be members of political clubs or parties.• Sign nominating petitions.• Be candidates for public oce in nonpartisan elections.• Campaign for or against referendum questions, constitutional amendments, or municipal ordinances.• Follow, like, or comment on the social media pages of a candidate for partisan oce, political party, or partisan group.• Display yard sign or bumper sticker on personal vehicle.Less RestrictedMay actively participate in partisan political management and campaigns, subject to the prohibitions we are about to discuss.Further RestrictedSubject to additional restrictions regarding active participation in partisan political management and campaignsLess Restricted Employees May Also: Engage in partisan political campaigning:• Circulate nominating petitions.• Volunteer to work on a campaign.• Distribute campaign literature.• Organize campaign events.• Speak on behalf of a candidate. Engage in partisan political management:• Hold party oce.• Serve as delegate to a party convention.• Organize party events.• Serve on a party committee.Compliance / Page 9

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WHO IS FURTHER RESTRICTED?Employees of certain intelligence or enforcement agencies and offices (except PAS), Office of Special Counsel, Career Senior Executive Service (Career SES), Administrative Law Judges, Contracts Appeals Board Members, and Administrative Appeals Judges.WHAT DOES THE HATCH ACT 24/7 PROHIBIT?1. Use their official authority or influence to affect the outcome of an election2. Solicit, accept, or receive a political contribution 3. Be candidates in partisan elections4. Solicit or discourage the political activity of a person with business before their employing officeON DUTY OR IN THE WORKPLACE PROHIBITION:Employees may not engage in political activity while on duty, in the federal workplace, wearing a government uniform or badge, and/or operating a government vehicle.WHAT IS POLITICAL ACTIVITY?Political activity refers to activity directed toward the success or failure of a political party or partisan political group (collectively referred to as “partisan groups”), or candidate for partisan political office (candidate).Compliance / Page 10

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GIFTS FORM OUTSIDE SOURCESMost executive branch employees know there are rules about whether or when they may receive gifts from outside sources. This pamphlet provides a brief overview of those gift rules by answering some of the frequently asked questions concerning gifts from outside sources.WHAT IS A GIFT?Almost anything of monetary value, such as cash, meals, paperweights, trips, concert tickets, and services.WHAT IS NOT A GIFT?A cup of coffee, modest refreshments which are not part of a meal, and items of little intrinsic value such as greeting cards, plaques, and certificates intended solely for presentation. Carpooling and similar arrangements are also fine, pro-vided there is a proportionate sharing of cost and effort involved.THE BASIC RULEQ: What is the basic gift rule that applies to me as a federal employee?A: As an employee of the executive branch, you may not solicit or accept a gift that is given because of your official position or that is given to you by a prohibited source, unless the item is either not considered to be a gift or falls within one of the exceptions to the basic rule.WHAT HAPPENS IF I VIOLATE THE HATCH ACT?An employee who violates the Hatch Act is subject to a range of disciplinary actions, including removal from federal service, reduction in grade, debarment from federal service for a period not to exceed 5 years, suspension, letter of reprimand, or a civil penalty not to exceed $1000.Compliance / Page 11

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GIFTS OF FREE ATTENDANCE Q: I sometimes receive invitations of free attendance for events hosted by private sector companies and other sponsors that do business with my agency.These events are very useful for both me and the agency because I learn about industry trends and make professional contacts.If my supervisor approves of me attending these kinds of events, is it okay for me to accept the offer of free attendance?A: You may be able to accept the offer of free attendance based on the exception for certain widely attended gatherings. An ethics official or other authorized individual must decide that your attendance is in the agency’s interest because it will benefit agency programs and operations. Other factors to be considered are the source of the invitation and whether that person has interests that may be substantially affected by the performance (or nonperformance) of your official duties; the number and identity of other participants expected to attend, and the market value of the gift of free attendance.Note that this exception does not permit you to accept travel and lodging expenses, although these items may be accepted under other authorities.Compliance / Page 12

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GIFTS OF FREE ATTENDANCE SEEKING ADVICEQ: Anything else I need to be aware of?A: If you have any questions regarding gifts, always seek your ethics official’s advice. Even if a gift falls under one of the exceptions to the gift rule, it is never inappropriate and frequently prudent for you to decline a gift offered by a prohibited source or given because of your official position, especially when the gift is offered by a person or organization whose interests could be affected by your official actions.GIFTS BETWEEN EMPLOYEESMost executive branch employees know there are rules about whether or when they can give gifts to oraccept gifts from their fellow employees. This pamphlet provides a brief overview of those gift rules by answering some of the most frequently asked questions concerning gifts between employees.THE GENERAL PROHIBITIONSQ: What are the prohibitions on gifts between employees?A: You may not give a gift to or contribute to a gift for your official superior. You also may not solicit a contribution from another employee for a gift for either your own or that employee’s official superior. Finally, you may not accept a gift from someone who is paid less than you, unless that person is not your subordinate, and a personal relationship justifies the gift.Compliance / Page 13

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SOME EXCEPTIONS TO THE GENERAL PROHIBITIONSTHE $10 RULEQ: My supervisor and I have developed a good working relationship over the years. Are there any gift-giving exceptions that would permit me to give him a gift on, let’s say, his birthday or Bosses’ Day?A: Yes. There is an exception that allows you to give and your supervisor to accept a gift, other than cash, with a market value of $10 or less on an occasional basis. This includes occasions when gifts are traditionally given such as birthdays, Bosses’ Day, or other annually occurring holidays.Q: Why a $10 limit?A: Because it is high enough to permit an exchange of modest tokens between employees such as cookies on holidays, or flowers and vegetables from home garden, but low enough generally to discourage employees from purchasing gifts for their superiors.SPECIAL, INFREQUENT OCCASIONSQ: My supervisor is in the hospital, and I’d like to send her a nice ower arrangement. Am I limited to $10? (I’m afraid $10 won’t buy many owers!)A: Yes, you may send your supervisor a nice arrangement of owers, and you don’t have to limit your purchase to a couple of daisies.In recognition of certain special, infrequent occasions of personal signicance such as illness, a marriage, or the birth or adoption of a child (but not holidays or annually recurring events), and on occasions that terminate the superior subordinate relationship, you may give gifts to an ocial superior and accept them from subordinates or other employees receiving less pay.On these occasions there is no monetary limit; however, the gift(s) must be of a type and value appropriate to the occasion.Compliance / Page 14

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WHISTLEBLOWER PROTECTION ACTThe WPA prohibits retaliation against applicants and employees who blow the whistle on misconduct such as a violation of law, rule, or regulation; a gross waste of funds; or a substantial and specific threat to public health and safety. Congress is a protected audience for WPA disclosures, and the law provides for independent investigation and enforcement through the Office of Special Counsel and Merit Systems Protection Board. The WPA protects covered employees who disclose information that they reasonably believe evidence:• A violation of any law, rule, or regulation• Gross mismanagement• A gross waste of funds• An abuse of authority• A substantial and specific danger to public health or safety The WPA also protects disclosures regarding agency policy decisions and/or censorship related to research, analysis, or technical information if the consequences of the policy decision or censorship at issue would result in the misconduct listed above.Compliance / Page 15

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REPORTINGDuty to Report (38 CFR 1.201)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. Anonymity will be protected!*Following the supervisor(s) chain of command is not mandatory Hatch Act Hotline: (202) 254-3650 or (800) 854-2824Hatch Act Fax: (202) 254-3700 E-mail: hatchact@osc.gov Website www.osc.gov VA Fraud, Waste and Abuse Website https://vaww.va.gov/OIC/STOP_FWA.aspCompliance / Page 16

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DUTY TO REPORTFederal regulations require VA employees must report any information about actual or possible violations of criminal law involving VA or its contractors to a supervisor, management ocial, VA police, or the Oce of Inspector General (OIG). VA employees must report all criminal matters involving felonies to the OIG.Report criminal activity, waste, abuse, mismanagement, and safety issues to the OIG.Call 1-800-488-8244, or write VA OIG Hotline (53E), 810 Vermont Avenue NW, Washington, DC 20420.Fax to 202-565-7936, or email vaoighotline@va.gov.Compliance / Page 19

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