Compliance Services is the point of contact for VCU Health Service’s annual reporting requirements to the state.
Every year, individuals determined by VCUHS to hold a position of trust are required by the state to complete Virginia's Statement of Economic Interest. This year, the form must be completed and submitted to VCUHS Compliance Services by January 6, 2012. If you are one of these individuals, you will be notified by our office.
Additionally, every other year, certain individuals are required by the state to complete a Conflict of Interests orientation course. The purpose of the training is to ensure that employees required to file the annual Statement gain a greater knowledge of the Act, its provisions and prohibitions. This year, training must be completed by January 6, 2012. You will be notified by our office if you need to complete this training. For your convenience, the VCU Integrity & Compliance Office (ICO) has provided an illustrated, step-by-step guide to accessing the course. All VCU employees can access it by going to http://www.assurance.vcu.edu/coitraining.html. All Board Members and VCU Health System Employees can access it by going to http://www.assurance.vcu.edu/HSCOI/.
Please print a copy of the certificate and submit it with your notarized Statement of Economic Interests form.
If you do not need the guide and are familiar with logging into this training, you may click here to access the training: https://covkc.virginia.gov/oag/external/
Please call our office if you need assistance at 828-0500. VCU Health System Interim Chief Compliance and Privacy Officer, Jill McCormack is available to you for questions about this process, at jmccormack@mcvh-vcu.edu.
Statement of Economic Interests
The form is located on page 4 of the booklet, which is available in both Word (545 K) and PDF (216 K) formats. Completed forms must be signed and notarized, and include all of the relevant supporting schedules in the packet.
Practical Submission Guidance:
- Faxes cannot be accepted; we must receive original signed documentation.
- All questions must be answered; paying special attention to Question #6 (off set alignment causes reporters to skip this question, resulting in delayed submission and follow up from VCUHS Compliance Services.
- A corresponding schedule must be completed for each question marked Yes.
- To aid in proper documentation and reporting, please do not staple forms. Please use a paper clip.
- Please have your information notarized prior to delivery as we do not have a notary available. Contact your department’s administration or our office at 828-0500 for the location of a notary.
- The notary seal should be an inked stamp or an embossed stamp shaded with pencil/marker to ensure the notary seal is photographically reproducible.
Submission Timeline:
NOVEMBER 2011: If applicable, you will receive an initial notice for training and interest disclosure during the third week of November.
DECEMBER 2011: If applicable, you will receive a one month reminder notice for training and interest disclosure during the second week of December.
JANUARY 2012: If applicable, you will receive a second, and urgent, reminder notice for training and interest disclosure during the first week of January.
Finally, if requirements are not complete by the end of the first week of January, you will receive an urgent Final Two-Day Reminder in order for VCUHS to meet its state reporting obligations. If you refuse to participate, this will be reported to the state as well as to your Vice President.
Frequently Asked Questions:
When filling out the Statement of Economic Interests form, who do I consider my "immediate family"?
Immediate family means spouse, children who are still living at home and are dependents, or any other person living in your home who is dependent upon you and who received from you more than one-half of his or her financial support.
When completing Schedule B of the Statement of Economic Interests form, what do I consider my "personal liabilities"?
Personal liabilities means money owed to a bank or one creditor for over $10,000. This debt includes such things as student loans and credit cards. This does not include such things that can be taken away for non-payment, such as a car loan or a mortgage on your home. For example, your house or car can be repossessed if you do not pay; however, if you have student loans, your education cannot be taken away from you, and you are personally liable to pay on these loans.
When completing Schedule E of the Statement of Economic Interests form, what do I consider a "gift"?
All gifts over $50 must be reported. A gift is considered any gratuity, hospitality, entertainment (including meals, transportation, lodging) that was given to you by a business, government or individual other than a relative or close personal friend and for which you neither paid for nor provided services in exchange.
When completing Schedule G of the Statement of Economic Interests form, who do I consider a "close financial associate"?
A close financial associate includes any partner in a business, co-owner of a business or piece of land, or member of your immediate family. This does not include an individual who is receiving retirement benefits from a business or who may be representing a state governmental agency.
What is the penalty for failure to file a Statement of Economic Interests form or wrongly filing the form?
Any person who does not file or who knowingly files the Statement of Economic Interests form inaccurately will be charged with a Class 1 Misdemeanor which is punishable by no more than 12 months in jail and a fine of no more that $2,500. A local official who knowingly files the form inaccurately will be charged with a Class 3 misdemeanor which is punishable by a fine of no more than $500. Any person who knowingly files the form inaccurately may also be dismissed from office or employment.
(Source: Secretary of the Commonwealth)