I.          PURPOSE:      To define the conditions under which PAIRE will pay honoraria to VA-paid employees.

II.         POLICY:         It is the policy of PAIRE to ensure that payment of honoraria to VA-paid employees is handled in a manner that does not put the employee at risk of violating federal ethics regulations. 

III.       DISCUSSION:            Compensation to VA employees for outside speaking, writing and teaching activities is governed by a complex series of regulations addressing federal ethics guidelines and dual compensation (5 CFR  §2635.807 and  §18 USC 209).  These are discussed below:

A.        VA-paid employees may not accept non-VA compensation while on official duty status.  Thus, any time compensation is to be paid by PAIRE to a VA- paid employee, s/he must be on non-duty status from the VA. 

B.         VA-paid employees may not accept non-VA compensation if the subject of the presentation is related to official VA duties, with one exception not applicable for this discussion. Requests for PAIRE to pay an honorarium to a VA-paid employee must include certification that the fee is not for work related to official VA duties.

IV.       PROCEDURES:

A.        Requests to pay honoraria to VA-paid employees should be made using a Payment for Services form and must include the payee's Social Security Number and home address. Additionally, the completed Honorarium Payment to (or on Behalf of) VA Employees form must be attached.

B.         If total payment to an individual in a calendar year is $600 or more, IRS Form 1099 MISC will be issued to the payee.