VCOM Institutional Policy and Procedure Manual

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Edward Via College of Osteopathic Medicine—Virginia Campus 2265 Kraft Drive Blacksburg, VA 24060 540-231-4000  Fax: 540-231.5252 Edward Via College of Osteopathic Medicine—Carolinas Campus 350 Howard Street Spartanburg, SC 29303 864-327-9800  Fax: 864-804.6986 Edward Via College of Osteopathic Medicine—Auburn Campus 910 South Donahue Drive Auburn, Alabama 36832 334-442-4000  Fax: 334-442.4095 Edward Via College of Osteopathic Medicine - Louisiana Campus 4408 Bon Aire Drive Monroe, Louisiana 71203 318-342-7100  Fax: 318-342-7280

Website: www.vcom.edu

This Manual is provided to the Board, faculty, staff and students of the Edward Via College of Osteopathic Medicine (VCOM) and contains all policies and procedures of VCOM. The College Catalog and Student Handbook, Faculty Handbook, and Administrative and Classified Staff Handbook are provided to the students, faculty, and staff of the Edward Via College of Osteopathic Medicine (VCOM) as a guide to the interpretation and application of the policies and procedures regarding their roles, responsibilities and their continuing status. These Handbooks do not include every detail of every policy but rather seeks to cover the essential provisions of the policies and procedures of VCOM and are to be considered VCOM policy. VCOM reserves the right to make changes in any policy and procedure as approved by the President and Provost and confirmed by the Board. Such changes take precedence over Handbook statements. While reasonable effort is made to publicize such changes, it is the responsibility of the reader to verify the current policy or procedure.

Table of Contents VCOM Policies and Procedures Effective and Revised Dates Table Board Policies and Procedures B001 VCOM Policy on Conflicts of Interest B002 VCOM Gift Acceptance Policy B003 VCOM Investment Policy B004 VCOM Policy on Red Flag Identity Theft Prevention Program B005 VCOM Policy Governing the VCOM Retirement Plan B007 VCOM Reporting of Misconduct or Financial Fraud Policy B008 VCOM Compensation Survey Policy B009 VCOM Policy on Chapters, Affiliates and Branch Campus Governance B010 Policy to Review VCOM’s Mission and Strategic Plan B011 VCOM Policy Governing Board of Directors Meeting Research Policies and Procedures R001 VCOM Transfer of Equipment Policy R002 VCOM Policy on Using Controlled Substances for Research R003 Policy and Procedures for Responding to Allegations of Scientific Misconduct R004 VCOM Institutional Review Board Policies and Procedures R004A1 VCOM Policy on Institutional Review Board Self-Assessment R004A2 VCOM Policy on Emergency Use of a Test Article R004A3 VCOM Policy on IRB Member Conflict of Interest R004A4 VCOM Policy on IRB Administrative Fees for Protocol Review R004A5 VCOM Policy on Compliance Auditing R004A6 VCOM IRB Guidance on Research Limited to Retrospective Medical Record Reviews R004A7 VCOM Procedure on Conducting and Documenting Continuing Review R004A8 VCOM Policy on Humanitarian Use Devices R005 Intellectual Properties and Agreements Policies and Procedures R006 Office of Research Administration Grants Administration Policies and Procedures R007 Cost Sharing On Sponsored Projects R008 Time and Effort Certification (Effort Reporting) Policy R009 VCOM Policy on Facilities and Administration (F&A) Distribution R010 Facilities and Administrative Cost Recovery Policy R011 VCOM Student Research Investigator Policy R012 VCOM Policies and Procedures Governing Environmental Health & Safety R013 Financial Conflicts of Interest in Research

R014 Office of Research Administration Residual Policy R015 VCOM Consistency in Charging Administrative and Clerical Costs Policy R016 VCOM Policy on Case Reports and Case Series R017 VCOM Policy on Cost Principles for Sponsored Projects IRB Procedures VCOM Procedure on Central Institutional Review Board (CIRB) Facilitated Review VCOM Procedure on IRB Review of Applications for HHS Support VCOM Procedure on Obtaining Informed Consent VCOM Procedure on Reporting of Compliance Audit Review Standard Operating Procedure VCOM Procedure on Review of Investigational Device Protocols Faculty Policies and Procedures

VCOM Policy on Faculty Recruitment VCOM Academic Visitor Policy and Procedure VCOM Faculty Adequacy Policy VCOM Statement on Professional Ethics VCOM Policy on Presentation of Instructional Materials

F001 F003 F004 F005 F006 F007 F008 F013 F014

VCOM Faculty Appointment, Promotion, and Tenure Policy and Procedures VCOM Faculty Misconduct and Disciplinary Action Policy and Procedures VCOM Policy on Faculty Responsibility to the College VCOM Campus Faculty Assembly, Campus Faculty Senate, and College-wide Faculty Senate Policy and Procedures VCOM Notice of Nondiscrimination and Diversity VCOM Academic Freedom Policy VCOM Policy on Educational Aid for Employees VCOM Copyright and Fair Use of Instructional Materials Policy VCOM Federal Funds Procurement Policy VCOM Policy on Social Media Usage VCOM On-Campus Electronic Communication Policy VCOM Computer Support Policy VCOM IT Equipment Procurement/Asset Management and Configuration Policy and Procedures VCOM Alcohol and Drug Testing and Abuse Prevention Policy VCOM Discrimination, Harassment, and Violence Policy and Procedures

Universal Policies and Procedures U001 U002 U003 U004 U005 U006 U007 U008 U009 U010 U011 U013 U014

VCOM Census Date Policy and Procedures VCOM Consensual Relationship Policy

VCOM Policy on Conflicts of Interest and Industry Relationships VCOM Code of Ethics VCOM Statement on Professional Ethics for Administrative and Classified Staff VCOM Policy on Medical Treatment of Students and Employees VCOM Employee Work Hours and Overtime Policy VCOM Credit Card Policy VCOM Records Retention Policy VCOM Business Travel and CME /CE Travel Policy VCOM Policy on Solicitations, Surveys, and the Use of College Outcomes VCOM Policy on Staff Recruitment VCOM Policy on the Collection and Review of Employee Driving Records VCOM Employee Grievance Policy and Procedure VCOM Policy on Financial Management of Federal Funds VCOM Policy on the Principles, Rules, and Guidelines for Committees VCOM Policy and Procedures on Complaints Related to Accreditation Standards VCOM Crime Statistics Report and Annual Security Report Policies and Procedures VCOM Policy on Health and Safety VCOM Policy on Workplace Site Expectations, Requirements, and Working Remotely

U015 U016 U017 U018 U019 U020 U021 U022 U023 U024 U025 U026 U027 U028 U029 U030 U031 U032 S002 S003 S004 S005 S006 S007 S008 S009 S010

Student Policies and Procedures S001

VCOM Admissions Policy for the Doctor of Osteopathic Medicine Program

VCOM Attendance Policy

VCOM Mandatory Medical Leave of Absence Policy and Procedures

VCOM Disciplinary Sanctions Policy

VCOM Transfer Student and Transfer of Credit Policy

VCOM Policy for Satisfactory Academic Progress and Financial Aid Eligibility VCOM Policy and Procedures on Tuition and Fees Refunds for the Doctor of Osteopathic Medicine Program

VCOM Credit Hour Policy

VCOM Policy on Assuring the Clinical Education Curriculum

VCOM International Student Policy

S012 VCOM Technical Standards for Admission and Successful Completion of the Osteopathic Program Policy S013 VCOM Minimal Health Requirements for Admission and Continued Enrollment Policy S014 VCOM Code of Conduct/Professional and Ethical Behavior Policy S015 VCOM Professional and Ethical Standards Board Policy and Procedures S016 VCOM Policy on Performing Patient Care Activities

S017 S018

VCOM Student Health and Counseling Services Policy

VCOM Grading, Satisfactory Academic Progress, and Graduation Requirement Policy and Procedures

S019 VCOM Student Promotion Board Policy and Procedures Graduate Medical Education Policies and Procedures G001 VCOM Policy for Planning and Promoting Graduate Medical Education

Edward Via College of Osteopathic Medicine Policies and Procedures

Effective and Revised Dates

Board Policies

Original Approval Date December 8, 2008

Revised Date(s)

B001 Policy on Conflicts of Interest

April 15, 2016 June 2011; November 2011

B002 Gift Acceptance Policy

June 1, 2009

B003 Investment Policy

June 1, 2009

November 2011; December 13, 2013; July 7, 2015; November 1, 2016

B004 Policy on Red Flag Identity Theft Prevention Program B005 Policy Governing the VCOM Retirement Plan

March, 2009 January 2002

June 1, 2011 April 2003; April 2009; April 2011

B007 Reporting of Misconduct or Financial Fraud Policy

May 31, 2011 May 31, 2011 May 31, 2011

B008 Compensation Survey Policy

B009 Policy on Chapters, Affiliates and Branch Campus Governance B010 Policy to Review VCOM’s Mission and Strategic Plan B011 VCOM Policy Governing Board of Directors Meetings

April 1, 2015

November 21, 2011 November 1, 2016

December 1, 2020

Research Policies

Original Approval Date

Revised Date(s)

R001 R002

VCOM Transfer of Equipment Policy

August 25, 2014

VCOM Policy on Using Controlled Substances for Research

June 1, 2007

February 13, 2012; October 28, 2013 February 1, 2012; October 28, 2013

R003

Policy and Procedures for Responding to Allegations of Scientific Misconduct

January 2, 2003

R004

VCOM Institutional Review Board Policies and Procedures

March 1, 2007

July 1, 2012; August 1, 2021

R004A1 VCOM Policy on Institutional Review Board Self-Assessment R004A2 VCOM Policy on Emergency Use of a Test Article R004A3 VCOM Policy on IRB Member Conflict of Interest R004A4 VCOM Policy on IRB Administrative Fees for Protocol Review R004A6 VCOM IRB Guidance on Research Limited to Retrospective Medical Records Reviews R004A7 VCOM Procedure on Conducting and Documenting Continuing Review R004A5 VCOM Policy on Compliance Auditing

July 1, 2007 April 1, 2007 April 1, 2007 April 1, 2007

November 1, 2007

March 1, 2008

February 13, 2012

R004A8 VCOM Policy on Humanitarian Use Devices

April 12, 2024

R005

Intellectual Properties and Agreements Policies and Procedures

September 1, 2006

February 1, 2012; May 1, 2013; November 11, 2013; August 23, 2022 February 1, 2012; October 28, 2013 February 1, 2012; March 10, 2014 February 1, 2012; March 10, 2014 February 1, 2012; March 10, 2014 February 1, 2012; October 30, 2013; October 31, 2014 February 1, 2012; October 30, 2013 February 10, 2012; October 28, 2013 November 21, 2016

R006

Office of Research Administration Grants Administration Policies and Procedures

February 2, 2004

R007

Cost Sharing on Sponsored Projects

December 1, 2004

R008

Time and Effort Certification (Effort Reporting) Policy

January 14, 2005

R009

VCOM Policy on Facilities and Administration (F&A) distribution

January 1, 2006

R010

Facilities and Administrative Cost Recovery Policy

February 28, 2006

R011

VCOM Principal Investigator Eligibility Policy

February 28, 2006

R012

VCOM Policies and Procedures Governing Environmental Health & Safety

May 23, 2007

R013 R014 R015 R016 R017

Financial Conflicts of Interest in Research

November 1, 2013 September 15, 2014

Office of Research Administration Residual Policy

VCOM Consistency in Charging Administrative and Clerical Costs Policy

August 15, 2014 October 1, 2019 August 1, 2019

VCOM Policy on Case Reports and Case Series VCOM Policy on Cost Principles for Sponsored Projects

IRB Procedures VCOM Procedure on Central Institutional Review Board (CIRB) Facilitated Review VCOM Procedure on Reporting of Compliance Audit Review Standard Operating Procedure

October 15, 2009 October 15, 2009

VCOM Procedure on Obtaining Informed Consent

October 15, 2009

VCOM Procedure on IRB Review of Applications for HHS Support VCOM Procedure on Review of Investigational Device Protocols

October 15, 2009

May 18, 2010

Faculty Policies

Original Approval Date

Revised Date(s)

F001 Policy on Faculty Recruitment

October 1, 2009

January 23, 2013; December 1, 2020; May 5, 2023; October 31, 2023 November 14, 2012 July 15, 2011; November 13, 2012; March 20, 2015 November 14, 2012; October 10, 2015; February 15, 2019 November 13, 2012; January 23, 2013; March 20, 2015; October 10, 2015; May 5, 2016; September 10, 2017; December 15, 2017; April 5, 2021; June 28, 2022; November 14. 2022 November 7, 2012; October 10, 2015; February 15, 2019; May 5, 2023; November 8, 2023 November 20, 2012; October 10, 2015; February 15, 2019; May 5, 2023 November 20, 2012; March 20, 2014; January 15, 2019; December 1, 2020; September 1, 2023 March 1, 2020; March 15, 2021;

F003 Academic Visitor Policy and Procedure

July 2, 2009

F004 Faculty Adequacy Policy

November 21, 2001

F005 Statement on Professional Ethics

November 30, 2001

F006 VCOM Policy on Presentation of Instructional Materials

June 10, 2016

F007 VCOM Faculty Appointment, Promotion, and Tenure Policy and Procedures

November 30, 2001

F008 VCOM Faculty Misconduct and Disciplinary Action Policy and Procedures

November 30, 2001

F013 VCOM Policy on Faculty Responsibility to the College

November 30, 2001

F014 VCOM Campus Faculty Assembly, Campus Faculty Senate, and College-wide Faculty Senate Policy and Procedures

November 30, 2001

Universal Policies

Original Approval Date November 30, 2001

Revised Date(s)

U001 Notice of Nondiscrimination and Diversity

November 14, 2012; February 19, 2013; January 6, 2014; September 9, 2015; September 10, 2016; March 1, 2018; November 20, 2012; February 15, 2019; December 1, 2020; May 5, 2023 July 20, 2011; September 20, 2015; November 1, 2016; September 20, 2018; August 20, 2018 June 30, 2011; June 29, 2012; November 20, 2012; January 15, 2019; January 12, 2023 December 19, 2012; January 1, 2022: January 12, 2023 December 19, 2012 December 19, 2012 November 7, 2012; December 19, 2012 November 14, 2012; September 9, 2015; March 1, 2018; January 12, 2023 November 14, 2012; October 10, 2015; August 20, 2018; February 15, 2019; August 14, 2020 November 26, 2012; August 20, 2018: January 12, 2023 August 12, 2013 August 20, 2018; August 14, 2020 August 2011; December 2011; August 20, 2014

U002 VCOM Academic Freedom Policy

November 20, 2001

U003 Policy on Educational Aid for Employees

July 1, 2009

U004 VCOM Copyright and Fair Use of Instructional Materials Policy

November 30, 2001 and October 1, 2010

U005 Federal Funds Procurement Policy

December 17, 2010

U006 Policy on Social Media Usage

September 15, 2011

U007 On-Campus Electronic Communication Policy

September 15, 2011 February 15, 2012 September 15, 2011

U008 Computer Support Policy

U009 IT Equipment Procurement/Asset Management and Configuration Policy and Procedures

U010 Alcohol and Drug Testing and Abuse Prevention Policy

June 10, 2005

U011 VCOM Discrimination, Harassment, and Violence Policy and Procedures

November 30, 2001

U013 Census Date Policy and Procedures U014 VCOM Consensual Relationship Policy

November 14, 2012 November 30, 2001

U015 VCOM Policy on Conflicts of Interest and Industry Relationships

August 1, 2005

May 17, 2011; December 10, 2013; May 27, 2014; September 15, 2014; June 30, 2015; January 12, 2023 November 14, 2012; September 9, 2015; August 20, 2018; April 28, 2023 October 1, 2015 December 5, 2022

U016 VCOM Code of Ethics

December 1, 2004

U017 Statement on Professional Ethics for Administrative and Classified Staff

March 1, 2014

U018 VCOM Policy on Medical Treatment of Students and Employees U019 VCOM Employee Work Hours and Overtime Policy

July 1, 2016

July 1, 2016

December 1, 2016

December 1, 2017 December 5, 2022

U020 VCOM Credit Card Policy U021 VCOM Records Retention Policy

August 23, 2016

April 8, 2011

May 31, 2011; March 1, 2017 March 10, 2020; July 24, 2023; April 10, 2024 January 1, 2022

U022 VCOM Business Travel and Continuing Medical Education/Continuing Education Travel Policy

March 1, 2018

U023 VCOM Policy on Solicitations, Surveys, and the Use of College Outcomes

October 20, 2020 December 1, 2020

U024 VCOM Policy on Staff Recruitment

U025 VCOM Policy on the Collection and Review of Employee Driving Records

April 19, 2019

U026 VCOM Employee Grievance Policy and Procedure

November 30, 2001

November 14, 2012; October 10, 2015; February 15, 2019; May 5, 2023

U027 VCOM Policy on Financial Management of Federal Funds

August 1, 2019 October 20, 2019 February 11, 2012

U028 VCOM Policy on the Principles, Rules, and Guidelines for Committees U029 VCOM Policy and Procedures on Complaints Related to Accreditation Standards

November 14, 2012; March 1, 2016; August 15, 2017; March 1, 2018; December 1, 2020; August 13, 2023; November 28, 2023

U030 VCOM Crime Statistics Report and Annual Security Report Policies and Procedures

January 1, 2021

U031 VCOM Campus Safety and Health Policy

January 11, 2021

May 1, 2023

U032 VCOM Policy on Workplace Site Expectations, Requirements, and Working Remotely

July 11, 2022

Student Policies

Original Approval Date

Revised Date(s)

S001 Admissions Policy for the Doctor of Osteopathic Medicine Program

July 1, 2002

July 1, 2011; February 18, 2013; August 15, 2015; July 27, 2017; March 1, 2018; August 20, 2018; September 1, 2019; December 1, 2020; July 15, 2011; January 6, 2014; September 9, 2015; May 5, 2016; August 30, 2016; July 27, 2017; March 1, 2018; November 20, 2019; June 1, 2020; September 15, 2021; July 1, 2022; September 1, 2023 November 18, 2021 April 12, 2022; January 9, 202 August 2008; June 30, 2011; January 6, 2014; July 1, 2017; February 1, 2019 July 1, 2011; January 30, 2014; September 9, 2015; August 20, 2018; December 1, 2020 September 1, 2011 December 2008; May 2011; December 10, 2012; August 1, 2021 July 1, 2012; May 3, 2016; November 16, 2016; August 20, 2018; December 1, 2020

S002 Attendance Policy

November 20, 2001

S003 VCOM Mandatory Medical Leave of Absence Policy and Procedures

February 1, 2019 November 30, 2001

S004 Disciplinary Sanctions Policy

S005 Transfer Student and Transfer of Credit Policy

January 5, 2005

S006 Policy for Satisfactory Academic Progress and Financial Aid Eligibility (Osteopathic Medicine Program) S007 VCOM Policy and Procedure on Tuition and Fees Refund for the Doctor of Osteopathic Medicine Program

November 31, 2001

November 30, 2001

S008 Credit Hour Policy

July 2, 2011

S009 VCOM Policy on Assuring the Clinical Education Curriculum

January 1, 2021

S010 VCOM International Student Policy

November 30, 2001

S012 Technical Standards for Admission and Successful Completion of the Osteopathic Program and Accommodations for Students with Disabilities Policy

November 30, 2001

November 14, 2012; August 20, 2015; July 1, 2017; March 1, 2018; August 20, 2018; September 1, 2019; November 18, 2021; March 21, 2022; November 8, 2023; January 22, 2024 November 14, 2012; January 6, 2014; August 25, 2014; September 9, 2015; October 10, 2018 July 1, 2022; October 26, 2022; February 1, 2024 November 14, 2012; January 6, 2014; September 9, 2015; May 5, 2016; October 15, 2016; December 1, 2020; November 18, 2021; February 8, 2022 November 14, 2012; September 9, 2015; October 25, 2016; November 18, 2021; February 8, 2022 November 26, 2012; August 1, 2017; March 1, 2018; August 20, 2018; December 1, 2020 November 26, 2012; March 1, 2018; January 15, 2019; December 1, 2020; July 1, 2023 April 2008; November 26, 2012; May 3, 2016; March 1, 2018; November 15, 2019; December 1, 2020;

S013 VCOM Minimal Health Requirements for Admission and Continued Enrollment Policy

November 30, 2001

S014 Code of Conduct/Professional and Ethical Behavior Policy

July 1, 2003

S015 Professional and Ethical Standards Board Policy and Procedures

July 7, 2002

S016 Policy on Performing Patient Care Activities

November 30, 2002

S017 Student Health and Counseling Services Policy

June 10, 2005

S018 VCOM Grading, Satisfactory Academic Progress, and Graduation Policy and Procedures

February 22, 2006

June 1, 2021; July 1, 2022;

August 23, 2022; July 1, 2023; November 21, 2023 April 2008; November 26, 2012; November 11, 2013; September 9, 2015; June 10, 2016; May 1, 2018;

S019 Student Promotion Board Policy and Procedures

February 22, 2006

March 15, 2021; August 1, 2022

Graduate Medical Education Policies

Original Approval Date

Revised Date(s)

G001 Admissions Policy for the Doctor of Osteopathic Medicine Program

March 1, 2020

December 1, 2020

VCOM Policy and Procedure

Policy #B001

Conflict of Interest Disclosure Form I am not aware of any existing or potential conflicts of interest that might impair or reasonably appear to impair my independent, unbiased judgment in the discharge of my responsibilities to VCOM.

________________________________

___________________

Signed

Date

________________________________ Printed Name

I disclose to VCOM that the following existing or potential conflicts of interest might impair or reasonably appear to impair my independent, unbiased judgment in the discharge of my responsibilities to VCOM.

________________________________

___________________

Signed

Date

________________________________ Printed Name

I disclose to VCOM that a member of my family, or an organization in which I or a member of my family is an officer, director, employee, member, partner, trustee, or controlling stockholder has the following existing or potential interest that might impair or reasonably appear to impair my independent, unbiased judgment in the discharge of my responsibilities to the University.

________________________________

___________________

Signed

Date

________________________________ Printed Name

VCOM Conflict of Interest Policy

Page 3 of 3

Edward Via College of Osteopathic Medicine

Policy Order No.: B002 Effective Date: June 1, 2009 Revised:

June 2011, November 2011

Signature on File ____________________________ Dixie Tooke-Rawlins, D.O. Dean and Executive Vice President

Signature on File ___________________________ James F. Wolfe, Ph.D. President ___________________________________________________________________________________________

VCOM Gift Acceptance Policy ____________________________________________________________________________________

1. P URPOSE The Gift Acceptance Policy is designed to ensure that all gifts to, or for the use of, Edward Via College of Osteopathic Medicine (VCOM) are structured to provide maximum benefits for both the donor and the College. Due to the ever-increasing complexity of giving plans and concepts, this policy has been developed to establish standards by which all gifts to VCOM will be evaluated.

2. E VALUATION OF G IFTS All gifts to VCOM will be evaluated within the following guiding principles:

1. VCOM does not provide legal, accounting, tax or other such advice to donors. Each donor is ultimately responsible for ensuring their proposed fits meets and furthers their charitable, financial, and estate planning goals. Therefore, each donor is encouraged to meet with a professional advisor before making any gift to the College. 2. VCOM reserves the right to refuse certain gifts, including: a. Those which would not be in the best interest of the donor (i.e., ones that might be inappropriate in light of the donor’s personal or financial situation). b. Those that might benefit the donor in certain ways that are not available to those of similar status and interest. c. Those from which VCOM will realize little or no financial gain. d. Those that are offered for purposes inconsistent with the College’s mission. e. Those which have restrictions that might violate VCOM’s ethical standards or require any form of discrimination. 3. Donations of gifts for unrestricted, general purposes are encouraged because of the flexibility they provide the College. 4. VCOM shall acknowledge all gifts and donations in a manner that respects and honors the donor.

5. In accepting a gift, VCOM accepts the responsibility to provide proper stewardship of the gift. This includes administering the gift properly, providing the donor with accurate, timely financial information about the gift and, when appropriate, reporting to the donor about the use of the gift. 2.1 Gift Acceptance Committee The Administrative Development Team consisting of the President, the Dean and Executive Vice President, the Director of Alumni and Development and the Associate Vice President for Financial (CFO) will function as the gift acceptance committee. T ERMS AND D EFINITIONS Conditional Gift A gift that, because of some qualifier or restriction, is considered non - routine. Condi tional gifts may commit the College to act within a specified time or use the gift for a specific purpose. Endowment A gift of at least $10,000 to be invested for the purpose of producing present and future income that may be expended or reinvested with the original gift. The principal (or corpus) of the endowment is to be kept intact. Income is expended according to the current policy of the College and may be restricted or unrestricted according to the donor’s intent. 3. Any transfer of personal or r eal property made on a voluntary basis and without consideration received in return. A gift is not a payment for goods or services received, nor payment made to directly benefit a pre - selected individual, such as a scholarship for a specific student select ed by the payer. In case of payments which are part gift and part payment for goods or services, the College’s policy is to include such differentiation in printed materials for events and gift receipts. Typically gifts of cash, stocks, bonds, real property, tangible personal property, or gifts - in kind. Generally gifts or commitments made in the present with the benefit to the College “deferred” until a future date. Commitment to give a specific dollar amount according to a fixed time schedule. Any gift on which a donor places special, out - of - the - ordinary restrictions as to its use. Discriminatory restrictions could cause VCOM to lose its tax - exempt status or the donor to lose the charitable in come tax deduction for the gift. Each restricted gift is accounted for as a separate self - balancing fund. 4.1 Gift Acknowledgement The College’s Office of Alumni and Development will send acknowledgement letters and receipts within a reasonable interval. When appropriate, donors may be given tokens of appreciation not to exceed federal requirements. The Office of Alumni and Development is responsible for oversight and compliance with the requirements regarding gift acknowledgement and receipts. 4.2 Evaluation of Costs Associate with Acceptance of Certain Gifts Proposed gifts of property and gifts-in-kind must be evaluated to determine whether the costs to VCOM associated with receiving the gift can be accommodated prudently. Such evaluations might include the cost maintenance and repair, insurance and cost of disposal. Outright Gift Planned Gift Pledge Restricted Gift 4. G ENERAL P OLICIES Gift

For example, accepting real property might require payment of closing costs and an environmental assessment, payoff of debt secured by the property, and physical changes to the property necessary to ensure safety or to control environmental hazards. Similarly, the cost to retrofit space on campus and provide necessary utilities associated with a proposed gift may be excessive. Associated costs could be so high that it would be to VCOM’s disadvantage to accept a gift. The authority and responsibility for prompt, careful evaluation of such costs rests with the CFO, who shall, after conferring with appropriate campus offices, bring the gift proposal to Administrative Development Team for review and for a decision. 4.3 Administration of Restricted Gifts Frequently, donors require the College to use gifts in particular ways. It is the responsibility of VCOM to comply with such arrangements if such a gift is accepted. The CFO and Finance Division are responsible for ensuring restricted gifts are spent in accordance with the donors’ wishes. 4.4 Memorandum of Understanding Before completing major and/or planned gift arrangements with donors, a member or members of the Administrative Development Team and the donor will sign a memorandum of understanding, which shall contain the following elements:

The purpose for the gift; The background behind the gift; How funding will occur; Criteria specifying who will benefit;

VCOM’s responsibilities;

Use(s) of the gift;

 Academic year of activation; and  Plan for public announcement of the gift.

4.5 Qualified Appraisals Legal and ethical requirements prohibit VCOM from appraising gifts. This protects both the donor and the College. Such appraisals are to be conducted by certified, independent appraisers not associated in any way with VCOM. The cost shall be the donor’s responsibility. G IFT A CCEPTANCE P OLICY The following policies relate to the types of gifts typically received by a medical school. It is understood that special gifts or circumstances might require a case-by-case review by the Administrative Development Team and may not be addressed by this document. 5.

5.1 Outright Gifts

Cash Cash is often the easiest way to give and the form of gift most frequently accepted by the College. These gifts can take the form of currency, check, or credit card contribution. Cash may be delivered in person, by mail, by Electronic Funds Transfer (EFT), or by w ire transfer. Cash (currency or check) gifts are reported the day VCOM receives the cash. For EFTs or wire transfers, the dates of the gifts shall be the date the money is transferred into VCOM’s bank account. Gifts remitted through credit cards are report ed the day the gift is received. Gifts of Insurance VCOM will accept life insurance policies as gifts only when the College is names as the irrevocable owner and sole beneficiary of the policy. VCOM prefers life insurance policies that are fully paid. Tho se gifts will be valued at the replacement cost of the policy. All partially paid policies must have written explanation of how further premiums are to be paid. Gifts of partially paid life insurance policies shall be presented to an approved by the Admini strative Development Team prior to gift acceptance. Partially paid life insurance policies will be valued at ht surrender value of the policy the day the gift transaction is completed. Personal Property Please refer to the section above regarding costs as sociate with acceptance of certain gifts.

Gifts of personal property and gifts - in - kind include but are not limited to such times as precious metals, jewelry, artwork, collections and equipment. Gifts of personal property shall be sold or used for the benef it of VCOM, at the sole discretion of the Administrative Development Team. The VCOM Finance Division, with direction from the Office of Alumni and Development, is responsible for issuing the Form 8283 (Non - cash Charitable Contributions) to the donor, and f or issuing the Form 8282 (Donee Information Return) to the Internal Revenue Service. The Form 8282 will be issued in the event the gift of personal property is sold within two years of the date of gift. The Administrative Development Team shall accept gifts of residential, rental, commercial, industrial, or agricultural real estate after proper review. Prior to acceptance, an independent appraisal for all properties is required. Any costs associated with obtaining a certified appraisal shall be the responsibility of the donor. VCOM will accept these appraisals unless the reviewers believe a second appraisal is warranted. In that case, VCOM will be responsible for all costs of the second appraisal. The aver age of the two independent appraisals will be considered to constitute the “fair market value” of the real estate, and thus the value of the gift. No gift of real estate encumbered by a mortgage or lien shall be accepted. No property will be accepted tha t has violations of local, state, or federal laws. There must be a clear title to the property, one not encumbered by recorded of unrecorded rights of way or easements. If VCOM cannot make use of gifted property, the CFO will handle the sale in a prudent and timely manner to maximize the benefit of the gift. Prior to closing the Administrative Development Team must review all potential sales of real estate that would result in net proceeds less than or equal to 80% of the gift value. All gifts of real est ate shall be evaluated in light of the need for an environmental assessment whose cost shall be borne by the donor. A qualified environmental professional will be hired to conduct the assessment. In the unlikely event that the gifted real estate incurs env ironmental clean - up expenses, under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) or any similar

Real Estate

legislation before or after the gift transfer has occurred, the College retains the right and authority to seek reimburseme nt. In the event a donor is giving a retained life estate gift, the donor shall pay all or a part of the property’s maintenance costs, real estate taxes and insurance for the duration of his/her life and acknowledge that in writing prior to VCOM’s accepta nce of the gift. Securities or mutual funds that are traded on any recognized stock exchange or have prices quoted daily and are readily marketable will be accepted as outright gifts or towards a pledge. The value of said securities is determined by averaging the high and low trading price on the day the securities are received by the College in accordance with established IRS regulations. All proposed gifts of closely held securities must be examined prior to acceptance for valuation a nd marketability and approved by the Administrative Development Team prior to acceptance. Pledges are commitments to give a specific dollar amount according to a fixed time schedule. Annual fund pledges are usually for less than one year. All othe r pledges must have written documentation that contains the following:  The amount of the pledge clearly specified;  A clearly defined payment schedule;  No contingencies or conditions;  The financial capability of the donor to make the gift; and  Acknowledgement of any naming opportunity associated with the pledge, and the removal of that opportunity if for any reason the pledge is not completed within the agreed upon payment schedule. 1. Anticipated matching gifts will not be included in pledge amounts. 2. Pledges and expected matching gifts will qualify separately for donor recognition in appropriate giving level groups. 3. For gift recognition purposes, pledging donors will be recognized in accordance with their wishes and as d eemed prudent by the Office of Alumni and Development. This recognition may occur before or after the entire pledge gift is received. 4. If for any reason (rounding, gift evaluation, or continued incremental giving), the pledge amount is altered, the donor wi ll be recognized at the level of final payment. 5. In the event of death, pledge balances will be written off when the College is notified, unless there are provisions in the donor’s will or the family has indicated an intent to complete the pledge. 6. All reque sts to deactivate a pledge must be present to, and approved by, the Administrative Development Team.

Securities

Pledges

Pledge Recording Policies

5.2 Planned Gifts Donors are encouraged to disclose their bequest intentions to the Office of Alumni and Development in writing to ensure the College is able to carry out their wishes and that the gifts conform to the principles stated in this Gift Acceptance Policy.

If a gift from the estate of a deceased donor who has not disclosed his/her intentions does not meet the principles of this Gift Acceptance Policy, the College’s concerns will be communicated to the legal representative of the estate and attempts will be made to achieve a mutually acceptable gift agreement. Life Insurance VCOM must be named as both the beneficiary and irrevocable owner of an insurance policy before a life insurance policy can be treated as a gift. The gift is values at its interpolated terminal reserve value, or cash surrender value, upon receipt. If the donor contributes future premium payments, the College will include the entire amount of the additional premium payment as a gift in the year that is made. If the donor does not elect to continue to made gifts to cover premium payments on the insurance policy, the College may:  Continue to pay the premiums;  Convert the policy to paid up insurance; or  Surrender the policy for its current cash value.

Charitable Gift Annuities

VCOM may offer charitable gift annuities. The minimum gift for funding is normally $10,000. The minimum age for life income beneficiaries of a gift annuity shall be 55. Where a deferred gift annuity is offered, the minimum age for life income beneficiaries shall be 45. No more than two life income beneficiaries will be permitted for any gift annuity. Generally, annuity payments may be made on a quarterly, semi-annual, or annual schedule. Funds contributed in exchange for a gift annuity shall be set aside and invested during the term of the annuity payments. Once those payments have terminated, the funds representing the remaining principal contributed in exchange for the gift annuity shall be transferred to the College’s unrestricted funds, or to such specific fund as designated by the donor. The college may accept designation as remainder beneficiary of a charitable remainder trust with the approval of the Administrative Development Team. The College will not accept appointment as Trustee of a charitable remainder trust. The College may accept designation as income beneficiary of a charitable lead trust. The College will not accept appointment as Trustee of charitable lead trust. Bequests will not be recorded as gifts to the College until the gifts are irrevocable. When the gifts are irrevocable, but are not due until future dates, the present value of those gifts may be recorded at the time the gifts becomes irrevocable.

Charitable Remainder Trusts

Charitable Lead Trusts

Bequests

6. D URATION OF P OLICY The Gift Acceptance Policy established by the Department of Finance and the Alumni and Development Department, approved by the Board of Directors, and is effective as of the date above and shall remain effective until amended or terminated by the Board of Directors.

VCOM Policy and Procedure

Policy #B003

Edward Via College of Osteopathic Medicine

Policy Order No.: Effective Date:

B003

June 1, 2009

Revised:

November 2011; December 13, 2013; July 7, 2015; November 1, 2016

Signature on File ________________________ Dixie Tooke-Rawlins D.O. President and Provost

Developed by Investment Committee Members: Mr. John Rocovich, Chairman of the Board, Dixie Tooke-Rawlins, D.O., President; Mr. Ray Smoot BOD and Investment Committee Member, Charles Swaha, Chief Financial Officer and Lesia Brolinson, Investment Consultant. ________________________________________________________________________________ VCOM Investment Policy ________________________________________________________________________________ 1. PURPOSE………………………………………………………………………………………...2 2. PHILOSOPHY…………………………………………………………………………………...2 3. OBJECTIVES……………………………………………………………………………………2 4. GENERAL PRINCIPLES………………………………………………………………………2 5. GOALS FOR RETURNS ON INVESTMENTS……………………………………………….3 6. ASSUMPTIONS………………………………………………………………………………….3 7. DELEGATION OF AUTHORITY……………………………………………………………..3 8. ASSIGNMENT OF RESPONSIBILITY……………………………………………………….4 8.1 Responsibility of the President and CFO………………………………………………….4 8.2 Responsibility of Investment Consultant (s)………………………………………………4 8.3 Responsibility of Investment Manager(s)…………………………………………………5 9. INVESTMENT GUIDELINES…………………………………………………………………5 9.1 Allowable Assets for Long Term Reserves….……………………………………………5 9.2 Allowable Assets for Short Term Reserves.………………………………………………6 9.3 Prohibited Assets for Long Term Reserves and Short Term Reserves................................6 9.4 Prohibited Transactions for Long Term Reserves and Short Term Reserves………….….6 9.5 Stock Exchanges for Long Term Reserves and Short Term Reserves………..…………..6 9.6 Asset Allocation Guidelines for Long Term Reserves….………………………...………7 9.7 Asset Allocation Guidelines for Short Term Reserves……….…………………………...7 9.8 Cost………………………………………………………………………………………..7 9.9 Transferring of Assets to VC Endowment Trust………………………………….....……7 10. DURATION OF POLICY……………………………………………………………………….7

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1. PURPOSE The purpose of the investment policy is to outline an investment philosophy and attitude, which will guide the management of the investment of excess or liquid assets toward the desired results. The policy is intended to be sufficiently specific to be meaningful, yet flexible enough to be practical. This policy reflects the investment objectives and constraints by describing the following: a. Define and assign the responsibilities of all involved parties b. Establish a clear understanding for all involved parties of the investment goals and objectives c. Offer guidance and limitations to all Investment Managers regarding the investments d. Manage investments according to prudent standards as established in common trust law e. Establish the relevant time horizon for which investments will be managed. A budget should be established by the President and CFO predicting cash needs and operating expenses for the school for the subsequent 12 month period. The time horizons should be managed as follows: a. Short Term Reserves: Assets that are expected to be needed within the next 3 to 12 months for operating expenses b. Mid Term Reserves: Assets that are deemed as may be needed within the next 24 months for operating expenses c. Long Term Investments: Assets that are not expected to be needed until a minimum of 36 months and beyond The VCOM investment policy of is overseen by the investment committee with final approval by the Board of Directors. 2. PHILOSOPHY VCOM’s investment philosophy is to preserve principal while seeking a modest increase through appreciation and income. Market conditions will be assessed periodically to ascertain if investments or the mix of investments should be changed. Any change in investments will include an assessment of the increase or decrease of risks associated with the change. For example, the precipitous drop in the major stock market indices in late 2007 could have triggered a review of investments. Selling stocks and investing in safer instruments, such as certificates of deposits, Treasury bills and notes, to mitigate the risks of further declines in the value of equity or stock investments may have been an appropriate response. 3. OBJECTIVES The primary objective is the preservation of capital or principal. The second objective is to earn modest income on investment principal. The third objective is the growth of investments through appreciation. The emphasis of the investment strategy is total return; that is, the aggregate return from capital appreciation and dividend and interest income. 4. GENERAL PRINCIPLES a. Investments shall be made solely in the interest of VCOM b. Investments shall be made with care, skill, prudence and diligence under the circumstances then prevailing that a prudent man or woman acting in a like capacity and familiar with such matter would use with similar characteristics and aims

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c. Investments shall be so diversified as to minimize the risk of large losses, which may also minimize the opportunity for large gains d. Cash or cash equivalents (short term) investments shall be employed productively at all times to provide safety and return; however allowing liquidity of funds when needed e. Moderate-term investments are those funds invested by VCOM, however maintained with the assurance of funds will be made available when needed and are generally kept for a twelve to twenty four month period; however invested in a manner where emergent funds may be obtained (liquidity) without great expense or loss. f. Funds that are not anticipated to be utilized for operations for a period of twenty four months or greater are transferred to the VC Endowment Trust from time to time; and are transferred only when determined by the Investment Committee and the Board as not anticipated to be required for operations of the College over a period of twenty four months or greater. 5. GOALS FOR RETURNS ON INVESTMENTS In typical economic conditions, all investments should attain or exceed the average of the appropriate standard benchmarks which must be identified in their respective portfolios by the Investment Advisor(s) and Manager(s). When reporting performance each manager must include comparisons of their returns to the appropriate indexes that are comparable to their portfolios. Overall, returns on the entire portfolio of investments should be calculated using a weighted-average methodology 6. ASSUMPTIONS a. Any VCOM investable deposits that exceed operating expense needs (less than 24 months) will be placed in the long term investment portfolio at the discretion of the President and the investment committee of the board. b. All parties that interact with VCOM on the management of its investment assets have fiduciary duty to act solely in the best interests of VCOM. VCOM’s investment committee of the board shall review the investments semi-annually and keep minutes and fiduciary files in order to ensure that everyone involves with the management of the investments is acting in the best interests of VCOM. c. VCOM shall liquidate investments to meet specific organizational goals and objectives, satisfy the wishes of the investment committee of the board as determined by the President and reported to the board at the regular semi-annual meetings. 7. DELEGATION OF AUTHORITY 8. The Chairman of the Board and the President have been delegated fiduciary responsibilities under the bylaws of the corporation. The President, the Chairman of the Board, the Treasurer, and the CFO, and a minimum of one (and up to three) additional board member shall constitute the investment committee of the board. The Investment Committee of the Board shall review and make determinations on the VCOM investments; and provide a report to the Board of Directors on the investments at each Board meeting. The President/Provost has the authority to make changes in investments under the VCOM investment policy and in accordance with the restrictions outlined below. If changes are made, the President/Provost will be responsible to provide a report on the changes to the Investment Committee. These include, but are not limited to: a. VCOM will utilize the services of an Investment Consultant. The consultant(s) may assist the President and CFO in establishing investment policy, objectives, and guidelines to present to

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the Investment Committee; in selecting investment managers and reviewing such managers over time; in measuring and evaluating investment performance; and other tasks as deemed appropriate. The consultant(s) will read and agree to comply with this policy. b. Investment Manager. The investment manager(s) has direction to purchase, sell, or hold the specific securities that will be used to meet VCOM’s investment objectives. The manager will be accountable and responsible to achieve the goals for investment returns noted herein or as agreed upon. The investment manager(s) will read and agree to comply with this policy. c. Custodian. The custodian(s) will physically maintain the possession of securities owned by VCOM, collect dividend and interest payments, will redeem maturing securities, and will effect receipt and delivery following purchases and sales. Also, the custodian(S) may perform regular accounting of all assets owned, purchased, or sold, as well as movement of assets into and out of the VCOM’s investment accounts. Furthermore, the custodian(s) will ensure cash equivalents are purchased from institutions insured at the maximum amount allowed by the FDIC, and other investment instruments are insured at the maximum amount allowed by the Security Investor Protection Corporation (SPIC). Moreover, the custodian(s) will read and agree to comply with this policy. d. Additional specialists such as attorneys, auditors and others may be employed by the President and CFO to assist in meeting its responsibilities and obligations to administer the investments prudently. These other specialists will read and agree to comply with this policy 8. ASSIGNMENT OF RESPONSIBILITY 8.1 Responsibility of the President and CFO The President and the CFO are responsible to VCOM’s Board of Directors for the management of the investments of VCOM. They shall discharge these duties with care, skill, prudence, and diligence under the circumstances then prevailing, that a prudent man or woman, acting in a like capacity and familiar with such matter would use in the conduct of an enterprise of a like character with like aims. The specific responsibilities of the President and CFO to the investment management include: a. Projecting VCOM’s cash flow needs (“liquidity needs”), and communicating such needs to the Investment Consultants, and/or Investment Managers, if employed by VCOM, on a timely basis b. Determining the VCOM’s risk tolerance and investment horizon, and communicating these to the appropriate parties; c. Establishing reasonable and consistent investment objectives, policies and guidelines, which shall direct VCOM’s investments; d. Prudently and diligently selecting qualified investment professionals, if deemed appropriate; e. Evaluating on a regular basis, but no less than annually, the Investment Manager(s) that includes the performance of all investments, related returns, and compliance with this policy f. Developing and enacting proper control procedures; for example, replacing Investment Manager(s) due to fundamental change in investment management process or investment performance and returns 8.2 Responsibility of Investment Consultant(s) The Investment Consultant’s role is that of a non-discretionary advisor to the President and CFO. Investment advice concerning investment management will be offered by the Investment

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