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Virginia Commonwealth University/VCU Health System
Public Positions on Legislative and Budgetary Issues
Faculty and Staff Public Comment Advisory

The purpose of this advisory is to help faculty and staff deal with requests for public comment, whether oral or written, on legislative and budgetary matters.  At the outset, it is important to emphasize that VCU and the VCU Health System respect the right of employees to communicate with government officials and others on matters of public policy.  This advisory is designed to clarify roles and responsibilities and contemplates two general situations: first, requests for public comments from faculty and staff in their individual capacities or as members of outside organizations; second, requests for public support from the University or Health System.

With respect to the first situation, there is a tendency for people who hear or receive comments from faculty and staff to believe that if a person identifies himself as an employee of VCU or the VCU Health System that he is speaking on behalf of or with the approval of his employer.  That is often not the case.  In fact, the President of VCU, who also serves as President of the Health System, must approve official University or Health System positions.  Accordingly, when faculty or staff testify as individuals or as representatives of an organization other than VCU or the VCU Health System, we request that they inform their “audiences” that their comments are not intended to represent the views of the university or health system.  A simple caveat at the beginning of written or oral comments that states, “I am not representing the views of Virginia Commonwealth University [or the VCU Health System],” will suffice.  Following this procedure will insure that faculty and staff can feel free to offer testimony.  It will alleviate any concerns that their statements will be wrongly construed to be official positions of the University or Health System.

Faculty and staff not testifying on behalf of VCU or the VCU Health System should refrain from using University or Health System stationery to express their views. Likewise, faculty and staff are encouraged to adhere to University and Health System policies relating to the use of equipment, including but not limited to email, facsimile, and telephones. In addition, if testimony is given during a faculty or staff member’s normal business hours, he should consider whether it is appropriate to utilize annual leave while away from the workplace.

With respect to the second situation, if faculty and staff believe it appropriate, they are encouraged to communicate in writing to their deans and/or department chairs any request for the University or Health System to publicly support a specific legislative or budgetary proposal.  It would also be helpful to provide a recommendation with supporting reasons in any such communication.  The dean or department head will determine if the matter should be referred to their vice president for further review and action.  The vice president will, in turn, decide whether to forward the request on to the president for approval.

In the event a request for University or Health System public support is received with a response time of less than five business days, in addition to a department chair, dean or vice president, contact with the Office of the Vice President for Government Relations and Health Policy would be appreciated.

This advisory was developed in consultation with the leadership of the VCU Faculty Senate, which understands and supports the objectives of the advisory.

If you have any questions regarding this matter, please contact Mark Rubin, Executive Director of Government Relations and Health Policy for VCU and the VCU Health System, at 828-1235.

Virginia Commonwealth University | Government Relations
Date Last Modified: November 2012
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