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Project on Government Oversight




POGO's Conflict of Interest and Ethic Proposals

February 1, 2006 


A. Lobbying

1. Require lobbyists to disclose executive branch lobbying activities. The requirement could apply to lobbying activities with Senior Executive Service members (both career and non-career SES employees), contracting officers, and program managers.

2. Increase the one-year ban on lobbying for Members of Congress and their senior staffers who have a nexus between authorizations or appropriations authority over their post-government employer; and

3. Ban Gifts, Meals, and Trips. Ban Members of Congress from accepting any gifts, meals, or trips from any person, group, contractor, company, or other entity.

4. Improve Lobbying Disclosure. Require all lobbyists to detail their prior work history, the specific issues for which they are lobbying Congress, and a financial reporting of any gifts, meals, or trips paid for by the lobbyist.

5. Paid contractor consultants should be required to register with the Office of Government Ethics. Many former government employees are hired to promote a contractors agenda and the current system does not prove any transparency of those actions.

B. The Revolving Door

1. Simplify the complex system of laws, Executive Branch regulations, department and agency regulations, executive orders, and agency directives that add ambiguity to government ethics laws. Repeal the multi-tiered system of laws and regulations and incorporate required provisions in a clear and consistent model rule of ethical conduct for the entire federal government;

2. Prohibit, for a specified period of time, political appointees and SES policymakers (people who develop rules and determine requirements) from being able to seek employment from contractors who significantly benefitted from the policies formulated by the government employee;

3. Require government officials to enter into a binding revolving door exit plan that sets forth the programs and projects from which the former employee is banned from working. Like financial disclosure statements, these reports should be filed with the Office of Government Ethics and available to the public. This requirement would benefit government employees who are unaware of or confused by post-government restrictions or who have multiple post-employment bans covering different time periods. It would also enhance public trust in the government;

4. Require recently retired government officials and their new employers to file revolving door reports attesting that the former government employee has complied with his or her revolving door exit plan;

5. Prohibit government employees from overseeing or regulating their former private sector employer;

6. Close the loophole that allows former government employees to work for a department or division of a contractor different from the division or department that they oversaw as a government employee;

7. Establish an Executive Branch-wide law for federal government employees, requiring notification of recusal or disqualification to a supervisor;

8. The Office of Government Ethics should provide enhanced oversight of private sector employees who enter public service. Those types of revolving door cases should receive enhanced oversight because government officials may be placed in positions in which they regulate or oversee programs and policies that may affect their private employer.

C. Money & Contracting

1. Congress should restore the pre-1976 prohibition on contractor campaign contributions thereby assuring the American public that contractors’ contributions are not driving contracting decisions.

D. Federal Advisory Boards

1. Remove or modify conflict of interest and Freedom of Information Act exemption and waiver provisions for advisory board members and ensure that unclassified portions of board meeting minutes are publicly available; and

2. Enact Executive Branch-wide law requiring federal advisory committee members to recuse or disqualify themselves from any discussion on matters where they or their private employer or client have a significant financial interest. This disclosure or recusal statement, including name, title and employer should be filed with the Office of Government Ethics and made publicly available.


Founded in 1981, the Project On Government Oversight (POGO) is a nonpartisan independent watchdog that champions good government reforms. POGO's investigations into corruption, misconduct, and conflicts of interest achieve a more effective, accountable, open, and ethical federal government.

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