Fund Solicitations for Redecorating the White House

GAO was asked to examine allegations that a group of non-Federal employees used Federal facilities to solicit corporations and individuals in the energy industry for contributions to the White House Historical Association to redecorate the White House. GAO was asked to determine if the solicitations were carried out consistent with Federal law, whether the solicitors violated any laws, and if the close relationship between the National Park Service (NPS) and the Association were questionable. The White House has denied that the solicitation of funds took place as described, and GAO has no basis to challenge this denial. An Association representative described the role of the Association as being limited to the receipt of the donations. At least two members of the board of directors of the Association must represent NPS. An agreement between NPS and the Association provides that the Association may use the White House and other Federal facilities for the sale of educational and interpretive items. Association employees are not Federal employees and care is taken to avoid the appearance that NPS directs the management of the Association. The statutory authorities relied on by NPS support its agreement with the Association. If the solicitations had taken place in the Executive Office Building, it would be important to determine if they were conducted by non-Federal employees or special employees within the meaning of the standards of conduct applicable to White House employees. To the extent that any solicitation could be construed as an exchange of favors, the Federal bribery statute might apply to these special employees. If the solicitors are not special employees and a Federal employee permitted them to use Federal facilities for the solicitation, a statute which prohibits employees from permitting Government property to be used for other than official purposes would possibly have been violated. However, GAO could not render a formal opinion on the matter due to the lack of facts at its disposal.