National Science Foundation:
Better Guidance on Employee Book Writing Could Help Avoid Ethics Problems
GGD-93-8, Oct 9, 1992
Pursuant to a congressional request, GAO reviewed the National Science Foundation's (NSF) practices regarding conflict-of-interest issues, focusing on whether: (1) NSF and two of its employees complied with book preparation laws and regulations; and (2) NSF adequately protects against violations of book preparation laws and regulations.
GAO found that: (1) federal agencies must classify whether the writing and publishing activities of federal employees are official government duties or outside unofficial activities; (2) the two NSF employees who wrote and published two NSF books did so without NSF determining the activities' classification; (3) the two employees used secretarial and computer support services during work hours, and NSF allowed the employees to publish the books privately through commercial publishers; (4) NSF failed to clearly determine the classification and review the manuscripts; (5) NSF lacks formal policies and procedures for reviewing employees' job-related writing and publishing activities, determining the official or unofficial status, or communicating employee publishing guidelines; (6) NSF allows unsupervised independent research, lacks guidelines requiring employees to seek book-writing guidance and agency approval, and fails to determine whether the proposed publication relates to its mission; and (7) other agencies require employees to obtain prior agency approval for writing and information dissemination activities, require agency determinations distinguishing between official and unofficial duties, require agencies to determine whether a government or private publisher should be used, and require policy determinations regarding employee or publisher copyrights and employee compensation.
- Review Pending
- Closed - implemented
- Closed - not implemented
Recommendation for Executive Action
Recommendation: The Director, NSF, should formalize and implement policies and procedures to require: (1) adequate prior review of employees' NSF-related book-writing and publishing activities; and (2) appropriate actions, including providing clear advice to employees to help ensure that such activities comply with applicable laws and regulations.
Agency Affected: National Science Foundation
Status: Closed - Not Implemented
Comments: A new draft policy and procedures to reflect the recommendation were circulated and received extensive comments. One more revision was to be circulated for comments. The new policy and procedures were expected to be final by February 1994. In early 1994, NSF ceased work on its policy covering book writing because of the President's Executive Order 12681, requiring all federal agencies, as part of reinventing government, to reduce internal management directives by half. In March 1995, NSF issued a staff memorandum implementing the executive order at NSF by calling for the cancellation of many existing and proposed regulations. Thus, according to an Office of General Counsel official responsible for drafting the book-writing policy, in order to be consistent with the executive order, the policy probably will not be issued. As of August 1996, the status had not changed in three years.