VA Health Care: Enforcement of Federal Ethics Requirements at VA Medical Centers

GAO discussed whether the employment of Department of Veterans Affairs' (VA) medical center managers at medical schools participating in VA contracting activities created a conflict-of-interest, focusing on: (1) federal ethics laws and regulations; (2) VA policies and procedures; (3) outside employment activities of senior managers; and (4) VA contracting procedures and operating practices. GAO noted that: (1) federal ethics requirements limit the employment activities of federal employees who may have conflicting financial interests; (2) VA medical center managers who are most susceptible to potential conflict-of-interest violations are chiefs of staff and chiefs of individual medical services; (3) although VA policies and procedures require dually employed full-time VA managers to obtain prior approval for outside employment and provide sufficient information to assess the possibility of conflict-of-interest, few chiefs of staff and service chiefs have received prior approval; (4) VA headquarters rarely requested or received VA management responsibilities information; (5) part-time service chiefs are not required to seek prior approval for outside employment; (6) although VA has provided adequate guidance to medical center managers concerning dual employment, many senior managers are unaware of dual employment requirements and the potential for conflict of interest; and (7) VA needs to revise its dual employment policies and procedures, establish strengthened enforcement procedures, and develop appropriate guidance to assist medical center managers avoid conflict of interest.