Propriety of Proposed Contractual Arrangement With Retired Annuitant for Preparation of Primers

The propriety of a proposed contractual arrangement with the former Associate General Counsel was questioned with regard to whether: the agency is authorized to enter into a contract with the annuitant to prepare up-to-date primers on political broadcasting rulings; the highest rate specified by the Classification Act is the maximum amount that may be paid for such services under the Communications Act of 1934, as amended; and the amount awarded under the contract is subject to reduction by the amount of retirement annuity. The agency may procure the services of a retired Government attorney for the services in question; the amount payable under the contract is not limited by statute; and the amount is not subject to setoff by the amount of the retirement annuity since work will be performed independently rather than under an employer-employee relationship.