VA Health Care:

Inadequate Enforcement of Federal Ethics Requirements at VA Medical Centers

HRD-93-39: Published: Apr 30, 1993. Publicly Released: May 14, 1993.

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Pursuant to a congressional request, GAO reviewed whether the part-time employment of Department of Veterans Affairs' (VA) medical center managers at medical schools complies with federal ethics laws and regulations, focusing on whether: (1) part-time employment creates a conflict of interest; and (2) part-time-employed VA managers participate in VA management activities involving the medical schools.

GAO found that: (1) nearly one-third of VA medical center senior managers are receiving part-time employment incomes; (2) only one-third of the senior VA managers receiving income from medical schools that provide medical services have received approval before engaging in dual employment; (3) the senior managers at 3 medical centers have participated in VA contract-related activities involving the medical schools that employed them; (4) part-time VA managers are not required to get medical center director approval for outside employment; (5) VA has not adequately addressed conflicts of interest arising from managers' dual employment, provided adequate written legal or ethical guidance to managers on dual employment, or effectively monitored managers' compliance with ethics requirements; and (6) VA operating practices jeopardize the integrity of its management process and subject managers to the risk of possible violation of conflict of interest laws and ethics regulations.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: VA does not agree with the recommendation and plans no action. VA stated that its policies already prohibited conflict-of-interest situations. VA stated that the problem was one of enforcement not inadequate policies.

    Recommendation: The Secretary of Veterans Affairs, after consultation with the Office of Government Ethics, should direct the VA ethics officer to revise VA policies governing the types of dual employment activities that medical center managers may engage in under federal ethics laws and regulations.

    Agency Affected: Department of Veterans Affairs

  2. Status: Closed - Not Implemented

    Comments: VA does not agree with the recommendation. VA stated that the restrictions on part-time managers regarding outside employment would be subjecting them to requirements with which no other federal part-time employees must comply and would seriously jeopardize VA's ability to recruit part-time medical staff, which would result in a corresponding loss to quality patient care.

    Recommendation: The Under Secretary for Health should establish procedures to enforce the revised policies developed by the ethics officer, including those for reviewing and approving managers' outside employment. These procedures should require part-time managers, as well as full-time managers, to receive VA approval for outside employment before engaging in such employment.

    Agency Affected: Department of Veterans Affairs: Office of the Under Secretary for Health

  3. Status: Closed - Implemented

    Comments: VA concurred with the recommendation and stated that VHA Directive 10-93-35, dated March 24, 1993, "Outside Professional Activities", requires all employee requests for approval to engage in outside professional activities to include information on both the employer's involvement in VA contracts with the prospective employer and the extent and nature of those contracts.

    Recommendation: As part of each outside employment request, the Under Secretary for Health should require that each manager include information on the: (1) extent and nature of the medical centers' contracting relationship with prospective outside employers; and (2) manager's involvement with any VA contract-related activities that may have an impact on the medical school.

    Agency Affected: Department of Veterans Affairs: Office of the Under Secretary for Health


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