DOD Revolving Door: Processes Have Improved but Post-DOD Employment Reporting Still Low
NSIAD-89-221
Published: Sep 13, 1989. Publicly Released: Sep 21, 1989.
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Highlights
Pursuant to a congressional request, GAO reviewed the Department of Defense's (DOD) implementation and enforcement of disclosure laws requiring certain former DOD employees to report any subsequent employment with certain DOD contractors.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of Defense should direct the Standards of Conduct Office to take more aggressive enforcement action to increase compliance with the reporting requirement. This should include: (1) developing a methodology for determining who is required to report, such as individuals who meet the reporting criteria but do not hold a security clearance; (2) following up to the extent deemed necessary for those who fail to report; and (3) as a means of demonstrating DOD commitment to enforcing the law, giving serious consideration to imposing fines against those who, after being directly informed of their obligation to report, still fail to do so. |
Closed – Implemented
The agency is currently negotiating with the Department of Defense Inspector General (DOD/IG) to conduct investigations and impose fines where applicable. DOD/IG has not investigated any of the cases forwarded and has declined to accept any referrals.
|
| Department of Defense | The Secretary of Defense should direct the Standards of Conduct Office to: (1) modify the reporting form to provide space for individuals to report positively or negatively whether they worked on major defense systems while at DOD or at the defense contractor; (2) clarify the reporting instructions to specify that negative reporting is also required; and (3) begin enforcing the requirement that former employees provide this information on their reporting form. |
Closed – Not Implemented
The agency considers the recommendation to be minor and changing a standard form requires tremendous effort. Also, the section of applicable law was suspended and may be repealed. The agency would only consider this recommendation after the uncertainty of the law is settled and then only if OGE issues final regulations on Standards of Conduct, which is unlikely. OGE regulations were not issued.
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Topics
Civilian employeesConflict of interestsContractor personnelDepartment of Defense contractorsFederal formsLaw enforcementMilitary officersNoncompliancePostemployment restrictionReporting requirements