March 12, 2008

DO-08-007

MEMORANDUM

TO:       Designated Agency Ethics Officials

FROM:     Robert I. Cusick

          Director

SUBJECT:  Government Accountability Office Report on Contractor
Employee Conflicts of Interest

     The Office of Government Ethics (OGE) would like to bring to your attention a new report issued by the Government Accountability Office (GAO), Defense Contracting: Additional Personal Conflict of Interest Safeguards Needed for Certain DOD Contractor Employees (March 2008), http://www.gao.gov/new.items/d08169.pdf.  OGE believes this report makes an important contribution to the ongoing policy discussion concerning appropriate ethical standards for employees of Government contractors.  As many of you know, OGE has been raising concerns about this subject for several years, particularly in light of the growing reliance of the Federal Government on contractor employees to perform a wide range of mission-critical services.  See, e.g., OGE, Report to the President and to Congressional Committees on the Conflict of Interest Laws Relating to Executive Branch Employment 38 (January 2006), http://www.usoge.gov/pages/forms_pubs_otherdocs/fpo_files/reports_plans/rpt_title18.pdf.  A number of you have expressed similar concerns to OGE in the past, and we look forward to working with ethics officials, policymakers, and other interested persons as the Government seeks a reasoned and effective response to this emerging ethics issue.