. i

ETHICS IN GOVERNMENT

t1WICE$ o 
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OFFICE OF INSPECTOR GENERAL 
OFFICE OF EV ALVA TION AND INSPECTIONS 
APRIL 1990  OFFICE OF INSPECTOR GENERAL

The mission of the Offce of Inspector Genera (OIG) is to promote 
the effciency, effective
ness and integrty of programs in the United States Deparment of Health and Human Services 
(HHS). It does this by developing methods to detect and prevent fraud, waste and abuse. Cre
ated by statute in 1976, the Inspector General keeps both the Secretar and the Congress fully 
and curently infonned about programs or management problems and recommends corrective 
action. The OIG perform its mission by conducting audits, investigations and inspections 
with approximately 1,400 staff strtegically located around the countr. 
OFFICE OF EVALUATION AND INSPECTIONS 
This report was produced by the Offce of Evaluation and Inspections (OEI), one of the three 
major offces within OIG. The other two are the Offce of Audit Services and the Offce 
of In
vestigations. The OEI conducts inspections which are 
designed to 
tyically short-tenn studies 
determne program effectiveness, effciency and vulnerability to fraud or abuse. 
The repon is entitled, "Ethics in Government." This inspection sought to assess how well pro
fessional employees of the Deparment understad the ethical standards of conduct. 
This study was conducted under the diction of Thomas F. Tully, Regional Inspector General 
of Region IT, Offce of Evaluation and Inspections. Paricipating in this project were the fol
lowing people: 
Region II  Support Regions 
Jack Molnar  Bar McCoy 
Tracey Rennie  Bob Katz III 
Jodi Nudelman  Ron Kalil 
Barbara Butz 
Headquarters  Perr Seaton VII 
Tom Noplock  Ralph Tunnel VI 
Scott Paterson  Kaye Kidwell IX 
Ta Zitans  Paul Gottlober IX  ..- .-- - -...--."---  -'--------'- --_ .-_ '-'
ETHICS IN 
GOVERNMENT

Richard P. Kusserow 
INSPECTOR GENERAL 
OEI-02-90-00710  APRIL 1990
 , "
EXECUTIVE SUMMARY
PURPOSE
To assess how well professional employees of the Deparment of Health and Human Services
(HHS) understand the ethical stadards of conduct.
BACKGROUND
The Inspector Genera conducted this inspection while the Deparent is implementing
Prsident Bush's Executive Order 12674 Prnciples of Ethical Conduct for Government
Offcers and Employees," which mandates annual trning to Presidential appointees,
employees who must fIe financial disclosur reports and procurement officials. Other
deparental ethcs trning consists of the Assistat Secreta for Management and Budget
implementation of the procurement integrty act, the Offce of Genera Counsel's (OGC)
orientation for al political appointees and Assistant 
Secretar for Personnel Administration
(ASPER) issuance of the "Stadards of Conduct" to new employees.
Despite the Deparent s efforts, the Offce of Government Ethics (OGE) found some
weakesses in ethics programs and in employees' understanding of the standards of ethical
conduct. Also, the Offce of Inspector Genera (OIG) contiues to see cases of employee
misconduct.
METHODOLOGY
The OIG mailed a questionnai to a strtified random sample of 600 professional employees
to assess their understanding of the ethical standads of conduct. Face-to-face interviews were
also conducted, at both headquarers and in the regions, with a representative group of 56
HHS managers. These interviews supplemented the surey findings by identifying
employees' perceptions and atttudes regarding the ethical standards and the process by which
they are made aware of the standards.
FINDINGS
Percent On Ethics Survey; Training Is Key To Higher Scores.
Employees Score  73 
The average score on the tre/false survey was 16.8 corrct out of 23 questions (73 percent).
Scores var with training; trained employees scored 17.5 while employees who have not had
training scored 16.3. Scores also var by pay plan and length of service. Senior Executive Service (SES) employees scored 17.5 correct, while General Schedule (GS) employees scored 
16.2 corrct. Those with less than 5 years scored 15.3, while those who have worked 21 years 
or more scored 17.3. However, upon analysis, the varance by training was found to be the 
only factor that was statisticaly signifcant. 
Employees Score Low On Hatch Act, Gifts And The Use Of Government Resources. 
Questions regardig the Hatch Act, gifts and the use of government resources received the 
lowest scores. Respondents tended to answer questions over conservatively on accepting 
monetar awards and wearng parsan election buttons, Le., believing that they could not do 
thngs that are, in' fact, permtted. 
Managers Believe Understanding Of Ethical Standards Is Adequate, But Want The Depart
ment To Do More. 
Ninety-five percent of the managers interviewed believe their understanding of the ethics 
standards is adequate; 76 percent believe their staf has an adequate understanding. Yet, over 
half believe the Deparent is not doing an adequate job of makng employees aware of the 
ethcal stadards of conduct, and another half believe that the standards of conduct are not 
uniformy enforced. Furer, 82 percent say they would attend a hypothetical four-hour 
course on ethics; 87 percent say they would diect their staf to attend such a course. Specific 
areas where more trning is requested include procurement, post-employment restrctions, 
conflct of interest and the recent changes in ethics regulations. 
CONCLUSIONS AND RECOMMENDATIONS 
The OGC, in consultation with ASPER, should: (1) develop an ethics education program for 
all professional employees, not only for those covered by the Executive Order, geared to the 
specific charcteristics of the components' stas and missions; (2) establish a system of 
newsletters or bulletins to provide infonnation on problems, weak areas and changes in the 
curent stadards of conduct; and (3) distrbute, for guidance purposes, a standard table of 
penalties to deal with common cases of ethical misconduct. 
AGENCY COMMENTS 
We received comments on the report frm most HHS operating divisions and staf offces. 
Respondents were generaly in favor of stronger educational programs. The General Counsel 
Assistat Secretar for Health, and Assistant Secretar for Personnel Administration objected 
to the standard table of penalties. We modified our recommendation on the latter to call for its 
distrbution for guidance purposes rather than making it mandatory.  .......................................... . ... ..... .... ..... .... .... ....... .... ..... ........ 
TABLE OF CONTENTS 
EXECUTIVE SUMMARY 
BACKG RO U N D 
........................................................................................................ 1

ETHODOLOG Y ................ ...................................................................................... 2

FI N DI NGS ..... ........ .11..  ..1111....... ...11..... ..e.  ..lIellll..II.OOG .011.11111111111111 

Employees Score 73 Percent On Ethics Surey; Training Is Key To 
Higher Scores .....  ...11... .11.11. II.. 11.111.1..1111. 111111111II1 1. 111101 111101111111111I1I1 0311 

Employees Score Low On Hatch Act, Gifts And The Use Of 
Government Resources................ ........ ............................................... ............ 4

Managers Believe That Their Understading Of Ethics Standards 
Is Adequate, But Want The Deparent To Do More................................... 5

CONCLUSIONS AND RECOMMENDATIONS .............................................. 7

AG ENCY COM ME NTS 
O.O...........DOIl DII.II...IIII.IIII.II..0.ell.. lIellll 0..111111111111111111111111 0111101111011181111111111 1111II1 1O1il 1111111 1011111101111111111

APPEN 
DIX.....IIII..IIII 1111111111.11..1.11.1.1. 1.....11.......... .......II..IIIIIIIIIIII......II.II.IUJeC e..11 ellllCl 111111...1111111111101 1313131111101111311111111111111111111 
 .- 
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'0' 
ETHICS IN GOVERNMENT 
PURPOSE 
To assess how well professional employees of the Deparment of Health and Human Services 
(HHS) understand the ethical stadards of conduct. 
BACKGROUND 
This inspection was conducted by the Inspector General while the Deparment has been 
implementig Prsident Bush's Executive Order  (B.  12674  Prnciples of Ethical Conduct 
for Government Offcers and Employees." In addition to clarying many of the specific 
ethical standads, this executive order  trning for everyone in the following
mandates  annual 
categories: Prsidential appointees; employees in the Executive Office of the President; 
employees who must fIe financial disclosure reports; and procurement offcials. 
The standards of ethical conduct for Federal employees are based on Presidential diectives 
and crmial statutes. Pror to E.O. 12674, Prsidents Eisenhower, Kennedy and Johnson each 
issued executive orders establishing or modifying ethical standards for Federal employees. 
Section 401 of President Johnson s E.O. 11222 requird the fIing of financial disclosure 
statements. Title 18, sections 202 though 209 of the United States Code, sets fort those 
crnal 
conflct of interest statutes having  penalties. 
The process of establishig and monitoring standards of ethical conduct for Federa 
employees involves a number of agencies. The Offce of Government Ethics (OGE), 
Offce of Personnel Management, is responsible for auditing 
origially established within the 
Executive Brach agencies' ethics programs. It reviews agency-specific standards of conduct 
and audits the fIing of financial disclosur statements. The OGE also provides training for 
Designated Agency Ethics Officials (DAEO) and renders opinions on specific cases. With 
O. 12674, OGE is now an independent agency and has increased staff for auditing and 
training. 
Each Federa agency is requird to implement the standards of conduct, assign DAEOs, and 
obtain periodic fIings of public and confidential financial disclosur statements by 
employees. Within each agency the DAEOs trn and render opinions, much the same as OGE 
does on a broader level. 
At HHS, the Assistant Secrtar for Personnel Admnistrtion (ASPER) issues the Standards 
of Conduct to all new employees upon entering on duty. The Deparent also has published 
Standards of Conduct...in Brief  DHHS Ethics Guide, and An Ethics Handbookfor 
Employees of the Department  Additionally, all incoming 
of Health and Human Services. 
political appointees receive an ethics briefing from the  (OGC). 
Offce of General Counsel  Within the last year, there has been an ethics training initiative for Public Health Service and 
Social Securty employees, and initial ethics training has been conducted for employees 
involved in procurement as par of the implementation of the "Offce of Federal Procurement 
Policy Act Amendments of 1988" (P.L. 100-679). Ethics training, as mandated by E. 
12674, is now being scheduled for all procurement officials and employees required to file 
fmancial disclosure statements. 
Yet problems remain. Recent audits of HHS components by OGE found some weaknesses in 
ethics programs and also employee misunderstanding of the standards of ethical conduct. 
Also, the Office of Investigations continues to find cases of employee misconduct. 
METHODOLOGY 
The fmdings of this inspection are based on two distinct data collections. The first, a survey 
containig 24 tre/false questions, developed with the assistance of OGC, was mailed to a 
stratied radom sample of 600 professional employees. Two hundred employees were 
selected from each of three strata: Strtum 1 - Senior Executive Service (SES); Stratum 2 
(CO) 
General Management (GM) and General Schedule (GS) 13 to 16, Commissioned Officer 

4 to 6; Stratum 3 - GS 10 to 12, CO 1 to 3. The total universe of professional employees was 
500. An overal response rate of 77 percent was obtained, 2 percent of which was not 
useable for varous reasons. Broken down by strtum, 1 had a 75 percent response rate, 2 was 
79 percent, and 3 was 69 percent. Although the surey originaly contained 24 questions, a 
question regardig the use of franed envelopes was dropped as the Deparent s policy was 
being reviewed at the tie of the surey. 
The second data collection consiste4 of 56 face-to-face interviews with a representative group 
of HHS managers required to complete financial disclosur 
statements. These interviews 
supplemented the surey findings by identifyig employees' perceptions, attitudes and 
concerns regarding both the stadads of ethical conduct and the process by which employees 
are made aware of them. These interviews took place both at headquarers and in the regions.  ,,,.....
FINDINGS

Percent On Ethics Survey; Training Is Key To Higher Scores. 
Employees Score  73 
The average score for professional employees who took the tre/false survey was 16. 8 correct 
out of 23 questions (73 percent). Because of the characteristics of the sample, overall and pay 
plan findigs can be generalzed to the respective population. 
Training was found to have a positive relationship with scores. Those employees who had 
traiing scored 17.5, while those who did not scored 16.3. The impact of traiing on scores 
was also found to be statisticaly signficant, based on an analysis of varance and application 
of tests to varous groupings of data. 
TRAINING IMPROVES AVERAGE SCORE 
Average Score Based on 23 Questions 
NOT TRAINED  TRAINED  Scores also increase with lengt of service and pay plan. Upon analysis, however, these 
relationships were not found to be statistically significant as was training. Those with less 
than 5 years had an average score of 15.3; the average score rose to 17. 3 for those who have 
worked 21 years or more. SES employees scored the highest, averaging 17.5 correct, and GS 
employees scored the lowest with 16.2 correct. 
Employees Score Low On Hatch Act, Gifts And Use Of Government Resources. 
Problem areas were identified in the surey by low scores on certain questions. As shown in 
the char below, employees scored lowest on questions regarding the Hatch Act, gifts and use 
of government resources. 
SUBJECT AREA SUMMARY. 
SUBJECT AREA  (# of responses)  % CORRECT  % WRONG  %N/A 
Reportg 
(447)  99% 
Post-employment  (1,341) 
Gambling  (447) 
Travel  (894) 
Conflct of Interest  (1,788) 
Outside Activity  (447) 
Use of Gov t Resources  (1,788)

Gifts  (2,682)  35*

Hatch Act  (894)  42*

of the wrong answers on gifs,  on Hatch Act reflect overly conservative 
* 3/4  and  2/3
interpretations . 
not answered 
Nt  A =  ...
With regard to questions on Hatch Act and gifts, respondents tended to answer conservatively, 
believing that alowable activities are prohibited. For example, over 
hal the respondents 
believe accepting monetar awards for a meritorious public contrbution and wearng parisan 
election buttons are not allowed when, in fact, both are permtted. They also think that 
supervisors may not give nomial gifts to employees, although there are no such prohibitions. 
They believe, erroneously, that they cannot accept unsolicited material such as pens, cups and 
calendars. As one senior manager noted, "I never studied the standards. In general, I think I 
know them. I am conservative about the standards.  (See Appendix 1 for scores and answers 
to each question) 
With regard to use of government resources, hal the respondents believe that they are allowed 
to use government time to prepare for such outside activities as wrting for a professional 
joural or teaching a course if the subject matter relates to their offcial duties, although it is 
not alowed. Additionaly, nearly hal are unawar of the mandatory suspension for using a 
GSA vehicle for personal puroses. Employees also did not know that they are required to 
obtai prior approval for an outside activity even when they are not compensated for that 
activity. Interestingly, this ara shows the greatest varance by pay plan, with managers 
answering correctly 72 percent of the time and GS employees only 53 percent of the time. 
Managers Believe That Their Understanding Of Ethics Standards Is Adequate, But Want 
The Department To Do More. 
The managers consider on-the-job ethical decisions a common event. Over half say that they 
are faced with makng an ethical decision at least weekly, and are comfortable when faced 
with those decisions. 
Ninety-five percent of the managers interviewed believe their understanding of the ethical 
standards of conduct for Federa employees is adequate. Furer, 76 percent believe their staff 
also has an adequate understandig. 
Managers report that their ethical decision-makng process is based priary on personal 
values and secondaly on government standads. When asked how they know an ethical 
decision they had made was correct, nearly two-thirds report they follow their instincts, 
relying heavily on years of service and their moral beliefs. Almost two-thirds also say they 
would call OGC with an ethics question since OGC is the designated ethics office and the 
experts in this area. This shows, as one respondent commented "  that people know where to 
go to for help and that s the impoqant thing. 
Managers face a wide varety of ethical decisions. One manager recalled when he had to 
refuse a contrbution by a State agency for a meeting his office was holding because his office 
has oversight responsibilty of the agency. Another manager attended a conference hosted by 
a State, but had to refuse the meals and lodging. Some smaller day-to-day ethics problems 
mentioned included: use of telephone for personal reasons; time and attendance disputes; and 
employees wanting to work outside the offce on a par-time basis.  ...
In general, senior managers do not have problems with the curent ethical standards. 
Ninety-one percent consider the ethical stadards of conduct realistic; 79 percent find them 
easy to understand. Most also think the standards are generally fai, equitable and 
self-evident. Furer, over 60 percent would not make any specific changes to the ethical 
standards if given the opportunity. However, when asked which standards were unrealistic 
they mentioned: accepting lunches and travel reimbursement from non-Federal agencies; 
frequent fler regulations; post-employment restrctions; and FTS rules. When asked 
specifically about post employment, most managers say they understand the restrctions and 
find the restrctions both necessar and fai. 
Understanding the standards is not the problem; rather, implementing 
One respondent said, 

them is the difcult part.  Nearly half of those interviewed believe that the ethics standards of 
conduct are not enforced uniformy thoughout the Deparment. 
Over half the managers interviewed also believe the Deparent is not doing an adequate job 
makg 
of  employees aware of the ethical stadards of conduct. Many believe efforts 
improving, but feel more can be done. Several cite a general lack of emphasis and concern 
about ethics, and a need for the Deparment to set an appropriate tone. 
Projecting from the surey, over half of the professional staf of the Deparment have not had 
any fonnal ethics training. Yet, most managers would lie additional training for themselves 
and their staff. Eighty-two percent of the interviewed managers would attend a hypothetical 
four-hour course on ethics; 87 percent would diect their staff to attend such a course. One 
manager, however, stated that he would "  want to review the course beforehand to make sure 
it is wortwhile and effective." Additionaly, another manager believed the training should be 
geared toward our parcular workload. Even then, I would only send those employees who 
had not recently been trned." Many managers also recommended that trining should 
include workshops and case studies relevant to ethical problems in everyday situations. 
ar 
When asked if there  specific standads they would like to know more about, senior 
managers mentioned procurement, post-employment restrctions, conflct of interest situations 
and recent changes in ethics regulations. When questioned about their awareness of the 
procurment integrty act and President Bush' s E. O. 12674 on Ethical Conduct for 
Government Offcers, the managers report a general lack of understanding of their potential 
effects.  CONCLUSION AND RECOMMENDATIONS 
surey 
Our basic recommendations are to strengthen training and enforcement. As noted in the 
fmdings, half the professional staf have had no fonnal ethics training, training helps improve 
test scores, lower-graded employees get lower scores, and scores improve with length of 
and interviews identify subject areas where training is needed 
service. Both the mai

or sought. 
The Deparent s curent ethics trning agenda consists of the OGC orientation for political 
appointees, the ASPER issuance of the "Stadards of Conduct" to new employees, and the 
trning mandated by E.O. 12674 for procurement offcials and employees who must fie 
fmancial disclosure statements. 
Specifcally, it is recommended that OGC, in consultation with ASPER: 
develop an ethics education program for all professional employees, not only 
those covered by the executive order, and an ethics component for new 
employee orientation. They should be geard to the characteristics of each 
components ' staff and mission; 
establish a system of newsletters or bulletins to provide employees with 
inormation on misunderstoo areas (Hatch Act, gits and use of government 
resoures), as well as changes in the ethical stadards of conduct; and 
distrbute within the Deparent, for guidance puroses, the Federal Personnel. 
Manual Letter 751-3, "Suggested Table of Actions for Corrcting Employee 
Misconduct." This table, developed by the Prsidents ' Council on Integrty and 
Effciency (PCIE) and adopted by the Office of Personnel Management, is being 
used by most other Federal agencies.  AGENCY COMMENTS

We received comments on the draft repon from ASPER, OGC, the Assistant Secretar for 
Management and Budget (ASMB), the Assistant Secretar for Planning and Evaluation 
(ASPE), the Office for Civil Rights (OCR), the Public Health Service (PHS), the Health Care 
Financing Admnistrtion (HCFA), and the Offce of Human Development Services (OHDS). 
Almost all agreed with the recommendations for trning and a system of newsletters. 
However, some believed that more study or evaluation should be done before ethics traiing is 
significantly expanded. Nevenheless, the OGC, which has the responsibility for monitoring 
and guiding deparenta implementation of ethics policies, identied a number of 
Deparent-wide training initiatives it was leadig and noted that it is developing an ethics 
newsletter. 
With regard to the recommendation to adopt OPM' s "Suggested Table of Actions for 
Correction Employee Misconduct," OHDS, ASMB, OCR, and HCFA concurred. The HCFA 
observed that Deparent-wide implementation might be diffcult due to the number of 
bargaining units. The ASPE recommended that the recommendation be modified to say 
consider" the Table. The OGC, ASPER, and PHS did not concur with this recommendation 
feeling that the table would limit managerial discretion. 
We believe that OPM and PCIE' s intent in issuing the Table was to provide guidance to 
lit 
managers and not to  their discretion. We have, therefore, modied this recommendation 
with 
to cal for its distrbution  the Deparement. This distrbution, for guidance purposes, 
would help addrss the findig that hal of the managers contacted believed that the ethical 
standards of conduct were not being enforced uniformy.  ._---
- .. --" - , ",,,,'- '--_._- _.--:-, -- -_.,-_ _.-
APPENDIX 
OIG GOVERNMENT ETHICS SURVEY 
% CORRECT  QUESTION AND ANSWER 
97%	 Failure to report instances of fraud, abuse, waste and corrption 
to appropriate authorities is a violation of the stadards of con
duct. 
TRUE - Executive Order 12674 (4/12/89), Section 101(k) states 
that employees shal disclose waste, fraud, abuse, and corrption 
to appropriate authorities. 
77%	 Even the appearance of a conflct of interest is a violation of eth
ics rules. 
TRUE - 45 CFR 73.735-802 and Section 101(n) of the Executive 
order cover appearce of a conflct of interest. Employees are 
encouraged to use the "Newspaper Rule." If the situation were re
to be a 
ported on the front page of a newspaper would it 	 appear 
confct of interest. 
82%	 If an organization you are monitoring asks whether you are inter
ested in working for them, you can give them your resume with
out telling your supervisor. 
FALSE - You must infonn your supervisor you may be. seeking 
employment with an agency you are monitoring so that you may 
be taen off the assignment. Such a situation creates a financial 
conflc  of interest in violation of 18 USC 208. Post employment 
rules should also be discussed.  66%	 You may represent a neighbor who is having a problem with 
SSA, if you do so on your own time. 
FALSE - 18 USC 203 & 205 prohibit a Federal employee from 
representing anyone except a parent, spouse, child or a person 
with whom there is a fonnal relationship, such as guardian, be
fore any Federal agency. 
60%	 You may accept unsolicited promotional material, such as pens, 
cups and calendars. 
TRUE - You may accept such unsolicited promotional material. 
It has been deemed more costly to return than it is worth. 
63%	 You may accept food or refreshments of nominal value on an in
frequent basis in the coure of a working lunch. 
TRUE - You may accept food during a working lunch if there is 
no established way to pay and the event is infrequent. However 
if the lunch is in a restaurant the Federal employee would be ex
pected to pay his or her 
fai share. 
56%	 You may give your supervisor a birday present of nominal 
value. 
FALSE - 18 USC 7351 & 45 CFR 730735-504 prohibit giving 
except on special non-recurg occasions. 
gits to supervisors, 
67%	 Your supervisor may give you a birday present of nominal 
value. 
TRUE - There are no prohibitions on supervisors giving gifts to 
staff.  79%  You may paricipate in frequent fler clubs in the course of off
cial  benefits must be turned over to the Govern
trvel but the 
ment. 
TRUE - Current policy, based upon guidance from the Comptrol
ler General, is that Federal employees may collect frequent flyer 
miles as long as those benefits accrue to the Government. 
89%  10.  You ar free to combine personal travel with offcial Government 
trvel without makng any special justification to your supervisor. 
FALSE - Extrme caution must be used when combining offcial 
and personal travel to avoid the appearce of misuse of funds. 
Such trps may not occur under a blanet travel order and as such 
require justification. 
N/A  11.  You may use Government envelopes to reimburse Diners Club 
for travel charges. 
As interpreted under 18 USC 1719, you may not use Government 
envelopes for any personal matter such as mailng payroll checks 
to bans. It is unclear whether this applies to payments to Diners 
Club. 
90%  12.  You may not sell commercial products on Government property.
durg 
your lunch period. 
TRUE - 45 CFR 73.735-305 prohibits the sellng of commercial 
products on Government time or in a Government buildig. 
87%  13.  You may paricipate in a football pool or lottery being run in your 
offce. 
FALSE - 5 CFR 735.305 prohibits Federal employees from par
ticipating in gambling, bettng, or lottery activities while on Gov
ernment time or propert.  50%  14.  You may use Government time to prepare for such activities as 
wrting for a professional journal or teaching a course if the sub
ject matter relates to your offcial duties. 
FALSE - 45 CFR 74.735-705 & 706 preclude the use of Govern
ment time, supplies, equipment or staff to prepare for such out
side activities as teaching or writing. 
92%  15.  You may accept honorara from private sources when you give 
speeches or perfonn other activities on behal of the Government. 
FALSE - Federal employees are prohibited by 18 USC 209 from 
receiving any salar or compensation for Government services 
from any source other than the United States Government. 
45%  16.  You may accept monetar awards for meritorious public service 
from civic or professional groups. 
TRUE - Under 45 CFR 73.735-505 Federal employees may ac
cept monetar awards for public contrbutions as long as there is 
no conflct of interest. 
91%  17.  For two years after you leave the government, you may not repre
sent others to the Federa government on contractual matters your 
staf worked on durng your last year of service. 
TRUE - 18 USC 207 (b) (i) places a two-year ban on all fonner 
employees. You cannot represent anyone in any parcular matter 
involvig specifc p  es, such as s contrct, that was pending 
under your offcial responsibilty durng your last year of service. 
46%  18.  You may wear or display parsan election buttons badges or 
stickers. 
TRUE - You may wear or display buttons, badges or stickers, but 
you may not distrbute campaign material in parisan elections.  68%  19.	 You may circulate nominating petitions in a parsan political 
election if you do so outside the offce. 
FALSE - You may sign a nominating petition, but you may not 
circulate one. 
69%  20.	 You do not have to get prior approval for an outside activity if 
you ar not compensated for that activity. 
FALSE - Under 45 CFR 73.735-708 you must obtain prior ap
proval for some outside activities even if you are not compen
sated. 
84%  21.	 As a designated "senior employee," you may not attempt for one 
year to inuence your fonner agency on any matter, even if it 
arose after you left. 
TRUE - 18 USC 207(c) places a one year ban on representation 
on any matter for cenain high level offcials. 
54%  22.	 If you are found to have used a GSA vehicle for personal pur
poses, you must be suspended or removed from service. 
TRUE - 31 USC 1349 establishes mandatory penalties of suspen
sion for at least one month or removal for the personal use of a 
Government vehicle. 
94%  23.	 You may not work on a contrct on behalf of a private contractor 
if you parcipated on behalf of the Government in the procure
ment of that contrct in the past two years. 
TRUE - Effective July 16, 1989, under 41 USC 423 there is a two-
year ban on "switching sides" on any contract. However, on 
11/30/89 this provision was suspended for one year. 
79%  24.	 You may own stock in a company that you regulate, as long as 
the value of that stock is less than $500. 
FALSE - Under 18 USC 208 you may not hold any stock in any 
company you regulate.