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ETHICS IN GOVERNMENT


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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, effectiveness 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. Created 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 Investigations. The OEI conducts inspections which are tyically short-tenn studies designed to 

determne program effectiveness, effciency and vulnerability to fraud or abuse. 

The repon is entitled, "Ethics in Government." This inspection sought to assess how well professional 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 following 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

Employees Score 73 Percent On Ethics Survey; Training Is Key To Higher Scores.

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 Department 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.. 11.1111...1111. 1111111111. II 11110 1111110111111111111 II 011
 3 

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..111111111111111111110111101111011111111 8111111111111 II Oil 1111 1111011111101111111111


APPEN DIX.....IIII..IIII 1111111111.11.11... ..1111.....11.......... .......II..IIIIIIIIIIII......II.II.IUJeC e..11 ellllCl 111111...111111110 1111131313111113 1101111111111111111111111 

, 

_ . ._. .._,,.,.._..____ _.. _ . ., .. .... , .. ._

'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 mandates annual trning for everyone in the following

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 

conflct of interest statutes having crnal 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), 

origially established within the Offce of Personnel Management, is responsible for auditing 

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 of Health and Human Services. Additionally, all incoming 

political appointees receive an ethics briefing from the Offce of General Counsel (OGC). 
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 ­

General Management (GM) and General Schedule (GS) 13 to 16, Commissioned Officer 
 (CO) 

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


Employees Score 73 Percent On Ethics Survey; Training Is Key To Higher Scores. 

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*


* 3/4 of the wrong answers on gifs, and 2/3 on Hatch Act reflect overly conservative 

interpretations . 

Nt A = not answered 
...

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. 

One respondent said, 
 Understanding the standards is not the problem; rather, implementing 

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 

of makg 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. 

When asked if there ar 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 

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 surey service. Both the mai
 and interviews identify subject areas where training is needed 

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 

managers and not to lit their discretion. We have, therefore, modied this recommendation 

to cal for its distrbution with 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 conduct. 

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 ethics 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 reported on the front page of a newspaper would it 	 appear to be a 

confct of interest. 

82%	 If an organization you are monitoring asks whether you are interested in working for them, you can give them your resume without 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, before 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 infrequent 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 expected 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 

gits to supervisors, except on special non-recurg occasions. 

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 offcial trvel but the benefits must be turned over to the Government. 

TRUE - Current policy, based upon guidance from the Comptroller 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 participating in gambling, bettng, or lottery activities while on Government 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 subject matter relates to your offcial duties. 

FALSE - 45 CFR 74.735-705 & 706 preclude the use of Government time, supplies, equipment or staff to prepare for such outside 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 accept 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 represent 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 approval for some outside activities even if you are not compensated. 

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 purposes, you must be suspended or removed from service. 

TRUE - 31 USC 1349 establishes mandatory penalties of suspension 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 procurement of that contrct in the past two years. 

TRUE - Effective July 16, 1989, under 41 USC 423 there is a twoyear 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.