Department of Health and Human Services
 

OFFICE OF 

INSPECTOR GENERAL 

NATIONAL INSTITUTES OF 


HEALTH’S HANDLING OF 


ALLEGATIONS CONCERNING 


CONFLICT OF INTEREST AND
 

ETHICS VIOLATIONS
 

Daniel R. Levinson
 

Inspector General 


October 2008
 

OEI-03-07-00220
 
 

 

 

 

 

 

Office of Inspector General
 http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 

amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits 

examine the performance of HHS programs and/or its grantees and contractors in carrying 

out their respective responsibilities and are intended to provide independent assessments of 

HHS programs and operations. These assessments help reduce waste, abuse, and 

mismanagement and promote economy and efficiency throughout HHS. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 

HHS, Congress, and the public with timely, useful, and reliable information on significant 

issues. These evaluations focus on preventing fraud, waste, or abuse and promoting 

economy, efficiency, and effectiveness of departmental programs. To promote impact, OEI 

reports also present practical recommendations for improving program operations. 

Office of Investigations 

The Office of Investigations (OI) conducts criminal, civil, and administrative investigations 

of fraud and misconduct related to HHS programs, operations, and beneficiaries. With 

investigators working in all 50 States and the District of Columbia, OI utilizes its resources 

by actively coordinating with the Department of Justice and other Federal, State, and local 

law enforcement authorities. The investigative efforts of OI often lead to criminal 

convictions, administrative sanctions, and/or civil monetary penalties. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support for OIG’s internal operations. OCIG represents OIG in all civil and 

administrative fraud and abuse cases involving HHS programs, including False Claims Act, 

program exclusion, and civil monetary penalty cases. In connection with these cases, OCIG 

also negotiates and monitors corporate integrity agreements. OCIG renders advisory 

opinions, issues compliance program guidance, publishes fraud alerts, and provides other 

guidance to the health care industry concerning the anti-kickback statute and other OIG 

enforcement authorities. 
 

 

 

 

 

Δ EXECUTIVE SUMMARY 

OBJECTIVE 

1. To determine the number and nature of allegations related to 

conflicts of interest and ethics violations received by the National 

Institutes of Health (NIH) between January 1, 2006, and 

June 30, 2007. 

2. To determine the final resolution of these allegations. 

3. To determine how different Institutes and offices at NIH handle 

allegations of conflicts of interest and ethical misconduct. 

BACKGROUND 

Congress, the Office of Government Ethics, and the Department of 

Health and Human Services (HHS) have promulgated 

conflict-of-interest statutes and ethics regulations to help ensure that 

Federal employees are not compromised by conflicts of interest when 

performing their official duties. Although NIH employees are permitted 

to perform outside activities with non-Federal entities, they may not 

undertake activities that might cause actual or perceived conflicts of 

interest. 

The NIH ethics program is composed of the NIH Ethics Office within 

the Office of the Director and ethics offices within each of the Institutes 

and Centers (Institutes) at NIH. The ethics program encompasses all of 

NIH’s approximately 18,000 employees. 

The NIH Ethics Office was established to provide guidance and advice 

to the ethics offices within each Institute and to the NIH community as 

a whole. In addition, the HHS Office of the General Counsel (OGC) 

maintains an ethics division at NIH to provide advice on ethics issues 

and the interpretation of HHS regulations. 

NIH staff members are responsible for reporting employee activities 

that they believe are criminal or improper. The HHS Office of Inspector 

General (OIG) handles allegations of criminal offenses, including 

violations of conflict-of-interest statutes. NIH’s Office of Management 

Assessment (OMA) handles allegations of noncriminal employee 

misconduct and conflicts of interest related to NIH programs and 

activities. 

We reviewed all documentation that we received from NIH pertaining to 

allegations of violations of conflict-of-interest statutes and violations of 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS i 
 

 

 

 

 

 

 

EXECUTIVE SUMMARY 

ethics regulations. The allegations were received by NIH from 

January 1, 2006, to June 30, 2007. We surveyed 31 Deputy Ethics 

Counselors at the Institutes. We also interviewed relevant staff in 

OMA, the NIH Ethics Office, and OGC Ethics Division to determine 

what role each plays in the handling of allegations. As part of our 

interview protocol, we collected any relevant documentation or 

operating procedures that these offices maintain. 

FINDINGS 

The most common allegations involved National Institutes of Health 

employees not completing required ethics training or ethics forms. 

We received documentation from NIH for 565 allegations related to 

conflicts of interest and/or ethics violations. NIH determined that 542 of 

the allegations were substantiated and 23 were unsubstantiated. The 

majority of substantiated allegations (296 allegations) were related to 

employees not completing required ethics training. The second most 

common substantiated allegation (194 allegations) was related to 

employees not completing required ethics forms. 

The majority of allegations were resolved within the National 

Institutes of Health; however, for one-third of allegations, no final 

resolution was documented. NIH resolved 60 percent of substantiated 

allegations internally and forwarded another 7 percent to OIG for 

possible investigation. The majority of allegations were resolved by 

having the employees complete the required ethics training or forms. 

NIH did not provide documentation regarding its final resolutions for 

33 percent of substantiated allegations. The absence of documentation 

does not necessarily mean that the allegation was not resolved. 

However, without complete documentation, it is impossible to determine 

whether and how these allegations were resolved, including whether 

they were handled appropriately and consistently. 

The majority of Institutes do not have written procedures regarding 

how to handle allegations and do not handle allegations uniformly. 

The majority of Institutes do not have Institute-specific policies or 

procedures for reviewing allegations regarding violations of the 

conflict-of-interest statutes and ethics regulations. Institutes reported 

that when handling an allegation, they do not uniformly confer with the 

NIH Ethics Office, the OGC Ethics Division, or OMA. For example, 

eight Institutes reported that they would contact any of the three offices 

for guidance when reviewing allegations. Another 15 Institutes 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS ii 
 

 

 

 

 

E X E E X E CUTIVE S U MMAR Y 

reported that they would seek assistance from only one or two of the 

offices. The remaining Institutes did not specifically report conferring 

with any of the three offices. With regard to criminal allegations, most 

Institutes rely on the NIH Ethics Office, the OGC Ethics Division, or 

OMA to refer these allegations to OIG. However, several Institutes 

make referrals directly to OIG. 

Coordination among the Ethics Office, the Office of Management 

Assessment, and the Office of the General Counsel Ethics Division 

occurs but is not formalized in a written policy. During interviews 

with staff at the NIH Ethics Office, OMA, and the OGC Ethics Division, 

it was clear that they understand their own roles and responsibilities 

with regard to handling allegations. However, although OMA has 

written policies and procedures in place to handle allegations, the NIH 

Ethics Office and the OGC Ethics Division do not. In addition, none of 

the offices have written procedures outlining the coordination between 

the three offices. 

RECOMMENDATIONS 

NIH employees have a responsibility to avoid the appearance of 

impropriety, which can undermine public confidence in the scientific 

integrity of NIH’s research program. Consequently, NIH has a 

responsibility to ensure that its employees abide by Federal statutes 

and regulations regarding ethics and conflicts of interest. Violations of 

these statutes and regulations could jeopardize the scientific integrity of 

NIH’s research programs. 

Because NIH is organized as various components, including Institutes, 

NIH’s ethics program is composed of various offices that work to handle 

allegations of conflict of interest and ethics violations. To maintain 

consistency in how allegations are handled, we recommend that NIH: 

Develop a formal, written policy outlining how allegations of conflicts 

of interest and ethics violations are to be handled among the 

Institutes’ ethics offices, the National Institutes of Health Ethics 

Office, the Office of the General Counsel Ethics Division, and the 

Office of Management Assessment. 

Ensure that documentation detailing how allegations are ultimately 

resolved is maintained. 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS iii 
 

 

EXECUTIVE SUMMARY 
 

AGENCY COMMENTS 

NIH concurred with our recommendations, stating that as of 

August 15, 2008, the recommendations were implemented as a new 

chapter in the “NIH Policy Manual.” However, NIH noted that our 

finding related to employees not completing required ethics forms was 

misleading because it did not provide as context the number of 

employees required to take the training. The official draft report shared 

with NIH did note in the background, as does this final report, that 

NIH’s ethics program encompasses approximately 18,000 employees. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS iv 
 

 

 

 

 

 

 

Δ TABLE OF CONTENTS 

EXECUTIVE SUMMARY ..................................... i 
 

INTRODUCTION ........................................... 1 
 

FINDINGS ................................................. 9 
 

Most allegations involved NIH employees not completing 

required ethics training or ethics forms ...................... 9 
 

One-third of allegations did not have documented resolutions . . . 10 

The majority of Institutes do not have written procedures

regarding how to handle allegations ....................... 13 
 

Coordination among internal offices occurs but is not 

formalized in a written policy............................. 15 
 

RECOMMENDATIONS ..................................... 17

 Agency Comments...................................... 18 
 

APPENDIXES ............................................. 19 
 

A: Types and Number of Allegations Related to Conflict 

of Interest and Ethics Violations Between January 1, 2006, 

and June 30, 2007 ................................... 19 
 

B: Agency Comments ................................... 21 
 

ACKNOWLEDGMENTS .................................... 24 
 
 

 

 

 

 

Δ INTRODUCTION 

OBJECTIVE 

1. To determine the number and nature of allegations related to 

conflicts of interest and ethics violations received by the National 

Institutes of Health (NIH) between January 1, 2006, and 

June 30, 2007. 

2. To determine the final resolution of these allegations. 

3. To determine how different Institutes and offices at NIH handle 

allegations of conflicts of interest and ethical misconduct. 

BACKGROUND 

NIH, located within the Department of Health and Human Services 

(HHS), is the primary Federal agency responsible for conducting and 

supporting medical research. Organized into 27 Institutes and Centers, 

NIH spends billions of dollars annually to support its mission. In fiscal 

year 2007, the total NIH appropriation was over $29.2 billion. Much of 

this funding is distributed through almost 50,000 competitive grants to 

more than 325,000 researchers at over 3,000 universities, medical 

schools, and other research institutions across the country and around 

the world.1 

One of NIH’s stated goals is to “exemplify and promote the highest level 

of scientific integrity, public accountability, and social responsibility in 

the conduct of science.”2 Maintaining this scientific integrity involves 

avoiding conflicts of interest in which employees’ performance of official 

duties might be affected by outside financial interests, such as stock 

holdings or employment activities with non-Federal entities. Although 

NIH employees are permitted to interact with non-Federal entities to 

perform certain outside activities that are crucial to maintaining 

technical proficiency, professional licenses, and academic credentials, 

they may not undertake activities that might cause actual or perceived 

conflicts of interest. Because NIH employees hold positions of trust, 

even the appearance of conflicts of interest can undermine the public’s 

confidence. 

1 NIH. “NIH Budget.” Available online at www.nih.gov/about/budget.htm. 

Accessed on July 3, 2008. 

2 NIH. “About NIH.” Available online at www.nih.gov/about. Accessed on July 3, 2008. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 1 
 

 

 

 

INTRODUCTION 

Conflict of Interest 

Congress has imposed prohibitions to help ensure that Federal 

employees are not compromised by conflicts of interest when performing 

their official duties. For example, 18 U.S.C. § 208 prohibits employees 

from participating in official matters in which they and certain others 

with whom they have relationships (such as spouses, dependent 

children, and outside employers) have a financial interest. A related 

statute, 18 U.S.C. § 209, prohibits Federal employees from 

receiving any salary, or contribution to or supplementation of salary, 

from any source other than the United States as compensation for 

services as a Government employee (such as receiving an honorarium 

for giving an official speech). Violations of these two statutes are 

considered criminal offenses. 

The Office of Government Ethics exercises leadership to prevent 

conflicts of interest on the part of executive branch employees. In 1992, 

the Office of Government Ethics promulgated Standards of Ethical 

Conduct for Employees of the Executive Branch (5 CFR pt. 2635), which 

included prohibitions against engaging in conflicting outside activities. 

In 1996, the Supplemental Standards of Ethical Conduct for Employees 

of HHS (Supplemental Standards), which prohibited all HHS employees 

from engaging in compensated outside activities involving HHS-funded 

grants, contracts, cooperative agreements, and cooperative research and 

development agreements, was issued. 

The Supplemental Standards were revised in August 2005, when 

additional prohibitions on outside activities were imposed. These 

prohibitions prevented NIH employees from engaging in outside 

activities with substantially affected organizations, supported research 

institutions, and health care providers or insurers. The revisions also 

included additional prohibitions on financial holdings for senior NIH 

employees, such that these employees and their spouses and minor 

children must divest all holdings in substantially affected organizations 

in excess of $15,000 per company. 

NIH monitors outside activities and financial interests of its employees 

by reviewing the following forms: 

•	 Request for Approval of Outside Activity (HHS-520). This form is 

required for certain outside activity requests. It contains 

information on the employee’s position; the nature of the outside 

activity; the length of time over which the outside activity will be 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 2 
 

INTRODUCTION 

performed; and the method of compensation, if any, for the outside 

activity. 

•	 Supplemental Information to the HHS-520 (NIH-2657). Outside 

activities involving consulting for industry, legal 

consulting/testimony, and professional practice by NIH employees 

require the submission of this form. 

•	 Annual Report of Outside Activity (HHS-521). NIH employees who 

conduct outside activities are also required to file this annual report 

of outside activities for the previous calendar year by February 28. 

•	 Public Financial Disclosure Report (SF-278) and Confidential 

Financial Disclosure Report (OGE-450). Office of Government 

Ethics regulations outline which executive branch officials are 

required to file these forms. 

•	 Confidential Report of Financial Interests in Substantially Affected 

Organizations for Employees of the NIH (HHS-717-1). Under the 

revised HHS Supplemental Standards of Ethical Conduct, NIH 

employees who file public or confidential financial disclosure forms 

and clinical researchers must disclose the amounts that they invest 

in substantially affected organizations on this form.3 

Ethics Program at the National Institutes of Health 

The ethics programs of HHS agencies, including NIH, are coordinated 

by the Designated Agency Ethics Official, who also serves as the 

Department’s Associate General Counsel for Ethics. The Designated 

Agency Ethics Official appoints Deputy Ethics Counselors in each 

agency, issues policies and procedures for the HHS ethics program, 

establishes ethics training for the Deputy Ethics Counselors and HHS 

employees, and conducts periodic site reviews of agencies’ ethics 

programs. 

The Deputy Director of NIH serves as the Deputy Ethics Counselor for 

all of NIH and the NIH Ethics Office assists the NIH Deputy Ethics 

Counselor in overseeing the NIH ethics program. The ethics program 

encompasses all of NIH’s approximately 18,000 employees. NIH 

requires more than one-third of these employees to submit financial 

disclosure forms on an annual basis. 

3 The HHS-717-1 used to be referred to as the HHS-716. For the purposes of this report, 

the HHS-716 and HHS-717-1 constitute the same form. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 3 
 

 

 

INTRODUCTION 

The NIH Ethics Office was established to provide guidance and advice 

to the ethics offices within each Institute and Center and to the NIH 

community as a whole. It also serves as the ethics office for senior NIH 

employees and Office of the Director employees and, as such, provides 

guidance and advice to these employees. It also assists with the formal 

and informal training of Institute officials. 

Each Institute’s and Center’s ethics office at NIH is also managed by a 

Deputy Ethics Counselor. In addition, the Office of Director, the Office 

of Research Facilities, and the Office of Research Services (both located 

within the Office of Director) each have their own Deputy Ethics 

Counselors as well. Hereafter we will use the term “Institute” to 

represent all Institutes, Centers, and offices. Each Deputy Ethics 

Counselor is responsible for the overall coordination and management of 

that Institute’s ethics program. Deputy Ethics Counselors review NIH 

staff financial disclosure forms and requests to engage in activities with 

outside organizations. Some of these forms are also initially reviewed 

by the employee’s supervisor. Deputy Ethics Counselors can approve 

and disapprove outside activity requests based on the requests’ 

compliance with current ethics regulations and policies. Institutes may 

also have their own Ethics Coordinators, who provide administrative 

and program support for the Institutes’ ethics programs. 

The HHS Office of the General Counsel (OGC) maintains an ethics 

division at NIH. The OGC Ethics Division functions as the NIH liaison 

to the Office of Government Ethics and provides advice on ethics issues, 

such as conflicts of interest, financial disclosures, and ethics training 

materials. 

The NIH Office of Management Assessment (OMA) also has a 

responsibility regarding the ethics program at NIH. It is responsible for 

reviewing allegations referred to its office. OMA does not have any 

other ethics functions. 

Policy and Procedures for Reporting Allegations of Misconduct 

All NIH employees, including management and supervisory personnel, 

are responsible for reporting allegations of noncriminal misconduct to 

the appropriate supervisor, to a higher level management official within 

the organization, or to OMA. According to Chapter 1754 of the “NIH 

Policy Manual,” OMA is responsible for reviewing allegations of 

noncriminal employee misconduct and conflicts of interest. 

All NIH employees also have the responsibility for reporting employee 

activities that they believe are criminal. According to the “NIH Policy 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 4 
 

 

 

INTROD U C T I O N 

Manual,” every employee, supervisor, and management official should 

report any allegation of criminal offense to the Office of Inspector 

General (OIG) for possible investigation.4 Depending on its assessment 

of the allegation, OIG may decide to conduct an investigation or to refer 

the allegation to OMA for administrative action. 

NIH employees may confer with OMA at any time for advice and to 

determine whether allegations are criminal in nature. OMA does not 

have authority to investigate allegations involving criminal offenses by 

NIH employees. 

Reviews of National Institutes of Health’s Ethics Program 

Multiple reviews conducted in recent years have highlighted the 

weaknesses of the NIH ethics program. The Office of Government 

Ethics has conducted five reviews since 1987. These reviews reported 

problems with the outside activity review process. In 2004, the most 

recent review, the Office of Government Ethics reported that “. . . NIH 

has had a permissive culture on matters relating to outside 

compensation for more than a decade.” It also noted that there is 

confusion at NIH as to who is responsible for the ethics program. 

According to the report, this results from having OGC ethics staff at 

NIH as well as a separate NIH Ethics Office. 

In response to conflict of interest concerns, NIH convened a Blue Ribbon 

Panel on Conflict-of-Interest Policies in 2004. The panel concluded that 

“the many hiring authorities used by NIH, combined with different 

regulatory and statutory requirements regarding financial disclosure, 

create a patchwork of policies and procedures that could easily lead to 

misunderstandings.”5 The panel’s recommendations helped in the 

development of revised Supplemental Standards, which were published 

in 2005. New provisions were added specifically for NIH employees. 

In 2005, OIG published a report entitled “Outside Activities of 

Senior-Level NIH Employees” (OEI-01-04-00150) that assessed NIH’s 

process for reviewing outside activity requests between 2001 and 2003. 

The study found that limited information submitted by employees and 

inadequacies in the review process inhibit NIH’s ability to effectively 

review outside activity requests. OIG recommended that NIH improve 

4 “NIH Policy Manual,” Chapter 1754, Reporting Allegations of Criminal Offenses, 

Misuse of Grant and Contract Funds, or Improper Conduct by an NIH Employee. 

5 “Report of the National Institutes of Health, Blue Ribbon Panel on Conflict-of-Interest 

Policies,” June 22, 2004, p. 21. 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 5 
 

 

 

 

INTRODUCTION 

the quality and extent of information collected for outside activities and 

address the inadequacies in the review process for outside activities. 

NIH concurred with the findings and recommendations of the report. 

NIH noted that it had already taken many steps to address the 

vulnerabilities identified in the report and had further initiatives 

planned.6 

METHODOLOGY 

Scope 

This study is limited to allegations provided by NIH that relate to 

violations of conflict of interest statutes and violations of ethics 

regulations (hereafter referred to as allegations).7 We limited our 

review of allegations to those made during the 18-month period between 

January 1, 2006, and June 30, 2007. To assess the handling of these 

allegations by NIH, we focused our review on the NIH Ethics office, 

OMA, the OGC Ethics Division at NIH, the Institutes, and Deputy 

Ethics Counselors. 

Data Sources and Data Collection 

We requested all documentation pertaining to allegations. We 

requested that the documentation include: 

(1) Allegations received by NIH (including the Institutes, the NIH 

Ethics Office, and OMA) and the OGC Ethics Division at NIH during 

the 18-month period between January 1, 2006, and June 30, 2007. 

Allegations included any evidence of noncompliance that Deputy Ethics 

Counselors found in the course of their ethics work and that involved 

clear, intentional, and preexisting or ongoing noncompliance. 

(2) Any letters, e-mails, memorandums, records of phone conversations, 

or other materials relevant to the allegations. 

6 During its review, OIG also found that two outside activities may have violated HHS 

supplemental regulations, which prohibit employees from providing consultative or 

professional services for compensation to assist in the preparation of any grant application 

intended for submission to HHS. These two cases were referred to NIH for further review. 

NIH agreed that the cases appeared to violate HHS supplemental regulations and the 

outside activities should not have been approved. 

7 Conflict-of-interest statutes are established in 18 U.S.C. §§ 208 and 209. Ethics 

regulations are established in Executive Branch Financial Disclosure, Qualified Trusts, and 

Certificates of Divestiture; Standards of Ethical Conduct for Employees of the Executive 

Branch; and Supplemental Standards of Ethical Conduct and Financial Disclosure 

Requirements for Employees of HHS (5 CFR pts. 2634, 2635, 5501, and 5502). 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 6 
 

 

 

 

INTROD U C T I O N 

We also conducted structured interviews with relevant staff in OMA, 

the NIH Ethics Office, and the OGC Ethics Division to determine what 

role each office plays in the handling of allegations. Our questions 

covered topics such as roles and responsibilities in the ethics program, 

policies and procedures for handling allegations, coordination among 

the different offices within NIH when handling allegations, and training 

and outreach efforts. We conducted these interviews onsite at NIH. As 

part of our interview protocol, we collected any relevant documentation 

or operating procedures that these officials maintained. 

Additionally, we sent a survey to the Deputy Ethics Counselors for NIH 

and the Institutes.8 All of the Deputy Ethics Counselors responded to 

our survey, for a total of 31 survey responses. 

Our questions covered topics such as each Institute’s policies and 

procedures for how employees report allegations; the Deputy Ethics 

Counselors’ understanding of the roles of OMA, the NIH Ethics Office, 

and the OGC Ethics Division; the circumstances under which 

allegations are referred to the appropriate NIH offices and the referral 

policies and procedures; the Institute’s procedures for determining when 

disciplinary action is necessary; and the Institute’s outreach and 

training regarding the reporting of allegations. 

Data Analysis 

We used a standard protocol to extract information from the 

documentation. From the information, we determined the number, 

nature, and final resolutions of the allegations. Some of the 

documentation we received involved allegations that related to multiple 

violations and/or instances of misconduct. For these allegations, each 

violation and/or instance of misconduct was counted separately. If the 

same type of allegation was made against a particular employee during 

different periods of time, the allegations were counted separately as 

well. If duplicate documentation regarding an allegation was received 

by more than one NIH office or Institute, the allegation was counted 

only once. 

From the survey data, we determined the frequency of responses to 

closed-ended survey questions and reviewed and categorized responses 

to open-ended survey questions. 

8 The NIH Deputy Ethics Counselor serves as the Deputy Ethics Counselor for NIH’s 

senior employees. 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 7 
 

INTRODUCTION 

Standards 

This study was conducted in accordance with the “Quality Standards for 

Inspections” issued by the President’s Council on Integrity and 

Efficiency and the Executive Council on Integrity and Efficiency. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 8 
 

 

Δ FINDINGS 

The most common allegations involved National 

Institutes of Health employees not completing 

required ethics training or ethics forms 

We received documentation from 

NIH for 565 allegations related to 

conflicts of interest and/or ethics 

violations between January 1, 2006, 

and June 30, 2007. According to the documentation, NIH determined 

that 542 of the allegations were substantiated and 23 were 

unsubstantiated. 

Table 1 below shows the categories and numbers of allegations received 

by NIH. Appendix A provides more details on the specific types and 

numbers of allegations. 

For the 542 substantiated allegations, the majority (296) involved 

employees’ failure to complete required ethics training. All of these 

allegations came from two Institutes. One Institute had 279 allegations 

and the other Institute had 17. 

Table 1. Number of Allegations Related to Conflicts of Interest and 

Ethics Violations by NIH Employees Between January 1, 2006, and 

July 30, 2007 

Category of 

Allegations 

Number of 

Unsubstantiated 

Allegations 

Number of 

Substantiated 

Allegations 

Total Number of 

Allegations 

Failure To Complete 

Required Ethics 

Training 

Failure To Complete 

Required Ethics Forms 

Violations Related to 

Outside 

Activities/Outside 

Entities 

Violations Related to 

Conflict of Interest 

Statutes 

13 

2 

4 

0 

296 

194 

18 

15 

309 

196 

22 

15 

Other 2 10 12 

Misuse of Position 2 9 11

 Total 23 542 565 

Source: OIG analysis of NIH allegation documents. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 9 
 

 

 

 

 

F I NDING S 

The second most common substantiated allegation was related to 

employees not completing required ethics forms.9 We reviewed 

documentation for 194 of these allegations at 15 Institutes. These 

allegations included: (1) failing to file required forms (162 allegations), 

(2) filing required forms in an incomplete manner (26 allegations), and 

(3) filing required forms in an untimely manner (6 allegations). 

Of the 162 substantiated allegations related to failure to file required 

forms, 65 percent involved financial disclosure forms (OGE-450, SF-278, 

HHS-717-1, and/or an unspecified financial disclosure form). The 

remaining 35 percent were related to failure to file an outside activity 

form (HHS-520, HHS-521, and/or NIH-2657) or Section 502 

authorization request. 

There were 52 substantiated allegations that were not related to ethics 

training or ethics forms. Eighteen of these allegations involved 

violations related to outside activities or outside entities. Examples of 

this type of allegation include employees conducting prohibited outside 

activities or holding prohibited financial interests in outside entities. 

Another 15 allegations were potential criminal violations of 

conflict-of-interest statutes. Ten allegations involved other issues, such 

as employees using Government resources for personal use. The 

remaining nine allegations were related to employees inappropriately 

using their official titles or inappropriately using their authority in the 

workplace. 

The majority of allegations were resolved within 

the National Institutes of Health; however, for 

one-third of allegations, no final resolution was 

documented 

NIH provided documentation that 

detailed how it resolved 60 percent 

of substantiated allegations 

(326) internally and referred 

another 7 percent (39) to OIG. 

For the remaining 33 percent of 

9 Required forms include the HHS-520, HHS-521, NIH-2657, SF-278, OGE-450, and 

HHS-717-1. We received one allegation related to an employee not filing a Section 502 

authorization request. This permits an employee who knows that a particular matter 

involving specific parties is likely to have a direct and predictable effect on the financial 

interest of a member of the employee’s household, or who knows that a person or entity with 

which the employee has a covered relationship is or represents a party to such matter, to 

participate in the matter because the interest of the Government in the employee’s 

participation outweighs the concern that a reasonable person may question the integrity of 

the agency’s programs and operations (5 CFR § 2635.502). 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 10 
 

 

 

 

 

 

FINDINGS 

allegations (177), NIH did not provide documentation about 

how it resolved the allegations. Table 2 below shows how the 

542 substantiated allegations were handled. 

Table 2. Final Resolutions of Allegations Related to Conflicts of Interest and Ethics Violations by 

NIH Employees Between January 1, 2006, and July 30, 2007 

Category of 

Allegations 

Number of 

Substantiated 

Allegations Resolved 

by NIH 

Number of 

Substantiated 

Allegations Referred 

to OIG 

Number of 

Substantiated 

Allegations Without 

Documented 

Resolution 

Number of 

Substantiated 

Allegations 

Failure To Complete 

Required Ethics 

Training 

196 0 100 296 

Failure To Complete 

Required Ethics 

Forms 

116 12 66 194 

Violations Related to 

Outside 

Activities/Outside 

Entities 

5 11 2 18 

Violations Related to 

Conflict of Interest 

Statutes 

1 14 0 15 

Other 4 1 5 10 

Misuse of Position 4 1 4 9

 Total 326 39 177 542 

Source: OIG analysis of NIH allegation documents. 

Sixty percent of allegations were resolved internally within the National 

Institutes of Health 

Because most of the 326 substantiated allegations that were resolved by 

NIH involved violations of ethics training and form requirements, NIH 

resolved these violations by having employees complete the required 

training or forms. 

For 195 of the 296 substantiated allegations involving ethics training, 

NIH provided documentation to show that the employees had 

eventually completed the required training. For one additional 

allegation, NIH provided documentation that the employee no longer 

worked at NIH. 

Of the 194 substantiated allegations concerning required ethics forms, 

NIH resolved 116 using a number of approaches. It resolved 101 by 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 11 
 

 

 

FINDING 
 S 

having the employees submit the missing required forms and/or missing 

information. NIH resolved another 10 ethics form allegations by: 

suspending administrative actions (leave requests, travel requests, and 

bonuses) for five employees until ethics forms were completed; directing 

two employees to cease conducting the outside activities; placing a letter 

regarding the violation in one employee’s personnel file; failing to 

approve an employee’s late HHS-520 request; and having one employee 

resign from his/her position at NIH.10 For five allegations related to the 

untimely filing of paperwork, the employees were counseled as to the 

importance of submitting paperwork on time. 

NIH resolved 14 of the 52 substantiated allegations not related to ethics 

training or forms. NIH resolved these 14 allegations using a number of 

different methods. These methods included: removing an employee 

from NIH employment, restricting an employee’s use of Government 

property, and having an employee return travel expenses to the outside 

entity that paid for them. 

Seven percent of allegations involved potential criminal violations and were 

referred to the Office of Inspector General for possible investigation 

Because NIH does not have authority to investigate allegations 

involving criminal offenses, it forwarded 39 potentially criminal 

allegations to OIG for possible investigation. Fourteen of the fifteen 

allegations related to potential criminal violations of conflict-of-interest 

statutes were included in this group. 

One allegation involving a potential violation of 18 U.S.C. § 208 was not 

referred to OIG. This allegation involved an employee who was working 

on an NIH-funded research project and whose spouse was listed as a 

contractor on the same project. This allegation was not forwarded to 

OIG because it was resolved internally by removing the employee from 

the NIH research project. 

The 39 allegations involved potential violations of conflict-of-interest 

statutes, as well as violations of other ethics regulations. Examples of 

the potential criminal allegations include employee(s) who: 

• served as a director of a company that submitted an application for 

an exclusive license to develop and commercialize a drug privately 

while participating as an NIH employee in research and data 

collection for the same drug, 

10 Other allegations led to the employee’s resignation. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 12 
 

 

 

 

 

 

 

 

F I NDING S 

•	 influenced the award of a contract to a university from which the 

employee is on a leave of absence, 

•	 improperly acted as a consultant for pharmaceutical companies, 

•	 used position and influence to encourage an NIH Board of Scientific 

Directors to deny funding to an intramural research program 

investigating a drug because of the employee’s financial ties with a 

pharmaceutical company developing a competing drug, 

•	 conducted prohibited outside activities, and 

•	 accepted compensation from prohibited outside entities. 

Thirty-three percent of allegations had no documented final resolution 

NIH did not provide documentation showing its final resolution of 

177 substantiated allegations. The absence of documentation does not 

necessarily mean that the allegations were not resolved. However, 

without complete documentation, it is impossible to determine whether 

and how these allegations were resolved, including whether they were 

handled appropriately and consistently. 

We could not determine whether ethics training was completed for the 

100 allegations related to employees not completing the required 

training. For 66 allegations related to employees not completing 

required ethics forms, there was no documentation to show that the 

required forms and/or missing information were submitted. We could 

not determine the final resolution of 11 allegations related to other 

types of violations, such as employees inappropriately using their 

official titles and using Government resources for personal use. 

The majority of Institutes do not have written 

procedures regarding how to handle allegations 

and do not handle allegations uniformly 

Twenty of thirty-one Institutes do 

not have written procedures for 

reviewing allegations regarding 

violations of the 

conflict-of-interest statutes and ethics regulations. Although 

11 Institutes reported that they have written procedures, the 

documentation we reviewed indicated that these were not 

Institute-specific procedures that detailed a review process. Rather, the 

Institutes were referring to more general policies or procedures 

established by NIH, OIG, or Federal regulation. 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 13 
 

 

FINDING 
 S 

When reviewing allegations, Institutes consult with or receive guidance from 

different offices 

Some Institutes reported that they do not uniformly confer with the 

NIH Ethics Office, the OGC Ethics Division, or OMA. For example, 

eight Institutes reported that they would contact any of the three offices 

for guidance when reviewing allegations. Six Institutes stated that they 

would contact either the NIH Ethics Office or the OGC Ethics Division 

for guidance regarding how to proceed with an allegation. Another five 

Institutes reported contacting either the NIH Ethics Office or OMA 

when reviewing an allegation. Three Institutes reported contacting only 

the NIH Ethics Office, and one reported contacting only OMA. 

In contrast, some other Institutes did not cite any of the three offices 

when describing how they review allegations. Three Institutes stated 

that they follow NIH policies and procedures in reviewing allegations. 

Another five Institutes reported that they review relevant documents 

and facts, but did not specifically state that they confer with the NIH 

Ethics Office, the OGC Ethics Division, or OMA. 

Several Institutes refer allegations of criminal offenses directly to the Office 

of Inspector General, but most rely on other National Institutes of Health 

offices to make the referral 

As stated in the “NIH Policy Manual,” Chapter 1754, “. . . every 

employee, supervisor, and management official shall report any 

allegations of criminal offenses to the OIG. . . .” This would include 

violations of the financial conflict of interest statutes (18 U.S.C. §§ 208 

and 209). We found that the majority of Institutes work with the NIH 

Ethics Office, the OGC Ethics Division, or OMA before referring 

criminal allegations to OIG. Seventeen Institutes forward criminal 

allegations to the NIH Ethics Office, the OGC Ethics Division, or OMA; 

these Institutes rely on these offices to refer the allegation to OIG if 

they believe it is warranted. Eight Institutes reported that they refer 

allegations of criminal offenses directly to OIG only after consultation 

with the NIH Ethics Office, the OGC Ethics Division, or OMA. 

Other Institutes reported that they would forward criminal allegations 

directly to OIG. Three Institutes reported that they follow the 

procedures outlined in the “NIH Policy Manual,” Chapter 1754, to 

determine when and how to refer allegations to OIG. Two Institutes did 

not specifically mention involving the NIH Ethics Office, the OGC 

Ethics Division, or OMA in the referral process, but reported that they 

refer allegations of criminal offenses directly to OIG. The remaining 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 14 
 

 

FINDINGS 

Institute did not respond to our question regarding referral procedures 

to OIG. 

The majority of Institutes refer allegations of noncriminal offenses to the 

Office of Management Assessment 

According to the “NIH Policy Manual,” allegations of improper employee 

conduct, such as violations of standards of conduct, shall be reported to 

OMA. Eighteen of the thirty-one Institutes reported that they refer 

allegations of noncriminal violations of the regulations directly to OMA. 

An additional seven Institutes stated that they refer allegations 

requiring further investigation to OMA. Three Institutes stated that 

the nature of the allegation would determine whether they refer 

allegations to OMA. One Institute replied that referrals would not be 

made directly to OMA, but did not elaborate further. Two Institutes did 

not provide a response to our question regarding referral to OMA. 

Coordination among the Ethics Office, the 

Office of Management Assessment, and the 

Office of the General Counsel Ethics Division 

occurs but is not formalized in a written policy 

From interviews with staff at 

the NIH Ethics Office, OMA, 

and the OGC Ethics Division, it 

was clear that they understand 

their own roles and 

responsibilities with regard to handling allegations. They reported that 

OMA is responsible for reviewing reported allegations, the OGC Ethics 

Division provides legal advice and guidance, and the NIH Ethics Office 

maintains the role of ethics policy expert. Because the three offices 

have distinct roles and responsibilities, they work together as necessary 

to handle allegations. However, this coordination is not outlined in a 

written policy. If staff were to change, this coordination might not occur 

because there are no policies in place to guide new staff. 

All three offices encourage employees to report allegations. Although 

employees can report allegations to any of the three offices, the OGC 

Ethics Division and the NIH Ethics Office understand that OMA is 

responsible for case development. The NIH Ethics Office reported that, 

for tracking purposes, it forwards to OMA allegations that need further 

investigation or need to be referred to OIG. If the NIH Ethics Office 

needs help in determining whether an allegation is criminal, it will seek 

assistance from the OGC Ethics Division. If an allegation is reported to 

the OGC Ethics Division, it consults with the Designated Agency Ethics 

Official to determine whether the allegation should be referred to OMA 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 15 
 

 

 

 

 

F I NDING S 

or directly to OIG. The OGC Ethics Division reported that, as a matter 

of courtesy, it informs OMA if an allegation is referred to OIG. 

OMA follows a standard procedure for handling allegations as they are 

received.11 However, these procedures do not address OMA’s 

coordination with either the NIH Ethics Office or the OGC Ethics 

Division. OMA reported that it seeks advice from the OGC Ethics 

Division and the NIH Ethics Office when necessary. If OMA needs legal 

advice regarding an allegation or clarification of whether an allegation 

is within the purview of OIG, it contacts the OGC Ethics Division and 

requests a written legal opinion. If OMA has a policy question 

regarding an allegation, it consults the NIH Ethics Office. 

Unlike OMA, the OGC Ethics Division and the NIH Ethics Office do not 

have written policies for handling allegations. They also do not have 

any written procedures outlining coordination among the three offices. 

The NIH Ethics Office is currently developing a policy to help employees 

determine where allegations should be reported and to provide some 

general guidance for managers and employees. 

11 OMA is currently in the process of revising its internal manual, which outlines the 

case review policies and procedures. 

O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 16 
 

FINDINGS 

 

Δ RECOMMENDATIONS 

NIH employees have a responsibility to avoid the appearance of 

impropriety, which can undermine public confidence in the scientific 

integrity of NIH’s research program. Consequently, NIH has a 

responsibility to ensure that its employees abide by Federal statutes 

and regulations regarding ethics and conflicts of interest. Violations of 

these statutes and regulations could jeopardize the scientific integrity of 

NIH’s research programs. 

Because NIH is organized as various components, including Institutes, 

NIH’s ethics program is composed of various offices that work to handle 

allegations of conflict of interest and ethics violations. To maintain 

consistency in how allegations are handled at NIH, we recommend that 

NIH: 

Develop a Formal, Written Policy Outlining How Allegations of 

Conflicts of Interest and Ethics Violations Are to be Handled Among 

the Institutes’ Ethics Offices, the National Institutes of Health Ethics 

Office, the Office of the General Counsel Ethics Division, and the 

Office of Management Assessment 

This policy should outline: 

• when managers and Deputy Ethics Counselors should report 

allegations and to which office they should report them; 

• which office should handle questions regarding allegations; as part 

of this clarification, NIH may want to designate a single, 

centralized office for allegation intake; 

• how the Deputy Ethics Counselors, NIH Ethics Office, the OGC 

Ethics Division, and OMA coordinate and share information 

regarding an allegation; 

• how much factfinding/case development should be conducted by 

each office regarding an allegation; and 

• the definitions of criminal and noncriminal allegations. 

Ensure That Documentation Detailing How Allegations Are Ultimately 

Resolved Is Maintained 

Because we found no documented resolutions for one-third of 

substantiated allegations, we believe that NIH should require all of its 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 17 
 

 

RECOMMENDATIONS 

offices to maintain complete documentation regarding how they resolve 

allegations about ethics and conflicts of interest. 

AGENCY COMMENTS 

NIH concurred with our recommendations, stating that as of 

August 15, 2008, the recommendations were implemented as a new 

chapter in the “NIH Policy Manual.” This new chapter is entitled 

“Managing Employee Non-Compliance with Government Ethics 

Requirements.” However, NIH noted that our finding related to 

employees not completing required ethics forms was misleading because 

it did not provide as context the number of employees required to take 

the training. NIH stated that its policy requires all employees to 

complete ethics training. In contrast, Federal regulation requires only 

those who file public and confidential financial disclosure forms to 

complete annual ethics training. Therefore, NIH reported that ethics 

training noncompliance would be less than 2 percent of the total 

population of approximately 18,000 NIH employees required to take the 

training. The official draft report shared with NIH did note in the 

background, as does this final report, that NIH’s ethics program 

encompasses approximately 18,000 employees. 

The full text of NIH’s comments is presented in Appendix B. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 18 
 

 

 

Types and Number of Allegations Related to Conflicts of Interest and Ethics Violations Between 

January 1, 2006, and June 30, 2007 

Δ A P P E N D I X A 

Number of Number of Total Number of Category of Allegations Specific Type of Allegation Substantiated Unsubstantiated Allegations Allegations Allegations 

Failure To Complete Required NA 296 13 309 Ethics Training (Total = 309) 

Failure To File the OGE-450 62 0 62 

Failure To File the HHS-520 45 1 46 

Failure To File the HHS-717-1 38 1 39 

Failure To Failure To File the HHS-521 10 0 10 File 

Paperwork Failure To File the SF-278 4 0 4 (Total = 164) 

Failure To File an Unspecified 1 0 1 Financial Disclosure Form Failure To
 Failure To File a Section 502 Complete 1 0 1 Authorization Request1 

Required 

Ethics Forms Failure To File the NIH-2657 1 0 1 

(Total = 196) Filing an Incomplete 21 0 21 HHS-717-1 

Filing Filing an Incomplete HHS-520 2 0 2 Incomplete 

Paperwork Filing an Incomplete SF-278
 2 0 2 (Total = 26) 

Filing an Incomplete NIH-2657 1 0 1 

Untimely
 

Filing of Untimely Filing of the HHS-520 6 0 6 Paperwork 

(Total = 6) 

Conducting a Prohibited 5 3 8 Outside Activity 

Financial Interest in Outside 

Entity Influencing Professional 3 0 3 

Decisions 

Holding Prohibited Financial 3 0 3 Interests in Outside Entities 

Inappropriately Accepting 

Reimbursement of Travel 3 0 3 Violations Related to Outside Expenses From Outside Entity Activities/Outside Entities Accepting Prohibited

(Total = 22 ) Compensation From Outside 1 1 2 

Entities 

Comingling Outside Activities 

With Official Duties 1 0 1

Conducting an Outside Activity 

as an Official Duty Without 1 0 1 

Approval 

Asking Outside Entity To 

Donate Honoraria to Private 1 0 1 

Foundation 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 19 
 

 

 

APPENDIX ~ A 

Category of Allegations Specific Type of Allegation 

Number of 

Substantiated 

Allegations 

Number of 

Unsubstantiated 

Allegations 

Total Number of 

Allegations 

Violation of 18 U.S.C. § 208 13 0 13 

Violations Related to Conflict 

of Interest Statutes (Total = 15) Violation of 18 U.S.C. § 209 1 0 1 

Violation of 18 U.S.C. § 2052 1 0 1 

Using Government 

Resources for Personal Use 6 0 6 

Misuse of Federal Funds by 

Not Complying With 

Government Travel Rules 

0 1 1 

Supervisory Failure 

Regarding Ethics Duties 1 0 1 

Other (Total = 12) Overuse of Vendor 1 0 1 

Improper Purchase of 

Government Equipment 1 0 1 

Violation of Employment Law 1 0 1 

NIH Staff Denying Funding to 

Outside Entity 0 1 1 

Misuse of Position (Total = 11) 

Inappropriate Use of Official 

Title 7 2 9 

Inappropriate Use of Authority 2 0 2 

 Total 542 23 565 

Source: Office of Inspector General analysis of National Institutes of Health allegations documents. 1 This permits an employee who knows that a particular matter involving specific parties is likely to have a direct and predictable effect 

on the financial interest of a member of the employee’s household, or who knows that a person or entity with which the employee has a 

covered relationship is or represents a party to such matter, to participate in the matter because the interest of the Government in the 

employee's participation outweighs the concern that a reasonable person may question the integrity of the agency’s programs and 

operations (5 CFR § 2635.502). 

2 18 U.S.C. § 205 prohibits employees from representing the interests of an outside entity before a Government agency. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 20 
 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 21 

Δ APPENDIX~B 

Agency Comments 
 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 22 

APPENDIX ~ B 
 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 23 

APPENDIX ~ B 
 

APPENDIX Δ ACKNOWLEDGMENTS 

This report was prepared under the direction of Robert A. Vito, Regional 

Inspector General for Evaluation and Inspections in the Philadelphia 

regional office, and Linda M. Ragone, Deputy Regional Inspector 

General. 

Tanaz Dutia served as the team leader for this study. Other principal 

Office of Evaluation and Inspections staff from the Philadelphia 

regional office who contributed to the report include Diane Epstein and 

Maria Johnson; central office staff who contributed include Ayana 

Everett and Rita Wurm. 

 O E I - 0 3 - 0 7 - 0 0 2 2 0 N I H ’ S HANDLING OF ALLEGATIONS C ONCERNING C ONFLICT OF I NTEREST AND E THICS V IOLATIONS 24