National Aeronautics and Space Administration 

Headquarters 

Washington, DC 20546-0001 

December 16, 2019 

Reply to Attn of: General Law Practice Group 

TO: 

FROM: 

Distribution 

Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance at the Senior Executive Association 

2019 Presidential Rank Awards Leadership Summit, December 17, 2019 

On December 17, 2019, the Senior Executive Association (SEA) will host the Senior 

Executive Association 2019 Presidential Rank Awards Leadership Summit at the 

Mayflower Hotel in Washington, D.C. SEA and the Federal Executive Institute Alumni 

Association (FEIAA), with which SEA has coordinated with on certain aspects of the 

activity, are in control of the organizing and planning, and Summit invitations.

1 The 

purpose of the event is to bring experts together with distinguished members of the Federal 

service together for training and discussions on innovative technologies, techniques and 

practices. Approximately 500 people are expended to attend the day portion of the 

Summit, which will include a breakfast and the presentation of awards during the luncheon. 

The estimated value of the day program is $250 per person. SEA will also host a dinner 

program to which at least 120 Summit invitees are also invited, to honor this year's 

Presidential Rank awards recipients, valued ( depending on SEA membership at between 

$175-$400 per person). Attendance at these events will allow attendees to share 

information regarding various NASA programs, and to gain information on new 

approaches and best practices to use at NASA. 

I further determine there is an Agency interest in having NASA personnel attend these 

events because they will enable attendees to exchange ideas and views pertaining to 

NASA's policies, programs and operations. Attendees will include representatives from 

industry, non-profit organizations and academia, in addition to distinguished Federal 

workforce members. Accordingly, NASA employees-including NASA employees in 

non-career positions required to sign the ethics pledge under Executive Order 13770 - who 

do not have a significant role in a matter affecting the interests of the SEA and/or FEIAA 

1 Some invitations were issued in a cooperative effort between SEA and FEIAA to enable certain recipients to 

attend-at no additional cost to FEIAA-a day of training, including the breakfast and award luncheon. 

Invitations issued in conjunction with this cooperation between the organizations are considered to be provided 

by the sponsor(s) of the event for purposes ofU.S. Office of Government Ethics regulations on the widely 

attended gathering exception. 
may accept an invitation for free attendance to this event. In those circumstances, I find 

that the Agency's interest in attendance outweighs any concern that the individual may be, 

or may appear to be, improperly influenced in the performance of their duties. 

However, NASA employees who have a significant role in any pending matter affecting 

the interests of any of the organizers, such as procurement duties, program management, or 

negotiating or administering a Space Act Agreement, should seek a separate determination 

from their local ethics counselor as to whether they may accept the invitation for this event. 

A ward winners may accept the trophy presented to them in recognition of their 

achievement. Congratulations to NASA's award winners! 

A

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