National Aeronautics and

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

 

 July 11, 2023

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance by NASA Employees at the Joint 

"JWST and Beyond Event" on July 13, 2023

On July 13, 2023, Northrop Grumman, Ball Aerospace, L3/Harris, Lockheed Martin, and 

Association of Universities for Research in Astronomy (AURA), AURA being designated 

as a not-for-profit organization under Section 501(c)(3) of the Internal Revenue Service 

Code, will jointly hold a reception at The National Academies Great Hall, 2101 

Constitution Ave., Washington, DC, from 6 p.m. to 9 p.m. AURA will be in control of the 

planning, organizing, and issuing invitations for this event. 

Approximately 400 people are expected to attend the event. Attendees will have a diversity 

of views or interests and will include personnel from other federal agencies, members of 

the legislative branch, state and local government officials, representatives from academia,

industry, and foreign entities. The estimated cost of the event, including all food and 

beverages, is approximately $100 per person. Attendance at this event will allow NASA 

attendees to exchange information regarding various NASA programs. I find that the event 

meets the requirements of a “widely attended gathering” as defined in 5 C.F.R. § 

2635.204(g)(2). 

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

event because it will provide an opportunity for the invited persons to exchange ideas and 

views pertaining to NASA’s policies, programs and operations. NASA employees who do 

not have a significant role in a matter affecting the interests of the five sponsors may accept 

an invitation for free attendance for themselves and a guest to the 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 the sponsors, 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. 
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Additionally, NASA employees in non-career positions who are required to sign an ethics 

pledge under Executive Order 13989 may only accept the invitation if they reimburse the 

hosts the fair market value of the events.

You are reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), which provides that 

you may accept gifts valued at no more than $20 per occasion (and no more than $50 from 

one source in a calendar year). We understand that AURA will be distributing lapel pins, 

stickers and informative handouts which NASA attendees, including NASA employees in 

non-career positions who have signed the ethics pledge, may accept. An honor basket will 

be provided to reimburse for other gifts. 

Attendees are reminded to exercise any COVID-19 precautions appropriate to their

individual situation.

Adam F. Greenstone