Federal Manager's Daily Report: Wednesday, October 27, 2004

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In This Week's Issue
1. Office of Government Ethics Issues Memo on Seeking Outside Employment
2. Guidance Covers Waivers and How to Recuse Quietly
3. Brand New Federal Employees Legal Survival Guide Just Published
http://www.fedweek.com/pub/index.php 
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1. Office of Government Ethics Issues Memo on Seeking Outside Employment
Prompted by Congressional and media scrutiny on federal 
employees working with prospective employers, the Office of 
Government Ethics has reissued a summary of the 
post-employment restrictions in 18 U.S.C 207 emphasizing 
their applicability to employees seeking new jobs. 
 
The provisions covering job seeking are in subpart F, 
Standards of Ethical Conduct, which state that an employee 
"shall not participate personally and substantially in any 
particular matter that, to his knowledge, has a direct and 
predictable effect on the financial interests of a 
prospective employer with whom the employee is seeking 
employment."  

In this case seeking employment includes expressing interest, 
"unsolicited communications by the employee, and any 
response by the employee, other than rejection, to an 
unsolicited overture from a prospective employer," even if 
it is through a headhunter or other intermediary, according 
to OGE�s summary. 

It warned that employees should be aware that "just testing 
the waters," is not justification for disregarding their 
recusal obligations -- and cited a case where the Department 
of Justice proceeded against an employee that wound up 
declining the employer�s offer. DAEOgram DO-02-003.

To communicate rejection, employees are supposed to say 
something along the lines of "all my time and attention right 
now are devoted to my government job, and I am not in a 
position to discuss employment," or "I am not really planning 
on leaving government in the near future but I will keep you 
in mind in case I ever change my mind," said OGE.   

2. Guidance Covers Waivers and How to Recuse Quietly
The guidance allowed that even though agencies have 
"legitimate interests in regulating the flow of work among 
its employees and preventing situations that could result 
in actual or apparent conflicts of interest," recusal from 
taking part in a matter in which a prospective employer has 
a financial stake could alert a supervisor to a job search 
prematurely, which OGE said is addressed in 5 C.F.R. 2635.604B.

It said that under that provision, upon becoming aware of the 
need to recuse, an employee should notify the person responsible 
for his assignment, and if the employee is responsible for 
their own assignment, the employee "should take whatever steps 
are necessary to ensure that he does not participate in the 
matter" -- though it added that the provisions "fall short of 
a mandatory notification duty."
 
An employee can be granted a waiver permitting involvement in 
a particular matter affecting a prospective employer "if the 
employment contacts have already reached the stage of 
bilateral negotiations or have resulted in an arrangement 
for prospective employment."

The official responsible for an employee's appointment may 
grant a waiver of the recusal requirement if he makes a 
certain written determination in advance of the employee's 
participation in the matter, according to the guidance. 

It said that the standard for making that determination is 
that the affected financial interest "is not so substantial 
as to be deemed likely to affect the integrity of the 
employee's services," and emphasized that the deciding 
official should weigh both the financial interests of the 
employee as well as that of the prospective employer.

Brand New Federal Employees Legal Survival Guide Just 
Published New Publication Announcement: The Federal Employees 
Legal Survival Guide http://www.fedweek.com/pub/index.php  
Passman & Kaplan announces the October 2004 publication of 
the SECOND EDITION of the Federal Employees Legal Survival 
Guide. This comprehensive book, first published by Passman 
& Kaplan in 1999, has been called the definitive how-to 
guide for enforcing the rights of federal employees. 

The second edition of the Guide includes 100 PAGES OF 
ADDITIONAL NEW MATERIAL (now 616 total pages) and useful 
advice. New features include information on internet 
legal research, preparing for and conducting a hearing, 
sample discovery requests, and up-to-date contact 
information for federal personnel agencies. The Guide 
also includes a listing of frequently used civil service 
acronyms and practical appendices of sample forms, 
charts illustrating appeal rights, and commonly-needed 
deadlines. 

As with the first edition of the Guide, Passman & Kaplan 
has attempted to move away from the "legalese" which so 
often complicates an already-bewildering array of 
regulations and policies. Although the Federal Employees 
Legal Survival Guide, Second Edition is clearly an 
invaluable resource for practioners, Passman & Kaplan has 
maintained its commitment to target the book to the 
average federal employee. 

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your secure order online. The cost of this 
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a 616 page reference that is chalked full of invaluable 
information that every federal manager must have!

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FEDweek, PO Box 5519, Glen Allen, VA 23058.

This is a one of a kind book you can't afford to be without!
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