Federal Manager's Daily Report

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Fourteen major defense contractors employed some 37,000 people in 2019 who had left DoD civilian employment or the military over the prior five years, including some 1,700 who had been in senior civilian or military positions or in acquisition positions making them subject to certain post-employment restrictions, GAO has said.

The report, ordered by Congress in the 2020 defense budget, is the latest look at the revolving door issue that has been a point of concern for many years regarding the relationship between DoD and its contractors. A series of laws and policies—some of which provide for criminal penalties against the individual and/or the company for violations—limits “the types of activities that could appear to be government-based relationships being used for private ends—i.e., conflicts of interest—such as former DoD officials using their DoD contacts to benefit a contractor to the detriment of the government,” GAO noted.


GAO noted that since a similar report in 2008 it found more than 400 persons could have been working on defense contracts under the responsibility of their former agency, office, or command and that some contractors were unable to identify all the former DoD officials they employed who were potentially subject to those restrictions.

Since then, DoD “has improved certain practices to help ensure compliance with post-government employment restrictions,” including more training of employees regarding those restrictions and better record-keeping regarding those who may be subject to them. Further, DoD has required that when submitting proposals in response to contract solicitations, contractors must represent their employees’ compliance with those restrictions, it said.

But it said that DoD has not incorporated into its rules a 2020 restriction on lobbying-type activities and “may be missing an opportunity to create a shared sense of accountability between the employees and the contractors who hire them, and a means of ensuring that DoD does not do business with companies whose employees violate the lobbying restriction with their employers’ knowledge.”

From the contractor side, GAO found that those involved in developing and producing weapon systems “reported having more practices in place to promote compliance” with the restrictions than did contractors that generally provide commercial products and services. It also found that the contractors under-counted the number of their employees potentially subject to the restrictions, largely due to limits in their personnel records systems.

The report said the department agreed with a recommendation to update its rules to include the change regarding lobbying.

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