The OGE’s new guidance on ethics considerations related to government shutdowns—in more detail than previously available, although not issued until after the shutdown ended—says that while outside employment often is allowable, it should be approached with caution.

“Outside employment is unlikely to conflict with an employee’s official duties unless the outside employer is an organization with which the employee is likely to interact or otherwise affect in the course of the employee’s government duties. Be aware that many agencies have specific regulations or statutes relating to outside employment, including, in some cases, prior approval requirements,” it says.


Further, employees are prohibited from representing outside parties before the federal government and from using their federal government title or position to benefit a non-federal employer, it says.

Employees who took outside employment during the shutdown should consult with their agency ethics officials to determine whether that work “would require them not to work on matters involving their former employer for a period of one year. If an employee is going to continue outside employment after returning to federal service, it is vital that the employee meet with an ethics official to ensure that the outside employment does not create a conflicting interest with the employee’s federal duties,” it says.

In addition, those required to file financial disclosure forms must report any income they earned from outside employment.