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B-103987 1 (1979-10-29)

handle is hein.gao/gaobabjpf0001 and id is 1 raw text is: -- :UNITED STATES GENERAL ACCOUNTING OFFICE WASHINGTON, D.C. 20548 IN EP B-03987 REFER TO:. OFFICE OF GENERAL COUNSEL October 29, 1979 Richard K. Berg A&- Administrative Con ferenceA &c0059 of the United States 2120 L Street, N. W., Suite 500 Washington, D. C. 20037 Dear Mr. Berg: This is in response to your September 20, 1979, letter requesting our comments on the ecommendations contained in .e Appropriate Limits 4 Participation in Matters Before an Agency by a Former Agency Official a report prepared by Professor Thomas D. Morgan of the University of Illinois.-4D Professor Morgan does a commendable job in presenting a balanced report and pulling together the many diverse issues surrounding post-Federal employment activities. His recog- nition of the possible need to rethink Government policy as it relates to post-Federal employment is well taken. One very relevant question that Professor Morgan's report brings into focus is whether the Government's policy on post-Federal employment should be based largely on a criminal statute. In our report What Rules Should Apply to Post-Federal Employment and How Should They Be Enforced? FPCD-78-38, August 28, 1978, we recognized--as does Professor Morgan-- ,thatLhe Government's policy must establis a. proper balance between the need to protect the public from officials with conflicting interests and the need to hire and retain the most qualified persons for Government service. We pointed out, however, the need to develop basic information through which the many issues surrounding post-Federal employment can be evaluated. We suggested, among other things, that the Office of Government Ethics either monitor or establish an agenqy-implemented monitoring system to study post-Federal employment and define its characteristics and parameters. To date we can report that this work still needs to be done. In our view the basic problem in this area is that the Government is confronted with a lack of information on which it can make meaningful judgments concerning the need for or

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