It has long been seen as an ideal job transition – work a few or a dozen years in government service and then move into a higher salary, and perhaps more flexible position as a defense contractor. Some defense department officials, however, are asking for better disclosures on which former government employees are now working for major defense contractors.

In a proposal by the Defense Department, companies would be required to submit details about former federal officials that ensure they are in compliance with post-employment restrictions, before being awarded a contract, according to a June 6 Federal Register notice.

Current post employment restrictions include how a former government official can represent a contractor who works with the official’s former agency. For instance, former government personnel are permanently barred from representing their new employer when working with their former government agencies in matters that they are “personally and substantially involved.” Companies must also be aware of the Procurement Integrity Act, which limits how former officials can influence an agency as a contractor after working there on a large federal contract.

The new proposal states that contracting companies should be required to include a statement of compliance when bidding on government contracts. If they aren’t in compliance they wouldn’t be allowed to submit an offer.

The proposal was created in part because of a 2008 Government Accountability Office investigation on post-employment concerns. The investigation found that contractors underreported the employment of former DOD officials. Contractors reported they employed 1,263 former DOD officials in 2006, while Internal Revenue Service data showed the contractors employed 2,435. Also, the GAO said that defense contractors might employ a substantial number of former defense officials on assignments related to their former positions.

According to the GAO, the DoD does not have a procedure for monitoring former senior officials and acquisition officials who work with defense contractors. The DoD does provide written ethics opinions to senior and acquisition officials who request them, but this only provides limited transparency, the GAO said. However, the DoD is in the process of implementing a single database for collecting and retaining this information.

Regulators are accepting comments through Aug. 5.



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Chandler Harris is a freelance business and technology writer located in Silicon Valley. He has written for numerous publications including Entrepreneur, InformationWeek, San Jose Magazine, Government Technology, Public CIO,, U.S. Banker, Digital Communities Magazine, Converge Magazine, Surfer's Journal, Adventure Sports Magazine,, and the San Jose Business Journal. Chandler is also engaged in helping companies further their content marketing needs through content strategy, optimization and creation, as well as blogging and social media platforms. When he's not writing, Chandler enjoys his beach haunt of Santa Cruz where he rides roller coasters with his son, surfs and bikes across mountain ranges.