National Science Foundation

Better Guidance on Employee Book Writing Could Help Avoid Ethics Problems Gao ID: GGD-93-8 October 9, 1992

Two National Science Foundation (NSF) employees coauthored and arranged for the publication of Rush to Policy in 1988 and The Practice of Policy Analysis in 1991. The employees prepared the books, in part, during official work hours, using government secretarial support and computers. Even so, NSF allowed the employees to publish the books as private individuals through commercial publishers. Had NSF determined that the books were being prepared as outside activities, the employees would not have been allowed to use those government resources. Or had NSF determined that the books were being done as part of the employees' official duties, it should have reviewed the content of the books and arranged for their publication according to federal laws and regulations. GAO concludes that NSF ethics officials did not clearly determine whether the book projects were official NSF responsibilities or outside activities. As a result, NSF did not ensure that the books were produced in accordance with federal requirements, thereby exposing the agency and its employees to possible statutory and regulatory violations. NSF needs policies and procedures for systematically advising employees on book-writing and publishing activities relating to NSF's responsibilities.

GAO found that: (1) federal agencies must classify whether the writing and publishing activities of federal employees are official government duties or outside unofficial activities; (2) the two NSF employees who wrote and published two NSF books did so without NSF determining the activities' classification; (3) the two employees used secretarial and computer support services during work hours, and NSF allowed the employees to publish the books privately through commercial publishers; (4) NSF failed to clearly determine the classification and review the manuscripts; (5) NSF lacks formal policies and procedures for reviewing employees' job-related writing and publishing activities, determining the official or unofficial status, or communicating employee publishing guidelines; (6) NSF allows unsupervised independent research, lacks guidelines requiring employees to seek book-writing guidance and agency approval, and fails to determine whether the proposed publication relates to its mission; and (7) other agencies require employees to obtain prior agency approval for writing and information dissemination activities, require agency determinations distinguishing between official and unofficial duties, require agencies to determine whether a government or private publisher should be used, and require policy determinations regarding employee or publisher copyrights and employee compensation.

Recommendations

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