Framework for Assessing Job Vulnerability to Ethical Problems

There is growing concern in Congress and elsewhere over the amount of Government money lost each year through fraud and abuse by Federal employees. GAO developed a framework in which a job's particular vulnerability to ethical or conflict-of-interest problems could be assessed. The framework was based on a group of factors which agencies could use to assess the strengths and weaknesses of their program for promoting the ethical conduct of their employees. GAO tried to determine what factors contributed to problems of ethical conduct within a job. These factors could be used in developing specific standards in identifying those vulnerable aspects of a job which could be modified or eliminated. The factors could also alert agencies to areas needing increased inspection or audit coverage.

GAO believes that most federal employees will abide by established standards of ethics if agencies: (1) apply standards consistently and equitably when questionable conduct is identified; (2) address situations which are meaningful to employees; and (3) keep employees aware of expected behavior. Agencies need to develop programs that aggressively implement standards of employee conduct and actively promote ethical behavior. The establishment of the Office of Government Ethics and the issuance of regulations by the Office have provided agencies with the foundation for a standards of conduct program. Agencies need to consider the impact of all facets of an agency on ethical behavior: its organization, the ways its jobs are structured, and its management philosophy. By considering all of these facets, an agency can identify areas of potential weakness and can take action to strengthen its program for promoting ethical behavior on the part of its employees. Although the framework which GAO used may not be developed to a point at which it can be used universally to determine the degree of vulnerability inherent in particular jobs, the use of a list of factors such as the one which GAO developed can be beneficial. Those who review and monitor agency functions should be aware of the factors which GAO identified and their potential impact on the ethical conduct of employees. These factors can help improve an agency's ethics program and alert managers to the need for additional oversight and guidance.