This really is interesting. It has kept me checking back amongst changing oil and such drab chores.

Vern brings up an interesting point about not having to be a contracting officer where the action does not involve appropriated funds. Brian noted limitations on agencies attempting to "augment their appropriations from outside sources." The latter clearly gets to the Constitutional question involved in Iran-Contra. The Constitution does not envision an Executive exercising "Entrepreneurial Government" to the point of exempting itself from the Legislative branch's power of the purse.

For really interesting discussion try this:

Instead of working for a SYSCOM the boss in question works for an Executive medical organization, say Navy. The free service offered is from an abortion clinic. Congress has said no funds can be spent on such services, but he is not involving appropriations. He wants to do this and has our questioner at the task of getting the service some of the commands clients are demanding, thus better serving the customer.

Explosive? You bet. No matter where one stands on the subject matter the Constitutional issue has to be an issue. I'm sure the actual issue is a little sparkler in comparison and perhaps not even combustible, but where does the line get crossed? Maybe the boss only wants to get a head start on something he and others think is needed, only Congress keeps killing funding for the system (just a small "bang") or maybe it is just to get some more heads on a fully approved system with some more thinking caps needed (not a "pop"). I'd guess there is a very fuzzy line, but one with some neat minefields.

By Vern Edwards on Tuesday, May 9, 2000 - 12:28 pm:

All:

Interesting discussion. At the risk of coming across as irresponsible, I will repeat that unless there is something dubious about what trayerd wants to do, or something that creates an appearance of impropriety, I would get it done in a heartbeat and move on.

Yes, yes -- I would talk to a lawyer.

By the way -- unless it somehow involves the obligation of appropriated funds, you don't have to be a contracting officer to accept free services for an agency, and the FAR does not apply. It may be that trayerd's boss may have come to him to take advantage of his business acumen. Maybe trayerd's boss should have just gone straight to the lawyers, instead. Of course, that would have deprived trayerd of the opportunity to show what he can do.

Vern

By Eric Ottinger on Tuesday, May 9, 2000 - 11:50 am:

A few afterthoughts.

If anybody is really expert in the kind of creative, partnership with industry, contracting that TR has in mind, it is probably DARPA. TR may want to call them up and get the benefit of their experience.

Also, it strikes me that contractors must borrow back our combat aircraft on occasion for testing or R&D. That might be a useful precedent.

It is obvious that I had Brian’s excellent article in the back of my mind somewhere. If I had read it more carefully, I might have remembered more of it.

Under the same category of half-remembered information, I remember reading somewhere that the law has been changed since the WWII “Dollar a Year” contracts. It is an interesting precedent, but I am not sure that you could do the same thing today. This would be another question for GC. (This would not rule out some combination of nominal $ consideration and barter.)

Eric

By Ramon Jackson on Monday, May 8, 2000 - 11:49 pm:

For the record, I do think there is a place for this type exchange, particularly when done openly and with care. An example I know of dealt with corporate internal research and development that could be provided and even modified if it looked promising to government. It was not going to be published as it was indeed revealing of corporate directions, including purely commercial ventures. It needed contract structure for several other reasons.

After bouncing this off OGC and ethics a few questions had to be resolved, no "gift" for one, and the exchange defined. I believe the exchange was similar access to some government development information and one of the conditions was that this arrangement had to be available to other companies and not a appear to favor the one. If I recall it worked out reasonably well, though no huge success stories were generated.

Since this "service" was really just a structured sharing of knowledge there was no real question about illegal augmentation of appropriation which is a real issue for substantial services.

By Ramon Jackson on Monday, May 8, 2000 - 11:28 pm:

One of the common causes of problems appears to be the hard charging executive who wants something that may be perfectly legitimate and wants it their way. The want may be legitimate but the "way" is questionable. They hand it off to someone to "make it happen."

One person salutes, draws saber and charges right over the hill into the pit (or maybe stripes). Some of that seemed to be going on here.

Another person may become convinced that the way is wrong and with it the objective. They then dig in and become "No" people -- something contracting people had something of a reputation for.

What I would call a sensible person looks at the objective and decides we can't get there from here in the desired way, but there is another way to get the objective or equivalent by a legitimate way.

Unfortunately this too often runs counter to the originator's ego and havoc reigns. In the government world this is when the MFRs begin filling volumes and programs become bogged in ego battles and not problem solving.

It is another reason why I still hold to my widely dismissed view in this forum that public sector contracting needs real checks and balances. The threatening ego, when faced with another power that can truly say "No" with force has been known to sit down and work the problem instead of just demanding "make it happen." I've seen exactly that work to the benefit of all and an improved solution -- one that survived the reason test rather than a hard driven want. If a corporate officer wants to place his company at risk over ego, so be it, but not so for the nation. The taxpayer deserves and demands more than ego contests.

By the way Eric, it appears the bulk of our filled jails are in for nonviolent drug offenses. Not to say a gram of crack should go unpunished, but I find it exceedingly odd that years can be lost to that while someone scamming the taxpayers or the elderly (sometimes leaving absolute desperate times at the end of life) gets a little reprimand or a few months in one of those limited departure spas we run. To be blunt, I'd rather see the one stealing millions by betrayal of trust do the real time. What we have now seems too often a bit like war against Franco's Spain while Hitler's Germany suffers a few trade sanctions.

By Brian Fisher on Monday, May 8, 2000 - 10:37 pm:

Vern,

As a quick side note, lets assume solely for the purposes of this discussion that voluntary services and gifts of personal property are constitutional. As Herb Fenster and I noted last year in Contract Management magazine, augmenting appropriations sometimes runs afoul of both the Constitution and basic fiscal law.

Lets also assume that acceptance of such gifts does not give the appearance of impropriety, and does not create any conflicts with CICA (both of these issues are complex, and would require substantial research).

That being said -- and without digging the Red Book out again -- the "gift" cases and statutes that I have seen tended to focus on the donation of money, real property, or personal property. I have not seen many cases dealing with voluntary services.

As with gifts of money or goods, the ability of a department or agency to accept voluntary services hinges upon the authority provided in the applicable gift-acceptance statute. If a statute does not authorize a department or agency to accept the donated goods or services, it cannot accept such donations.

For example, Congress specifically authorized DoD to "accept from any person, foreign government, or international organization any contribution of money or real or personal property." See 10 U.S.C. §2608(a).

In that same statute, however, Congress expressly limited DoD's ability to accept only those voluntary services provided by foreign governments or international organizations (i.e., not by "any person"). Stated differently, Congress did not authorize DoD in this statute to accept voluntary services from any person -- which presumably, would preclude a government contractor, U.S. citizen, and others that do not fall within the definitions of "foreign government" or "international organization" from donating services. [note; another statute might authorize DoD to accept services. Therefore, COs should consult the statutes or their OGC.]

Unlike the limitations placed on DoD, Congress authorized NASA "to accept unconditional gifts or donations of services, money, or property, real or personal, or mixed, tangible, or intangible." See 42 U.S.C. § 2473. Note the difference between the DoD and the NASA statutes: NASA is silent as to who might provide the services, while DoD identifies specific parties. Therefore, assuming that other statutes do not limit this grant of expansive authority, NASA might accept voluntary services from anybody.

On a final note, Eric stated in another thread that lawyers would willingly work until 2:00 AM. So as to not prove him correct, I am going home. Have a nice evening.

Brian

By Eric Ottinger on Monday, May 8, 2000 - 10:06 pm:

Vern,

I don't know whether TR was selected for this mission because he is the kind of bright, hard-charging young contract specialist who will get the job done, or because older, more cautious heads don't want to be in the vicinity when the boobietraps go off.

Either way he wants to get GC and higher management involved. In the first instance it is a question of prudent office politics. In the second instance, it might be a question of bureaucratic survival.

This might be a great idea, but it needs some careful thought.

Thanks to everyone who has done real research (especially Brian) while I have been pontificating.

Eric

By Vern Edwards on Monday, May 8, 2000 - 07:45 pm:

Brian:

It appears that the statutes and the GAO decisions distinguish between "gifts" and services. It appears that gifts are personal and real property. Is that your impression?

Vern

By Brian Fisher on Monday, May 8, 2000 - 07:02 pm:

Some general thoughts:

The Government as a whole may accept gifts, which are treated as miscellaneous receipts and should be deposited into the Treasury. See United States v. Burnison, 339 U.S. 87, 90 (1950).

The Comptroller General has defined the term "gifts" as "gratuitous conveyances or transfers of ownership in property without any consideration." B-217909, Sept. 22, 1986; 25 Comp. Gen. 637, 639 (1946). While gifts to the United States as a whole do not require specific statutory authority, the GAO has concluded that the statutes prohibit individual federal agencies from accepting for their own use gifts of money or property, or to augment their appropriations from outside sources, absent specific statutory authority. See, e.g., The Red Book at 6-103; B-277521, July 31, 1997; 60 Comp. Gen. 456 (1981); 16 Comp. Gen. 911, 912 (1937).

A number of agencies, including the deptartments of Agriculture, Commerce, Education, Labor, Treasury, VA, GSA, DoD, NASA, and the USPS, possess statutory authority to accept, retain, and utilize donations. Each agency’s statutory authority is unique as to who or what may accept donations, for what purpose, and under what circumstances.

Each agency with such authority implements its own policies and practices concerning the acceptance of gifts. The common thread appears to be the recognition that the agency should assess the propriety of accepting each gift.
A gift must be given gratuitously, with no quid pro quo. Thus any implication that a “gift” to an agency in fact is in return for something is a basis to argue that acceptance is an illegal augmentation of appropriations, because the gift statute does not authorize its acceptance. It is this factor which underlies many of the policy-level considerations.

For example, Air Force Instruction 51-601 states that gifts can be accepted unless they “clearly would not be in the best interests of the Air Force,” which includes gifts that “would raise a serious question of impropriety in light of the donor's present or prospective business relationships with the Department of the Air Force."

Similarly, the DoI Guidelines state that DoI agencies should not accept donations from persons and entities who “have litigation pending with, or have or are seeking to obtain a contract, lease, grant or other business, benefit or assistance from the agency that would receive the donation.” Likewise, DoI agencies and employees should not accept donations from persons or entities “who appear to be offering a gift with the expectation of obtaining advantage or preference in dealing with the Department or any of its agencies.” DoI even provides an example: “JKL Construction has submitted a bid to the [BIA] to construct a school on an Indian reservation. While this matter is pending, BIA may not accept . . . donations from JKL Construction.” DoI Guidelines at D.4.

Also, DoC’s DAO 203-9 § 6.01 states that a gift or bequest may be accepted by an authorized official only if the donation would "(a) aid or facilitate some part or aspect of the work . . . (b) constitute a bona fide gift . . . rather than a payment in exchange for goods or services; e.g., the donor has not implied or requested some particular Department action in return; or (c) not cause a reasonable person with knowledge of the facts . . . to question the integrity of the agency programs or operations.” In making this determination, an authorized official shall consider, among other elements, “the nature and sensitivity of any matter pending at the Department affecting the interests of the donor.”

Suffice it to say that the statutes, regulations, and case law provide sufficient "wiggle room" for creative contracting officers to obtain what they want/need. However, were it ME obtaing the gift on behalf of the taxpayer, I would discuss the idea and vet it fully, especially with the agency OGC.

Just my two cents.

By Vern Edwards on Monday, May 8, 2000 - 03:13 pm:

Ron:

It's hard to assess the problem before us, because treyerd didn't give us any details. But frankly, unless this were something really dubious, if I were the CO I would get it done in a heartbeat.

Vern

By Vern Edwards on Monday, May 8, 2000 - 03:07 pm:

Eric:

If the contractor is going to get something, so that the services are not truly gratuitous, then trayerd can use my first approach and negotiate a contract that provides other than monetary consideration.

I think you've made your point that you think trayerd should talk to a lawyer. Maybe everybody in America should just become lawyers.

trayerd -- talk to a lawyer!

By Eric Ottinger on Monday, May 8, 2000 - 02:56 pm:

Vern,

If I understand this correctly, the contractor does want to get a benefit out of this deal: the use of the Government facilities. If the contractor breaks something big or pollutes something, there will be a considerable problem.

TR shouldn't worry about going to jail, but he should get knowledgeable, experienced help to do this right and to keep him out of trouble.

Eric

By Ron Vogt on Monday, May 8, 2000 - 02:48 pm:

The "voluntary" vs "gratuitous" distinction is interesting. I wonder how common a practice it is to accept gratuitous services?
I did a quick search for cases citing 31 USC 1342, and came up with nothing relevant. Maybe the "gratuitous" distinction makes this less of an issue than originally thought. Granted, there are problems, but it no longer looks to be outright illegal.

By Vern Edwards on Monday, May 8, 2000 - 02:21 pm:

I've made an interesting discovery: The GAO makes a distinction between "voluntary" and "gratuitous" services. It says that agencies may not accept voluntary services, but that it may accept gratuitous services. It says that 31 U.S.C. § 1342 "covers any type of service which has the effect of creating a legal or moral obligation to pay the person rendering the service," and cites decisions in which it allowed an agency to accept free services "as long as the services were agreed in advance, and so documented, as gratuitous."

See the GAO Redbook, pp. 6-65 thru 6-69.

Go to it, trayerd.

By Eric Ottinger on Monday, May 8, 2000 - 02:20 pm:

Thanks Vern,

Ron,

It was my thought that TR doesn't really have to worry about wearing stripes. Fortunately for us, U.S. Attorneys and the correctional system are already booked up with violent felons, drug dealers and such. It is much more likely that TR will find that he has suddenly limited his career options. He may have to choose between parking cars and flipping burgers. Or he might be a career GS-5. “Do it because the boss wants to do it,” isn’t the best advice. If the boss knows what he is doing, the boss should have some idea how to do it.

In any case, TR should get GC and higher management on board before the proverbial hits the rotating blades, not afterward.

Vern provided a relevant cite, but I could think of at least a half dozen other issues that ought to get attention from General Counsel.

On the whole, I like contractors; but, I don’t confuse them with charitable institutions. The phrase, “Something for nothing” would normally tend to make me nervous and motivate me to ask what is really going on.

However, this is beginning to sound like legitimate sort of barter, where the contractor gets to use some (presumably underutilized) facilities and the Government gets the fruits of the contractor’s efforts.

On the other hand, intellectual property rights go to the Government if the Government provides funding. TR’s higher management and the contractor may be looking for a way to get around these rules. If so, TR should do what is fair, but be careful not to give away the farm.

Eric

Ron:

Correction to my last message: the GAO says that agencies may not accept gifts without statutory authorization.

By Vern Edwards on Monday, May 8, 2000 - 01:59 pm:

Ron:

31 U.S.C. § 1342, Limitation on voluntary services, says:

"An officer or employee of the United States Government or of the District of Columbia government may not accept voluntary services for either government or employ personal services exceeding that authorized by law except for emergencies involving the safety of human life or the protection of property. This section does not apply to a corporation getting amounts to make loans (except paid in capital amounts) without legal liability of the United States Government. As used in this section, the term 'emergencies involving the safety of human life or the protection of property' does not include ongoing, regular functions of government the suspension of which would not imminently threaten the safety of human life or the protection of property."

31 U.S.C. § 1350 says:

"An officer or employee of the United States Government or of the District of Columbia government knowingly and willfully violating section 1341(a) or 1342 of this title shall be fined not more than $5,000, imprisoned for not more than 2 years, or both."

In Principles of Federal Appropriations Law, 2nd ed., Chapter 6, p. 6-141, the GAO calls the acceptance of a gift an "improper augmentation" of an appropriation and says that agencies may accept gifts without statutory authority. The GAO defines gifts as "gratuitous conveyances or transfers of ownership in property without any consideration." The GAO has written a number of advisory opinions about the acceptance of gifts.

By Ron Vogt on Monday, May 8, 2000 - 01:45 pm:

Several writers have claimed that the acceptance of free services violates some statute, regulation or rule, although I have yet to see a cite. Similarly, several people have claimed various ethical hurdles, even criminal violations, without providing specifics.
The boss in this case will not be satisfied with "you can't do it." He (and I) will want to see the statute or rule being violated, the ethical problem being created. I don't mean to claim that there is no problem with this situation, because I have never had to look into it. However, to further my education, I want to know exactly what would be wrong with this. Is there a statutory prohibition against receiving voluntary services? Does it violate the prohibition against receiving gifts or gratuities (which I thought applied to government employees, not the government itself).
Admittedly, the contractor is probably looking ahead to the next competition and trying to gain favor. Is that alone enough to create the ethical problem?
I hope that there isn't an easy answer so that I just embarassed myself by not knowing it. Nevertheless, the writers seem to be groping at some vague idea that this is wrong, without being able to say exactly why. If there isn't a prohibition, then the answer would seem to be to structure this in a way that future competitions involving this contractor won't be influenced.

By Vern Edwards on Monday, May 8, 2000 - 01:18 pm:

trayerd:

One other thing: Consideration need not take the form of money payment. If you are evaluationg a process or technology, the contractor will enjoy the benefits of your work. Document the file to explain what you are doing and why, e.g., accepting the service to evaluate a process, or technology, and state in the contract what non-monetary benefits the contractor will receive from your part of the bargain in consideration.

By Eric Ottinger on Monday, May 8, 2000 - 12:59 pm:

TR,

Following up on Vern's thought-- What you have in mind sounds more like barter than something for nothing.

Some combination of barter and nominal monetary consideration might be the way to go. In any case, I wouldn't be afraid of GC. You need to get them involved.

Eric

By Vern Edwards on Monday, May 8, 2000 - 12:45 pm:

trayerd:

In answer to your question: Give the firm a contract with a price of one dollar ($1.00) or some other nominal sum. It is legal and was done extensively during WWII to hire the so-called "Dollar-a-Year" men who volunteered their services as managers for the War Production Board.

Write a complete government contract, including all clauses that apply to a $1.00 contract.

As you can see from the responses that you have received, people are suspicious of freebies, and understandably so -- those darned Greeks! I assume that you and your boss are smarter than the Trojans. In any event, there may be many legitimate business reasons that a firm would do something without charge.

Make sure that you have a good reason for what you are doing and document your file. I assume that nothing underhanded is going on between you or your boss and the contractor. Write a memo to file explaining what you're doing and why and why the firm is willing to do it for one dollar. One explanation might be to test a new technology.

The prohibition against voluntary services is in 31 U.S.C. § 1342.

By Eric Ottinger on Monday, May 8, 2000 - 12:20 pm:

All,

Interesting discussion.

TR,

When I suggested that you talk to the ethics expert in your GC office, it was my thought that he/she would be the person with the best knowledge of the relevant statutes (i.e. the statutes regarding voluntary services which JD mentioned).

I didn't mean to suggest that you have an ethics issue. It's up to the person who signs the contract to give it the smell test. Unless I had all of the facts, I wouldn't jump to any conclusion one way or another.

Assuming that you are really doing something really creative and interesting, you want to get your legal counsel involved from the outset as a key member of the team strategizing this contract.

Good Luck,

Eric

Ramon, You are right but the principle is the same. I was referring to the safety of the PCO's position and not the ethics of the situation.

Ethical dilemmas are not "solved" by vetting or by following selective interpretations of the rules. If both the government and the contractor (with or without the contracting function knowing) provide something for nothing, or something for much less than cost, the undue influence has ocurred. The "reason" you cite for the rules against free gifts are the same for "discounted" gifts - ": undue pressure from government and attempts to create hidden and detrimental obligations from the private sector."

I was not referring to mistakes, unforseen events, renegotiation of contract terms etc. I was referring, using your words, to "(possible extortion like behavior?) and a... (circumvention of open competition by a hidden "cost" in the form of gaining knowledge and a lock on future work)."

Take the Lockheed award of the avionics mods to the C-5, way under cost. Lockheed was forced to bid within existing funding ceilings to allow fast obligation and to make it a fait accompli. Sole source with "available" funds resulted in charges from Congress of misappropriation of funds and hair splitting denials by AF officials. Following that, the under the table agreements with Congress and the Administration to fund a C-5 re-engineing and reliability improvement program which is essentially "in the bag" for LM with a wink and smile between LM and USAF! No one will object because of retribution for a Boeing or Raytheon complaint or for that matter any contractors of lesser size. Why no complaint? because of high level "approvals" and then the Armed Services Congressional staffs and members from Lockheed locations who will ride herd on any wayward complainers from lesser Committees like Appropriations, Government Reform, Small business or any naysayers.

In this situation a PCO is invulnerable in any decision, even if GAO or DoD IG have them dead to rights, because higher authority will be blamed. (Actually if you were to ask Generals Butchko and Nauseef of the C-17 SPO they would disagree since those that ordered the "bailout" of MacDonnell Douglas on the C-17 are still around after the military guys took the fall. But no PCOs lost their warrants!)

My contention is that as the degree of political involvement goes up the relative danger to the CO goes down! Conversely a small potatoes contract will land squarely on the CO's shoulders so be careful and avoid exposure - from one who has been out on a limb and didn't notice the termites!

By Ramon Jackson on Sunday, May 7, 2000 - 12:01 pm:

No Luigi, there is a difference. Underbidding, whether intentional or poor estimating, and "getting well" with changes or other mechanisms is not just the same. In some cases it may be no more than poor management on both sides and in some it may be relatively innocent. However, there are specific rules about government accepting free labor from either individuals or companies and with good reason: undue pressure from government and attempts to create hidden and detrimental obligations from the private sector.

Within the rules such exchanges can be beneficial and not raise ethical questions. The context of this one definitely raises questions for me: a supervisor pushing for "free" labor (possible extortion like behavior?) and a company eager to comply (circumvention of open competition by a hidden "cost" in the form of gaining knowledge and a lock on future work). The indication this is a "sole source" deal is also worrysome. It raises questions precisely about the good reasons the rules exist.

I'd have fewer questions and qualms if CBD carried a notice that interested companies could "provide . . ." in exchange for "access to . . ." within a framework vetted by legal and ethics offices.

The Air Force is doing exacly this sort of thing in accepting a low bid in order to get a contractor on contract; and then the contractor "makes up" on the follow on. The difference I expect is that the contract is huge, it has politicians behind it, it is politically blessed to the White House so that is a pretty safe bet for a CO.

If this is a small issue and small contract the potential for going to jail for stealing a loaf of bread is immensely higher than stealing a fire truck! Actal cases at Lake Charles AFB closure in the early 60's!

Run do not walk to the nearest exit!

By Ramon Jackson on Friday, May 5, 2000 - 07:36 pm:

It is fine to seek a way to accomodate an idea. It is fine to hit an initial block and explore alternatives. Saying "Aye, Aye, Sir" to something not legal is not even acceptable in the military. Going too far in "where there's a will, there's a way" is probably the prelude to all sorts of life changing events for people in your situation, Watergate being one.

There may be a way, but there are legitimate barriers to this "freebie" stuff. I for one have some doubts about the ethics of allowing a contractor into a cozy relationship that might taint future competetion (as you indicate) -- to the detriment of your and your boss' employers -- the U. S. taxpayer. On the other hand I do know of some efforts in which intangibles were exchanged after full legal and ethics review and all benefited.

This forum is no place to risk your future. You can't present the full case, those of us replying have no stake in your future freedom and we may just be off track too. I feel sure you are well out of "idea shopping" and into the "need professional guidance" arena already.

Your agency used to be among the best in Navy contracting and even wrote some excellent guidance. Maybe you lost a lot of talent moving west, but there must be some left. Go to your own legal and ethics folks, come clean with all details, work issues and get accurate professional advice for the exact situation. Continue on this path and you may make some IGs day - or perhaps the U.S. Attorney in SD may have more work.

How do you look in stripes?

With all respect, I encourage you to listen to Eric and consult with your servicing counsel. There is a legal prohibition (statutory) on the acceptance of voluntary services (though I couldn't tell you exactly where it is right now). There are exceptions and special permissions, but you need to be sure you're fitting into one of the exceptions before you accept voluntary services. Good luck.

By trayerd on Friday, May 5, 2000 - 02:59 pm:

I recognize that there are probably a bizillion excuses I could use to say, "No boss, can't be done". But I'm from the school that says where there's a will, there's a way. What about a MOA? Or no-cost contract or no-cost assistance agreement? The contractor has presented an unsolicited, no-cost proposal. You mean there's NO way to accept it? The contractor is using this effort as a loss-leader in hopes that it will pay-off later down the road. Isn't that essentially what unsolicited proposals are about....try me out, I'm confident you'll like me?? My biggest concern is the issue of consideration. Is rent-free access to and use of Government facilities and equipment, sufficient consideration for the services rendered?

--- Don

By Ramon Jackson on Thursday, May 4, 2000 - 11:09 pm:

You might also want to find out exactly what "nothing" really means in this readiness on the part of the company. Wariness of large gift horses is prudent entirely aside from a number of ethics and legal issues.

By Eric Ottinger on Thursday, May 4, 2000 - 05:15 pm:

Don,

I think not, unless you are talking about something that is really a charitable contribution like a firm sponsoring an exhibit at the Smithsonian.

There should be some kind of ethics counselor in your General Counsel's office. This person should be able to identify the relevant laws.

Eric

By trayerd on Thursday, May 4, 2000 - 04:16 pm:

I have a boss who wants these particular services, but is not interested in paying for them. Just so happens there's a company ready, willing and able to provide said services.....for nothing. How can I get these services for the boss without him having to pay? Thanks.

--- Don