While other federal officials are hunkering down as the spotlight shines on federal contracts in agency after agency, Action is taking the opportunity to do a little bragging.
"We have a whole different way of doing business at our little agency that is a hope for the rest of government," says Don Green, an official with the federal volunteer agency.
Green and Sam Brown, Action's director, think they have a handle on the corruption problem with a set of self-imposed rules and an innovative way of enforcing them.
Though the $100 million Action spends on outside contracts and grants is peanuts compared to the $9.5 billion spent on consultants by the Department of Energy alone, Action official tackle possible conflicts of interest head-on and with occasional self-mockery.
"We might be more venal if we had more money," says one Action higher-up.
Brown, though, discusses Action's purposes in a more solemn tone. "Public service is a privilege and ought not to be something which people see as a track to make a buck, but as a chance to serve the public," he says.
Action started its program three years ago when Brown found his agency mentioned in a gossip column, the location of advance reviews for many a scandal. The columnist intimated that Action was -- horror of horrors -- enmeshed in a conflict of interest.
Brown decided to look at the federal standards of conduct in force since 1965, when President Lyndon B. Johnson issued them. He says he found the regulations, which are supposed to be to bureaucrats what the Bible is to Christians, "lax and unenforceable."
The Administrative Procedures Act of 1946, an operating guide for federal agencies, allows agencies to adopt their own standards of conduct if they do not conflict with the federal standards, so Brown set up a task force to tighten Action's regulations.
The task force's goal was to clear up the relationship between Action employes and organizations that either had or were seeking Action grants or contracts. These are some of the regulations it drew up:
A provision to prohibit an employee from participating in a decision to award a contract or grant to an organization with which he or she has been associated. This is meant to provide a "cooling off" time for a person who has just joined the government.
A provision to prohibit an employe from associating with an organization that either has or is applying for a contract or grant with the agency. Action defines the words "associated with" to include being an executive or having a financial interest in such an organization.
The phrase also includes marriage. Last year, an employe's husband tried to get a contract with Action. The agency gave him a choice: the contract or his wife. He chose his wife, they say.
A provision to prohibit an employe -- for one year after leaving the agency -- from working for an organization with an Action contract or grant in the area he or she worked on while with the agency. This regulation is directed at the "revolving door" phenomenon.
The task force also set up a new procedure designed to prevent conflicts of interest from developing:
Every new Action employe files a disclosure statement listing the employers, financial institutions and other organizations he or she has been associated with in the two previous years. All those organizations are entered in a computer, with the employe's number.
Then, when an organization applies for a contract, its identity is automatically checked against the computer list. If it catches up with an employe and there appears to be a conflict, the application is flagged and the general counsel's office notified.
The general counsel then makes a recommendation about whether there is a conflict. If the employe involved objects, the general counsel calls a meeting of Action's Committee on Conflicts of Interest, composed of eight top agency officials.
Since the regulations went into effect in October 1978, the committee has met 11 times, considered 16 cases and found seven conflicts.
Director Brown believes that the procedure will help restore public confidence in government. It's not just public relations, he said. "It's a question of how people see, and feel about our common endeavor."
Right now, general public confidence in the governmental regarding the endeavor of hiring consultants does not appear to be high.
Action, on its small scale, is trying to change that.