The Army has warned its civilian employees that obtaining or even seeking outside employment while furloughed could trigger ethical considerations that would require approval from management and potentially affect their regular jobs.


The guidance, posted online Friday, comes as the Army along with the rest of the Defense Department prepares to furlough most employees for 11 days over three months starting the week of July 8, and as employees face the resulting loss of income.

“Army employees should be mindful that they remain subject to the ‘normal’ ethics rules (e.g., Joint Ethics Regulation), when furloughed,” the guidance says.

For example, it says, “Once an employee starts to seek outside employment, the employee is disqualified from personally and substantially participating in a particular matter that will have a direct and predictable effect on the financial interests of a current or prospective employer.”

Similarly, it says employees must notify management within three days of starting negotiations for outside employment with certain companies. “If the employee’s duties could have a direct and predictable effect on the financial interests of a prospective employer, the employee must file a written disqualification statement with his ethics office, and a copy provided to the employee’s supervisor,” the guidance says.

“Bottom line: If DoD personnel are considering an opportunity to serve in an outside position in their personal capacities, whether the position is compensated or uncompensated, they should immediately disqualify themselves from participating in DoD matters that could affect their prospective employer to avoid a conflict of interest,” it says.

The Office of Government Ethics and the Office of Personnel Management have sent similar warnings, saying that ethical restrictions continue to apply because furloughed workers remain federal employees; they are placed in a status akin to other forms of leave without pay such as parental leave.