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What ethics issues arise in connection with employee assignments under the Intergovernmental Personnel Act?

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What ethics issues arise in connection with employee assignments under the Intergovernmental Personnel Act?

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The Intergovernmental Personnel Act (IPA), 5 U.S.C. §§ 3371-3376, authorizes the temporary assignment of a federal employee a non-federal entity, and vice versa, to do work of mutual concern. The non-federal entity might be a state, local or tribal government, or a public university. A federal employee who works for a non-federal entity under the IPA remains a federal employee and therefore continues to be subject to federal ethics requirements. A non-federal employee who is appointed to a federal agency is considered a federal employee for most purposes. One who is detailed to a federal agency, while not considered a federal employee, is subject to the federal ethics rules and regulations while working for the federal agency. This OGE memorandum serves as a reminder of the kinds of ethics issues that can arise in connection with IPA assignments. The representational restrictions of 18 U.S.C. §§ 203 and 205 can limit the permissible activities of a non-federal employee detailed to a fe

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