Investigation of a National Historic Landmarks Official for Potential Conflict of Interest

OIG investigated allegations that an official with the National Historic Landmarks Program (NHL) of the National Park Service (NPS) may have pressured an NPS partner organization to award a contract to a former intern who had worked directly for the NHL official.

 

During a separate investigation, interviewees expressed concern over how the former intern had won the award from the National Collaborative for Women’s History Sites (NCWHS) and said that his academic qualifications were inferior to those of other bidders. Our initial review of the contract files disclosed that the former intern’s proposal contained a letter of recommendation authored by the NHL official and dated 13 days before the proposals were due.

 

Based on this information, we attempted to determine whether the NHL official violated any ethics rules or laws regarding Government procurement and conflict of interest.

 

We learned that the NHL official was significantly involved in the evaluation of the proposals on behalf of NPS and strongly advocated for the former intern to win the award, which she said she supported because he was the lowest qualified bidder. The NHL official also said that she wrote the recommendation letter as a general recommendation, not specifically to endorse the former intern for the NCWHS contract.

 

Because the former intern was never an NPS employee, post-employment restrictions governed by Federal law were not applicable to this situation. We also found that NPS policy authorizes employees to write letters of recommendation. Further, we did not uncover any evidence that the NHL official received anything of value in exchange for writing the recommendation letter or that she violated any criminal laws related to Government procurement.

 

As for potential conflict of interest, because the NHL official was the branch chief when the former intern served his internship, theirs may have been a “covered relationship” under conflict of interest rules codified at 5 C.F.R. § 2635.502(b)(1). 

 

We provided this report to the NPS Director for any action deemed appropriate.