NATIONAL SCIENCE FOUNDATION OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM Case Number: A12110080 Page 1 ofl 1 NSF informed us of discrepancies between a program officer's annual conflict of interests disclosure (OGE Form 450) and his Independent Research and Development (IR/D) plan. The discrepancies related to the program officer's involvement on editorial boards and advisory committees. Disclosures of these activities are specifically required on OGE Form 450 for both paid and unpaid positions. This information is also requested on the IR/D plan which allows program participants a portion of their NSF duty-time to maintain currency in their research areas. The Deputy Agency Ethics Official's (D AEO) staff in the Office of General Counsel review submitted OGE Form 450s for all covered employees on an annual basis as well as on new employees' entry into NSF. According to the IRID application, OGC review of the IRID plans is not triggered unless the plan includes one of four narrowly described situations that do not include participation on editorial boards or advisory committees. However, the NSF personnel manual requires OGC to review all IRID plans. The IRID plan in this case was not reviewed in OGC when it was submitted or when it was resubmitted by the program officer months later. The discrepancy was not identified until after the program officer submitted a travel voucher related to his participation at an advisory committee meeting for which the committee reimbursed some of his travel expenses. We interviewed the program officer and reviewed his OGE Form 450 and IR/D plan with him. Prior to coming to NSF he had never made a financial disclosure of the type required in OGE Form 450. He made corrections to his original OGE Form 450 at the request ofOGC but failed to include the positions on editorial boards and advisory committees. He demonstrated confusion with respect to the terminology used to describe positions that required disclosure. There was insufficient evidence to establish a knowing intent to omit the required information. Absent such evidence, there is no support for proceeding with this case. Accordingly, this case is closed. NSF OIG Form 2 (11102)
Published by the National Science Foundation, Office of Inspector General on 2013-05-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)