Revolving Door Rules

The revolving door rules are a body of ethics laws and regulations designed to prevent former government officials from immediately using their government access, relationships, and inside knowledge to benefit private contractors, and to prevent contractor employees from improperly influencing procurements they may return to after government service.

What are the Revolving Door Rules?

"Revolving door" is the informal term for the statutory and regulatory scheme governing the movement of personnel between government and industry. The rules operate in both directions:

Government-to-industry (the outgoing door): 18 U.S.C. § 207 imposes lifetime and cooling-off bans on former officials representing private parties before their former agencies on matters they handled. See post-employment restrictions for the full tiered framework. Additional restrictions under the Procurement Integrity Act (41 U.S.C. § 2103) prohibit former officials from accepting compensation from contractors who received a contract award that the official was involved in evaluating, for one year after the award.

Industry-to-government (the incoming door): The Ethics in Government Act and OGE regulations require government employees to recuse from matters involving their former private employers or clients for two years after joining government. FAR 3.101-2 requires that contracting officials avoid any conflict between their private interests and official duties.

Contractor personnel performing government functions: FAR 3.11 (Personal Conflicts of Interest) applies to contractor employees who perform "acquisition functions closely associated with inherently governmental functions," such as writing specifications, evaluating offers, or advising on source selections. These employees must report financial interests in offerors and recuse from decisions where such interests exist.

The revolving door rules interact with OCI policy because a former government official who joins a contractor may bring with them information or influence that constitutes an organizational conflict.

Why Revolving Door Rules matter for government contractors

The strategic value of former government employees - their agency knowledge, program relationships, and understanding of procurement processes - must be balanced against the legal constraints that follow them. Contractors who establish systematic screening processes, recusal programs, and ethics training for newly hired former officials minimize the risk of inadvertent violations and the reputational damage that comes from being publicly associated with revolving door abuse.

Example

A Department of Defense contracting officer retires and joins a defense contractor as a capture manager. During her last year in government, she served as the contracting officer's representative on a $200 million logistics support contract that is now approaching recompete. The Procurement Integrity Act's one-year cooling-off provision bars her from accepting compensation from the contractor related to that specific contract. The contractor's legal team identifies the conflict, places her on a formal recusal from the recompete pursuit, and assigns her to programs unrelated to her former agency portfolio.

Frequently Asked Questions

Can a contractor employee take a temporary government position without triggering revolving door rules?

Temporary detail positions under the Intergovernmental Personnel Act (IPA) or similar programs are generally subject to standard conflict of interest rules for the duration of the detail, but the post-employment restrictions under 18 U.S.C. § 207 are triggered when someone leaves a position as a government employee. Short-term detail assignments can still create conflicts if the person performs functions that involve their home employer.

Are revolving door restrictions publicly searchable?

There is no centralized public database of revolving door restrictions. However, senior official ethics pledge agreements are public records, some agency IG reports document violations, and advocacy organizations track revolving door movements. The best practice for a contractor is to conduct its own screen by reviewing the former official's SF-278 (public financial disclosure) and asking the official directly to identify restricted matters.

What happens when a violation is discovered after hiring?

A contractor that discovers a revolving door violation must immediately remove the individual from the prohibited activity and consider whether to self-report to the agency IG and the contracting officer. Continuing to use the individual's services in a prohibited manner after discovering the violation significantly increases criminal and debarment risk.

Do the rules apply to contractor personnel who become political appointees?

Yes, in both directions. A contractor employee who becomes a political appointee must recuse from matters involving their former employer for two years. When that official later leaves government, 18 U.S.C. § 207's post-employment restrictions apply based on what they handled in the government role.