The 2019 Presidential Transition Enhancement Act is now law. Primarily an update to the 2015 version of a similar law, this law does a laundry list of things. For example, when the “campaign” becomes the “administration”, the transition team use to have 180 days to use GSA’s discounted services. This is like an Amazon Prime membership, specially limited to government organizations. The new law reduces that benefit for the transition team to 60 days.

This was a strongly bi-partisan effort and was welcomed from both sides of the aisle.

A buried impact of the law is the requirement to have all presidential candidates create and release ethics plans for their transition teams before the election. Just like any other Ethics and Code of Conduct Plan, this requires disclosure of an potential Official Conflicts of Interest of any people on the team. A positive step towards disclosure and awareness. The deceitful will always find a way, but this law forces a plan to be developed and published.

The trend is moving towards disclosure and ethics. Federal contractors already have this requirement. The Code of Federal Regulations, Title 48 (also known as the Federal Acquisition Regulation or FAR) 48 CFR § 52.203-13, requires disclosures of conflicts of interest as well as internal control systems and regular training programs.

RECOMMENDATION, be proactive on these matters. Develop an ethics plan and enforce it. Ensure your employees are aware of your plan. Conduct refresher training. Make it relevant and make it practical.