Ethics Agency Director Resigns ... Comstock Cites Professional, Personal Reasons for Leaving

By Christopher Lee
Washington Post Staff Writer
Friday, December 5, 2003; Page A29

The head of the federal agency in charge of promoting high ethical standards and preventing conflicts of interest in
the executive branch is stepping down today, giving President Bush an opportunity to fill the job with a nominee of his
own.

Amy L. Comstock, a Clinton appointee who has been director of the Office of Government Ethics since November 2000,
begins a new job Monday as executive director of the Parkinson's Action Network. The nonprofit group lobbies for more
research money for Parkinson's disease, a debilitating and progressive brain disorder that afflicts 1 million
Americans.

Comstock, 44, said in an interview this week she decided to leave her $142,500-a-year ethics post three years into her
five-year term because she wants to pursue other opportunities, both professional and personal. She previously served
as an attorney at the Department of Education and the White House Counsel's Office.

Jeffrey C. Martin, Comstock's former boss at Education, is the chairman of the board of the Parkinson's group. "I
talked to him and interviewed with the board and was very impressed with their mission to cure this devastating
disease," she said. "I feel it's a real challenge, a new opportunity."

Another reason for her departure, said Comstock, is that she and someone who works for her at the ethics office "have
become friendly, and it is a relationship we would like to pursue."

Pursuing a romantic relationship with a subordinate while serving as director would constitute a breach of the federal
government's standards of ethical conduct, ethics experts said. It could raise questions about favoritism in job
evaluations and pay raises.

"Nobody asked me to leave. But I will be frank with you, it did make me want to leave," said Comstock, referring to the
prospective relationship. "It made me want to pursue other opportunities. We're both interested in pursuing a
relationship, and the best way to do that is to not work in the same office."

Marilyn L Glynn, general counsel at the agency, will serve as acting director until the Senate confirms a replacement.
A White House spokeswoman said officials are working to identify a nominee.

The main task of the 25-year-old agency, which had 81 employees and a budget of $10 million in fiscal 2003, is to
review and interpret the rules pertaining to conflicts of interest, post-employment restrictions, standards of conduct
and public and confidential financial disclosure statements.

With the help of designated ethics officers inside federal agencies, the office is supposed to determine where
violations occur and recommend corrective action. The office also is responsible for training employees on ethics
standards.

The agency has done a good job administering a system in which tens of thousands of employees file regular financial
disclosure forms, said Charles Lewis, executive director of the nonpartisan Center for Public Integrity. Lewis has been
less impressed with the agency's role in advising officials about potential ethical conflicts.

For instance, Lewis said, the agency sat on the sidelines this spring when Richard N. Perle, then the head of a
Pentagon advisory board, came under scrutiny for representing companies that had dealings with the Defense Department
while he was board chairman. (Last month, the Pentagon's inspector general concluded that Perle, who resigned as
chairman but remains on the panel, had violated no ethics laws.)

"OGE wasn't beating down the door," Lewis said. "No one was upset about or concerned about the whole Perle matter."

Comstock said there is a common misperception that the OGE is supposed to police federal agencies, looking for ethics
violations.

"We're an oversight agency," she said. "Every agency has an ethics official who is actually responsible for
implementing our regulations. . . . And if there is a problem, if the program is working, it's that ethics official who
handles it."

Comstock said she focused her efforts on eliminating redundancy in financial disclosure forms and broadening the use of
technology. She said some ethics laws are too onerous, such as a provision that prohibits federal employees from
representing another entity before a federal agency. While such restrictions sometimes make sense, they can prevent a
low-level federal worker from, say, volunteering to help homeless people apply for government benefits.

"In Washington, there's a lot of hesitation to change the ethics rules for fear that someone will be told that it looks
like they are weak on ethics," she said.

Stephen D. Potts, a former director of the OGE, praised Comstock, saying, "overall she's done a good job."

SOURCE: The Washington Post  Page A29
http://www.washingtonpost.com/wp-dyn/articles/A36742-2003Dec4.html

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