New Ethics Bill Forces Public Disclosure for Part-Time Federal Workers, Cracking Down on Corporate Conflicts

The SGE Ethics Enforcement Reform Act of 2025, or SEER Act, is aimed squarely at tightening the screws on part-time federal employees who often juggle government work with high-paying private sector jobs. Essentially, this bill says if you’re a “special Government employee” (SGE)—someone who works for the government intermittently—you’re about to get a lot more scrutiny, especially if you deal with big money or big companies. It mandates a public, searchable database of these employees and significantly expands conflict-of-interest rules, forcing many who currently fly under the radar to step into the sunlight.

The End of Hidden Day Jobs

One of the biggest changes the SEER Act introduces is transparency. Currently, many SGEs don't have to make their financial reports public. This bill changes that by creating a mandatory, free, and publicly searchable database (Section 5). This database must list the SGE’s full name, the running total of days they’ve worked, and why they were classified as an SGE instead of a full-time employee. Think of it as a public time clock for part-time policy influencers. This directly addresses the finding that the public often has no way to see potential financial conflicts of interest for these workers.

Why does this matter to you? Because these SGEs often advise on complex technical or financial issues. If a part-time advisor working on, say, new energy regulations also happens to be a highly paid consultant for a major oil company, the public deserves to know. This database ensures that if an SGE is serving for more than a few weeks, their commitment and potential conflicts are tracked and visible.

Conflict Rules Get Serious

For SGEs who aren’t just serving on advisory committees, the rules for avoiding conflicts are getting much stricter (Section 3). Previously, an SGE could sometimes participate in a broader government decision even if their outside financial interest only touched a small part of it—as long as that small part wasn't considered a "particular matter." The SEER Act largely closes that loophole. If your outside job has a financial stake in even one piece of a government decision, you’re likely conflicted out of the whole thing.

Furthermore, the bill tightens the waiver process. If an SGE is granted permission to work around a conflict, that waiver now requires sign-off from the Office of Government Ethics (OGE) and must be posted online within 14 days. This means fewer under-the-table deals and more public accountability for exceptions to the ethics rules.

The Billion-Dollar Blackout Rule

Perhaps the most restrictive provision is Section 4, which creates a communication blockade between certain SGEs and government agencies dealing with "large companies." A large company is defined as one with over $1 billion in market cap or revenue, or a federal contractor earning over $100 million annually. If an SGE owns stock in one of these giants or is a senior executive/director, they are now restricted from communicating with the agency if that agency is contracting with, regulating, or pursuing an enforcement action against that company.

In plain English: If you’re a part-time government expert, you can’t use your government position to talk to regulators about the company that pays your main salary. This is a massive firewall designed to stop the revolving door from spinning while the SGE is still technically inside the building. However, the definition of a "large company" also relies on the OGE Director determining if a company "controls too much of its industry market," which could introduce subjective and potentially political judgment calls into who gets blacklisted.

Serving Too Long Means Full-Time Rules

Finally, the bill addresses the issue of SGEs serving longer than the spirit of their part-time status allows. If an SGE works for their agency for more than 60 days in a 365-day period, they are now subject to all the standard Federal ethics rules that apply to full-time employees (Section 8). If they hit the 130-day mark, they also face specific rules regarding pay and post-employment restrictions, regardless of whether they were paid or volunteered.

This change is key because it prevents agencies from relying on part-time staff for nearly half the year while allowing them to bypass the full ethics and disclosure requirements of career employees. While this is great for accountability, agencies relying on highly specialized SGEs for extended periods might face administrative headaches, and some experts might be deterred from serving if the increased scrutiny outweighs the convenience of part-time work.