The Defense Department inspector general recently criticized seven military officials for their participation, but did not judge the involvement of EPA Administrator Stephen Johnson or Retired Vice Adm. Dan Cooper, undersecretary for benefits at VA.
"Our office did conduct an inquiry into Administrator Johnson's participation in a promotional video for Christian Embassy and found no wrongdoing," said John Manibusan, a spokesman for the EPA inspector general's office, in a statement. "Therefore, the inquiry was closed."
Manibusan declined to release any further details on the investigation, and no report on the inquiry appears on the agency's Web site.
When approached by the Defense IG's office, "we made a referral to the designated agency ethics official," said Cathy Gromek, a spokeswoman for the VA inspector general's office. "He reviewed the video, and he determined that conduct portrayed in the video did not violate federal laws or regulations."
The Defense Department's investigative branch released its own report on Aug. 3, concluding that seven Army and Air Force officers, four of them generals, acted improperly by appearing in the video in uniform and in locations within the Pentagon. Those appearances, the IG said, could be construed as meaning the Defense Department endorsed Christian Embassy, an outreach program of the evangelical group Campus Crusade for Christ ministering to Washington leaders.
The Defense auditors also said the unusual level of access given to the film crew to shoot at the Pentagon constituted an inappropriate "selective benefit."
The appearances of Johnson and Cooper in the video differed from those of the military officers. Both were identified simply as presidential appointees, and though Cooper was labeled as an "undersecretary," he was not linked to a department. Though both showed up in what appeared to be offices, the only insignia visible during their interviews was the American flag.
The differing responses to military and civilian officials' participations may also be explained by the ethics rules they are required to follow.
The EPA requires training on ethics rules -- which include some general prohibitions on providing preferential treatment to outside organizations and guidelines for acceptable fund-raising -- for some, but not all, of its employees. About 9,000 EPA employees were required to complete an hour of ethics training last year.
All Defense employees are required to complete annual ethics training. The Standards of Conduct Office has developed online training that includes a lengthy section on use of official position and promotion of nonfederal entities.
The Air Force uses a secured Web site to provide annual ethics training and certification.
In April 2005, Francis Harvey, then the secretary of the Army, mandated that all soldiers and civilian employees of the Army receive annual face-to-face ethics training. Those programs are administered by the designated agency ethics official -- currently the general counsel -- who is appointed by the secretary of the Army.
That training states that "endorsement of a private organization event, product, service may not be stated or implied by soldiers or . . . civilians in their official capacities," and reiterates that "When participating in [private organizations] or [nonfederal entities], soldiers and Army civilians must act exclusively outside the scope of their official positions."
Prohibitions on identification by title and appearing in uniform are specific to the Defense Department.