Holiday Hazards

December is a time for merriment and gift giving, but for federal employees -- especially managers -- it can be a minefield.

While the litany of restrictions governing holiday behavior for federal employees can be a hassle, it's usually more stressful to see something vague and generic like: "Please note, there are no legal restrictions on gifts given to peers or subordinates, however, common sense (and good taste) should apply."

Federal managers and employees seem to have more than usual to worry about this holiday season, from a new snow policy to the possibility of extended pay freezes. But even during less anxiety-ridden times, navigating the gifts and parties that come with the holidays can be tricky for federal managers. The Defense Department's Standards of Conduct Office releases an annual Holiday Guidance memo for Pentagon personnel, but it's a very good starting point for all government managers and employees as well. A few highlights:

  • Supervisors generally cannot accept gifts from subordinates or co-workers who receive less pay than they do. During the holidays, however, supervisors can accept noncash gifts of $10 or less from a subordinate. They also are permitted to accept food and refreshments shared in the office and can contribute to an office party.
  • Office parties are unofficial events -- managers cannot use appropriated funds to pay for them. Nor can they use appropriated funds to purchase and send greeting cards. They also are barred from soliciting outside sources for contributions -- including funds, food or other items -- for an office party.
  • If federal managers invite subordinates to a social event at their home, those employees are allowed to give them a hospitality gift "of the type and value customarily given on such an occasion."
  • Be careful when considering door prizes or drawings for office parties. They cannot involve gambling, which requires compliance with state statutes and federal regulations. Defense regulations prohibit gambling in the Pentagon and on federal property or while in a duty status. General Services Administration regulations ban gambling in GSA-owned or controlled buildings.
  • Under most circumstances, Defense employees and officials are barred from accepting gifts -- including attendance at parties, open houses and receptions -- from contractors or other "prohibited sources." There are a number of exceptions, however, including events that are widely attended or open to the public.

Gifts for employees should be kept small and relatively uniform. It also is a good idea to present them all at once, perhaps during the office holiday event. This will help avoid making any employee feel -- even temporarily -- like he or she is receiving special treatment or being left out. If there is no time to catch everybody at once, then leave gifts on workers' desks one morning before they arrive.

Of course, steer far clear of anything that could seem excessively personal or inappropriate. Business-related gifts like business cardholders, pens or USB drives are the safest bets followed by gift certificates or cards, perhaps to a local coffee shop or movie theater.

By boning up on the relevant laws and regulations and staying well within the bounds of appropriate professional gift-giving, federal managers and employees can ensure that they will have a fun and productive holiday season.

Elizabeth Newell covered management, human resources and contracting at Government Executive for three years.

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