If you write or manage grants for a government agency, you've built a skill that is in demand well beyond your own office. You may also get asked to help a nonprofit, a neighboring town or a friend's organization with an application, or you may be thinking about where your career goes next.
This article covers the rules to check before you do any grant work outside your job, how to handle tools and data, and how to build skills in ways your employer will back. It isn't legal advice. Your agency's ethics office is the authority on your situation.
Start with the rules that apply to you
Federal executive branch employees are covered by the Standards of Ethical Conduct in 5 CFR part 2635. State, local and tribal employees are covered by the laws and policies of their own governments, and those differ widely. Whichever applies to you, the first step is the same: find your ethics official and ask.
The federal standards say employees who have questions about particular situations should seek advice from an agency ethics official (5 CFR 2635.107). The same section says an employee who acts in good-faith reliance on that advice, after full disclosure of all relevant circumstances, won't face disciplinary action for the conduct. It also says disclosures to an ethics official are not protected by an attorney-client privilege. Ask before you start, and get the answer in writing where you can.
Keep your time, tools and records separate
Three federal rules give a useful picture of the boundaries, and most state and local codes have counterparts.
- Government property. Under 5 CFR 2635.704, employees may not use government property for other than authorized purposes. The definition includes computers and other electronic devices, government email and social media accounts, telephones, printing facilities and government records.
- Official time. Under 5 CFR 2635.705, employees must use official time in an honest effort to perform official duties. Outside grant work doesn't belong in your workday, even a slow one.
- Nonpublic information. Under 5 CFR 2635.703, nonpublic information is information you gain by reason of federal employment that you know or should know hasn't been made available to the general public. It includes information that is protected from disclosure or designated confidential by an agency. You can't use it to further your own private interests or another's.
The practical result is a clean line. Use your own device, your own account and your own hours. Don't draw on anything you know only because of your job, such as unreleased scoring information, other applicants' materials or internal funding plans.
Check outside activities before you accept them
Even with clean tools and clean time, the activity itself can be a problem. Several federal provisions are worth knowing:
- Approval and conflicts. Employees may not engage in outside activity that conflicts with their official duties, and agencies may require prior approval (5 CFR 2635.801 and 2635.802). An activity can conflict if an agency regulation prohibits it, or if it would require you to step aside from matters central to your job.
- Organizations you belong to. An employee may not use their public office for the private gain of persons with whom they are affiliated in a nongovernmental capacity, including nonprofit organizations of which they are an officer or member (5 CFR 2635.702).
- Paid writing. An employee may not receive compensation from outside the government for teaching, speaking or writing that relates to their official duties (5 CFR 2635.807). Writing relates to your duties if, for example, its subject deals in significant part with a matter you were assigned in the previous year, or with an ongoing program of your agency.
Taken together, a few questions are always worth asking your ethics official. Does the organization apply to or receive money from your agency? Do you review, score or manage grants in the same program? Would you be paid, and by whom? A volunteer favor for a nonprofit that your agency funds can raise issues that a favor for an unrelated organization doesn't.
Use only data you're permitted to use
Public notices are public. Grants.gov publishes funding opportunities for anyone to read, and a funding notice is the safest foundation for any application work.
The harder cases are the ones where data is involved:
- Never put confidential data into an unapproved tool. That includes case files, personal information about the people your agency serves and anything marked sensitive, whether the tool is a document editor or an AI assistant.
- Follow your agency's technology and data policy, not a general rule of thumb. Policies on outside tools and AI vary by agency, and the policy that applies to you is the one your agency's IT or privacy office has published.
- Use your own organization's materials for outside work, or those of the client, with their permission. Never rely on your employer's records.
Our posts on data privacy and confidential information and what to hand off to AI go further on tools.
Build skills the right way
Grants.gov's Learning Center has a Grant Careers section that points to resources for people building a career in federal financial assistance. It notes that the CFO Council offers an online course for government employees and grant professionals, with five modules: laws, regulations and guidance; financial assistance mechanisms; Uniform Guidance administrative requirements; cost principles; and risk management and single audit. The CFO Council has also defined functional competencies for the field and a career roadmap.
Ask your supervisor whether training time and costs can be covered. Employer-supported training keeps your development inside your job, where the ethics questions are simple.
Why the skills travel
The Uniform Guidance speaks to both sides of the table. Part 200 sets duties for federal agencies, such as what a notice must contain, and duties for recipients, such as reporting and records. Someone who understands both sides is useful to an agency, a nonprofit or a consultancy. Our guide to the grant professional career path maps where those skills lead.
A worked example
Say a county grants analyst is asked by a friend to help a local food pantry with an application to a state program that the county also applies to. The analyst could answer the question in five parts:
| Question | Why it matters |
|---|---|
| Does the county compete for the same funds? | Possible conflict with official duties |
| Does the analyst help score, advise or manage that program? | Possible need to step aside |
| Is the analyst an officer or member of the pantry? | Affiliation rules may apply |
| Would the analyst be paid? | Compensation rules may apply |
| Will the work use county time, devices or records? | Generally off-limits without authorization |
The analyst takes the list to the county's ethics office or counsel and follows the answer. This is a hypothetical, and your own rules may differ.
Your next step
Read your agency's technology and data policy and its outside-activity rules this week. Find your ethics official's name and contact details and save them. Then write down the one outside grant task you've been considering, and the questions above for it, before you say yes to anyone.
SoliContraX is built to start from a public funding notice and materials you're allowed to use, and you review everything it drafts. Whether you may use any outside tool is a question for your agency's policies first. See how to get started.
Sources
- 5 CFR 2635.107, Ethics advice (eCFR)
- 5 CFR 2635.702, Use of public office for private gain (eCFR)
- 5 CFR 2635.703, Use of nonpublic information (eCFR)
- 5 CFR 2635.704, Use of Government property (eCFR)
- 5 CFR 2635.705, Use of official time (eCFR)
- 5 CFR 2635.801, Overview (outside activities) (eCFR)
- 5 CFR 2635.802, Conflicting outside employment and activities (eCFR)
- 5 CFR 2635.807, Teaching, speaking, and writing (eCFR)
- Grant Careers (Grants.gov Learning Center)