When Covid began to run roughshod over the U.S in mid-2020 I had an opportunity to work as a “senior advisor” at the U.S. Department of Health and Human Services (HHS). I spent much of my time working with Covid “testing czar” Brett Giroir and the other leaders and staff of the Food and Drug Administration (FDA) and Centers for Medicare and Medicaid Services (CMS) on communications and messaging matters. Covid was the issue 24/7.
I had an excellent experience, and have written about it elsewhere.
This brief piece deals more with the business implications to your small firm if you decide to work with a federal agency. As a healthcare consultant with several clients dealing with regulatory matters before the FDA and CMS, this was an opportunity to see things from the inside.
But for my particular HHS gig, though, I was required to end my relationship with two current health clients with pending FDA and CMS federal regulatory matters. Not a problem, and surely reasonable from a conflict of interest standpoint. After a one year “cooling off period” upon leaving HHS service, I was confident I could get those clients back. If not, I would find others. All has worked out fine in that regard.
I was unfortunately forced to resign as a board member of Headcount — the non-profit, non-partisan voter registration group I’d been involved with since 2012. I didn’t want to do that. It didn’t make sense to me, felt the “rule” might be malleable, and hired an attorney to resist the supposed board resignation requirement. This might seem like a minor matter, but music festival voter-registration was the only facet of electoral politics I was still involved with after many years working campaigns. I had to let it go.
All in all, the paperwork burden regarding my security clearance, human resources folderol, unwinding federal payroll, tax compliance and ongoing conflict of interest avoidance (my cooling off period is finally over) is severe. More than two years after ending all HHS work, there was still paperwork to file with the ethics staff.
Was the experience and remuneration at HHS worth it all?
Short answer: yes. But if you’re a small business without the wherewithal of in-house legal, accounting and human resource staff, prepare to spend endless hours filling out documents, going over seemingly mundane information with federal bureaucrats, answering questions from the FBI (with multiple follow-ups) and possibly hiring legal assistance depending upon the nature of your agency involvement.