Hiring From Government: A Field Guide for Contractors

For a government contractor, few hires carry more promise than a leader who has just come out of the customer's organization. They understand the mission, the budget and the people. They also arrive with a set of post-government employment rules that shape what they can do for you, and when.

Most of those rules are manageable once they are understood. The trouble comes when a company discovers them after the offer is signed. This guide covers what we look at on every search that involves a sitting or recently departed federal official or military officer.

This is a practical overview, not legal advice. Every hire of a current or former official should be reviewed by your counsel and by the candidate's agency ethics office.

Before the first call: the candidate's recusal clock starts early

Under the executive branch ethics rules, a federal employee is generally "seeking employment" as soon as they respond to an approach with anything other than a clear no. From that point they must step away from any government matter that would affect your company. Senior officials who file public financial disclosure reports must also notify their ethics office within three business days of starting negotiations.

If the candidate is involved in one of your competitive procurements, the procurement integrity rules add another layer: they must report the contact in writing and either reject the possibility of employment or recuse themselves from the procurement.

That makes the very first conversation a compliance event. When we approach a sitting official on a client's behalf, we say so plainly at the start and remind them of their obligations. It protects the candidate, and it protects your procurement.

The restrictions that follow them out the door

• Lifetime: a former employee may not represent anyone back to the government on a specific matter, such as a contract or a claim, that they worked on personally and substantially.
• Two years: the same restriction applies to matters that were under their official responsibility during their last year, even if they did not work on them directly.
• One year for senior officials, two years for very senior officials: a "cooling off" period during which they may not contact their former agency, and in the most senior cases a wider set of officials, to influence official action.
• One year, procurement integrity: an official who served as contracting officer, source selection official, program manager or in certain other roles on a contract over $10 million may not accept compensation from the company that won it for one year.
• Defense lobbying: former general and flag officers and senior Defense Department civilians face a separate one- or two-year restriction on lobbying the Department. The Department asked Congress in 2026 to narrow this rule in the next defense authorization act, so check its current status before relying on it.

The key point for most hires: nearly all of these rules restrict what a former official may say to the government on your behalf, not whether they may work for you. Behind-the-scenes work is usually permitted, with some exceptions for the most senior officials and for foreign representation.

The ethics opinion: ask for it and keep it

Senior Defense Department officials, and those who held certain acquisition roles on large contracts, must request a written opinion from a Department ethics official before accepting pay from a defense contractor within two years of leaving. Contractors, in turn, may not knowingly compensate a covered former official who has not requested one.

Ask every candidate in this group for the letter, read it with your counsel and keep it on file. It tells you in writing which matters the candidate must stay away from, which is exactly what you need to design their first year.

Build the first year around the restrictions

The most common mistake we see is hiring a former official specifically for work they cannot yet do, such as leading capture on a recompete at the agency they just left. The better approach is to write the role so that the first twelve to twenty-four months do not depend on restricted activity:

• Point them at adjacent customers, internal operations, program delivery or talent, where their judgment is valuable and the rules do not bite.
• Use their understanding of the customer inside the company, in strategy and proposal reviews that do not involve contact with their former agency, after counsel confirms the arrangement.
• Name one person, usually in legal or contracts, who owns the compliance plan and reviews it at each restriction's end date.

Timing, retirement dates and clearances

Military candidates on terminal leave are still on active duty until their retirement date and are still covered by the rules for current personnel. Federal civilians often have a preferred separation date tied to retirement eligibility. Build both into the search calendar early; they frequently drive the start date more than the candidate's preference does.

A clearance does not move with a person on its own. Your facility security officer will need to establish access, and whether the candidate's eligibility can be reinstated quickly depends on how long ago their investigation was completed and how long they have been out of access.

What to assess for

Former officials bring rare strengths: credibility with the customer, a real understanding of the mission and often very large organizations run under difficult constraints. The questions worth probing are different ones: how they think about profit and loss, how comfortable they are with business development targets, and how they adapt to the pace of commercial decisions. The best candidates have usually thought about those questions before you ask.

A short checklist

• Identify every current or recent federal and military candidate on the slate, and their grade or position.
• Confirm when each began "seeking employment" and that they have handled recusal and notification.
• Request the post-employment ethics opinion from any covered Defense Department candidate before an offer is accepted.
• Have counsel map the restrictions against the role's first two years, and adjust the job if needed.
• Set the start date around retirement, terminal leave and clearance timelines.

Reffett Associates has recruited for the federal government and its contractors for more than three decades. Our team includes former military officers and congressional staff, and we run these searches with the rules in mind from the first call.