Federal Agencies CAN’T Refer or Recommend Consultants.

  • March 11, 2020

The world is imperfect and sometimes things happen that shouldn’t. As professionals and members of the Grant Professional Association (GPA) and the American Evaluation Association (AEA), and simply people who care about doing the right thing, we feel it aligns with our code of ethics to let clients and potential clients know about some of the situations they may encounter that are not quite right or a bit sketchy.

In order to give all companies an equal advantage and remain an impartial third party, federal agencies are not allowed to provide recommendations to program participants.

If you are participating in a federal agency program and a federal employee refers a company or individual for consultation, commercialization, evaluation, or proposal preparation to you or your colleagues this should be a HUGE RED FLAG. (An example of this would be a federal employee affiliated with an SBIR/STTR agency or other federal grant agency referring you to a specific company or consultant to work with to help with proposal development and preparation.)

Federal agency representatives are responsible for being impartial. For this reason, reviewers and funders recommending or referring certain consultants is a blatant conflict of interest. Besides, do you really want advice or referrals from a person who breaks their organization’s code of ethics? Sketchy…

But what to do in this situation? The unfortunate truth is it can be difficult to know how to proceed in this situation. The startup community is fairly tight-knit and those who bring inappropriate behavior to light can be “punished” by their peers through exclusion and gossip. (We do support you letting your peers know what is going on. Just be careful how you frame it.)

If you feel something has happened that absolutely must be addressed there is a government portal where you can report wrongdoing by federal agencies. Report Fraud, Waste, and/or Abuse HERE.

Hotline to Report Fraud, Waste or Abuse

The Inspector General Act of 1978 gave the Office of the Inspector General (OIG) the authority to accept complaints from the Office of Personnel Management (OPM) employees, contractors, and the public concerning criminal activity, fraud, waste, abuse, and mismanagement of OPM programs and operations.

The best way to handle this, besides reporting egregious behavior, is to protect yourself by being informed. By learning about regulations and ethics you can spot questionable behavior and avoid situations where it may occur. Also, by doing a small bit of research you can either find a professional who suits your individual needs or fact-check any recommendations or referrals you receive.

One example we always like to point out is the Grant Professionals Association (GPA). It is a great resource for locating proposal professionals (We are listed here). The members of this organization agree to uphold the organization’s code of conduct and ethics. GPA even has a searchable database to help put you in touch with grant professionals.


On a final note, you should know, that the overwhelming majority of federal agency representatives adhere to their organization’s code of conduct so hopefully, you never have to deal with a situation like this. However, if you do, we hope you now have a better idea of how to respond and where to find appropriate consultants.

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We assist our clients in locating, applying for, and evaluating the outcomes of non-dilutive grant funding. We believe non-dilutive funding is a crucial tool for mitigating investment risks, and we are dedicated to guiding our clients through the entire process—from identifying the most suitable opportunities to submitting and managing grant applications.