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important ethical questions about an effort to influence the Veterans Administration (VA) to limit veterans’ ability to use their GI Bill benefits at certain colleges.

An outside interest group opposed to for-profit education, Veterans Education Success (VES), drove the effort. VES paid the husband of a key career official at the VA, Charmain Bogue, while at the same time advocating that she take action to further VES’s ideological crusade against for-profit schools.

Now, NLPC has obtained the official federal financial disclosure forms for Charmain Bogue. The forms raise more questions than they answer about her husband Barrett Bogue’s income from VES.

Under the section where a spouse’s income is supposed to be disclosed, Charmain Bogue wrote only, “Self-Employed (Consulting Firm)” and listed the income type as “Salary, Consulting Fees.” There is no disclosure of the name of the firm or the amount of income Barrett Bogue earned.

A key purpose of financial disclosure rules is to ensure that there are no hidden conflicts of interest by government officials. Yet these disclosure forms failed to inform VA leadership and the public of the conflict caused by VES’s payments to her husband while trying to influence Charmain Bogue.

Why didn’t she disclose the name of her husband’s firm, the amount of his income, or his employment relationship with VES? If she wasn’t technically required to, perhaps the disclosure standards should be improved.

The rules can get complicated, but essentially characterizing him as “self-employed” allows the Bogues to withhold some detail that they would otherwise be required to disclose on earned income from a third-party. See, the Ethics in Government Act, 5a USC § 102(e)(1)(A).

So, is Barrett Bogue self-employed? Or does he receive a “salary” as the disclosure states? And if so, who pays it?

VES lists Barrett Bogue, as a “Senior Communications Advisor” on its website. His VES bio mentions his company, Evocati, LLC, but fails to disclose his wife’s position at the VA or that VES has sought to influence her to take official actions.

Why does it matter? A few months after VES wrote to Charmain Bogue urging her to limit veterans’ educational choices and punish for-profit colleges, the VA threatened to do exactly that. On March 9, the VA issued a press release trumpeting its intent “to suspend enrollment of new GI Bill students” in certain for-profit schools.

But guess who beat the VA to the punch on the news? Former staffer to Sen. Tom Harkin (D-IA) and VES President Carrie Wofford. VES issued a press release earlier in the day praising the VA decision before the VA even announced it.

Did VES manage to extract the March 9 threat and get advance notice through its insider connection and payments to Barret Bogue? Did VA leadership know about the conflict? Ultimately, the VA backed down from following through on its public threat, but the situation invites a great deal more scrutiny.

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Tags: Barrett Bogue, GI Bill, Veterans Administration, Veterans Education Services