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External Organizations Board Practice

Report Information

Date Issued
Report Number
2021-17259
Report Type
Inspection / Evaluation
Description
In response to requests from stakeholders, we scheduled an evaluation to determine if the Tennessee Valley Authority (TVA) complied with the 2016 Board Practice regarding memberships in external organizations.We found no evidence TVA was out of compliance with the TVA Memberships in External Organizations Board Practice. We did not identify any evidence of direct lobbying or litigation on behalf of TVA; however, the external organizations do not administratively segregate TVA’s funds, so we were unable to determine if the funds were used for lobbying or litigation. We also found all contracts or membership agreements contained required language limiting the use of TVA funds for prohibited activities such as litigation or lobbying; however, TVA does not have a contract or membership agreement with one external organization.We also identified opportunities for improvement related to TVA’s management of memberships in external organizations. Specifically, we determined TVA could (1) provide training of employees participating in committee or leadership roles in external organizations and (2) benefit from the coordination of all memberships in external organizations with the Office of the General Counsel to confirm all legal and ethical requirements are met.
Joint Report
Yes
Participating OIG
Tennessee Valley Authority OIG
Agency Wide
Yes (agency-wide)
Questioned Costs
$0
Funds for Better Use
$0
View report on Oversight.gov

Recommendations

We recommend the Executive Vice President and General Counsel implement a policy for coordination of Tennessee Valley Authority memberships in external organizations which includes a (1) review for compliance with all legal, ethical, and governance requirements and(2) centralized record of all employees participating in external organizations.

We recommend the Executive Vice President and General Counsel implement a training program for employees involved in external organizations to educate them on the boundaries of their participation as a Tennessee Valley Authority employee.

We recommend the Executive Vice President and General Counsel implement an agreement, for the external organization with no contract or membership agreement, to include specific language prohibiting the use of Tennessee Valley Authority funds for lobbying or litigation, as is included in other membership agreements or contracts.