Former Education Service Executive Violated Ethics Rules and Her Duty to Cooperate Fully with the OIG

The OIG conducted an administrative investigation that included a congressional request to look into allegations that Charmain Bogue, former executive director of the Veterans Benefits Administration’s Education Service, committed ethical violations arising from her spouse’s consulting work for Veterans Education Success (VES). VES is a nonprofit advocacy group that regularly had business before the Education Service. The allegations also pointed to possible incomplete financial disclosures by Ms. Bogue concerning her spouse’s consulting business. In the course of their work, investigators uncovered evidence of other potential conflicts of interest and related misconduct by Ms. Bogue. As a result of the investigation, the OIG made four findings. First, Ms. Bogue participated in Education Service matters involving VES without considering whether it raised an apparent conflict of interest and acted contrary to ethics guidance she received from her supervisors. Second, Ms. Bogue sought résumé feedback from the president of VES to aid in her search for career advancement without considering whether this raised apparent conflict of interest concerns in subsequent VES matters. VES also endorsed Ms. Bogue for presidential nominee positions. Third, although Ms. Bogue provided insufficient detail about her spouse’s business in 2019 and 2020 public financial disclosures, VA ethics attorneys had found them compliant. She remedied the subsequently identified deficiency in her 2021 disclosure. Finally, the OIG found that Ms. Bogue refused to cooperate fully in the OIG’s investigation by refusing to complete her follow-up interview. Her husband and VES president also refused to participate in OIG interviews, and the OIG lacks testimonial subpoena authority over individuals who are not VA employees. Ms. Bogue resigned from VA in January 2022 and, as a result, the OIG made no recommendations. VA concurred with the OIG’s findings.