Allegations of Conflict of Interest at Gettysburg National Military Park

We investigated an anonymous complaint alleging that Superintendent Ed Clark of Gettysburg National Military Park (GETT) violated ethics rules by soliciting funds on behalf of the Gettysburg Foundation, a non-Government organization; accepting Foundation-funded travel to events sponsored by the Foundation and those sponsored by other non-Government entities; and hosting a Foundation-funded dinner for his employees. We found that from February 2014 to October 2016, Clark traveled 27 times to attend events organized by the Foundation. We found that Clark committed criminal violations by submitting false travel vouchers and by accepting more than $23,000 in meals, lodging, and other in-kind gifts from non-Government organizations as compensation for his official services. In addition, he violated laws and regulations by failing to obtain required supervisory and ethics approval prior to taking these trips and by failing to report expenses accurately following his trips. We also found that his subordinate staff approved his travel authorizations, that he sometimes traveled without first submitting a travel authorization request, and that he requested full per diem reimbursement even though the Foundation paid for some of his meals during those trips. We found that Clark functioned as GETT’s liaison to the Foundation without prior supervisory approval or consulting with ethics officials. We did not find evidence that Clark solicited funds on GETT’s behalf, but we did find that Clark twice gave statements of support to the Foundation and the Civil War Trust that were included in solicitation letters addressed to members and potential donors. We also found that in September 2015 Clark asked the Foundation to pay for a dinner costing more than $6,000 that Clark and other National Park Service employees and Foundation guests attended, violating the ethics regulation that prohibits soliciting gifts from prohibited sources. We coordinated this investigation with the U.S. Attorney’s Office for the Middle District of Pennsylvania and on October 17, 2018, we were informed that office had declined prosecution.