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John Windom was the public face of the Electronic Health Record Modernization (EHRM) project for the Veterans Affairs Department. It’s one of the largest IT modernization projects the federal government has undertaken. The Justice Department recently charged him with “alleged failure to disclose his receipt of thousands of dollars in cash, casino chips, gift cards and other gifts from contractors while leading the project.” The indictment says he was “fully aware of ethics laws and regulations restricting his acceptance of gifts.” Yet he “routinely accepted personal benefits such as gifts, meals, alcohol, entertainment and other services” in the course of his duties. Further, he “used his position ... to encourage, monitor, and facilitate contracting and subcontracting opportunities.”Potential weak spots in financial disclosure Financial disclosure is a mandatory process for any government employee who independently exercises significant judgment in taking action in certain designated areas. The purpose of disclosure is to remove potential conflicts of interest and prevent taxpayer-funded decisions that lead to personal gain.At the time of this writing, these are only allegations of wrongdoing. Windom is entitled to a presumption of innocence until the matter is settled in court. However, the controversy calls to mind three weaknesses in the financial disclosure process for federal employees.