Section 207(d), like section 207(c), discussed immediately above, imposes a one-year prohibition on post-employment representational contacts with "intent to influence"; but unlike section 207(c), it applies only to former very senior employees; it prohibits such contacts not only with any such employee’s former department or agency but with high-level personnel in any department or agency; and it is subject to no limitation by determinations of the Director of OGE. The "very senior personnel" to whom the prohibition applies are

1. the Vice President;
2. persons in executive branch positions, including positions with an independent agency, paid at Level I of the Executive Schedule;
3. persons in the Executive Office of the President paid at Level II of the Executive Schedule or above;
4. persons appointed by the President under section 105(a)(2)(A) of title 3 [certain White House employees]; and
5. persons appointed by the Vice President under section 106(a)(1)(A) of title 3 [certain assistants to the Vice President].

     As described under 1.11:600, above, subsection (j) of section 207 sets out seven general exceptions to some or all of the post-employment prohibitions contained in that section. The prohibition of subsection (d) is subject to all seven of those exceptions.

There are two categories of persons that the former very senior employee may not make representational contacts with during the one-year period. The first is employees of the department or agency in which the very senior employee served as such within the one-year period preceding termination of his or her government employment. Section 207(d)(2)(A). This is substantially equivalent to the restriction imposed by section 207(c) on former senior employees, except that there is no comparable provision for designation of separate agencies or exemption of particular positions by OGE.

In addition, very senior employees are prohibited from contacting "any person appointed to a position in the executive branch which is listed in section 5312, 5313, 5314, 5315, or 5316 of title 5" [listing the grades of the Executive Schedule], regardless of whether these persons serve within the very senior employee’s former agency. Section 207(d)(2)(B).

The prohibition applies for one year following the date on which the former employee ceased to be a very senior one, and not from the termination of government service, unless the two dates are the same. OGE Summary at 9.

Like the prohibition of section 207(c), this one applies to communications or appearances with respect to all matters, regardless of whether they involve specific parties; but, again, it does not prohibit in-office drafting or counseling.