OpenSecrets: Health and Human Services Secretary Tom Price has been mired in questions about his investments in the healthcare industry. As it turns out, some of the people helping him get grounded at the department are also prompting questions about their ties with the industry.

Lance Leggitt, a lobbyist at Baker Donelson since 2006, was named Price’s chief of staff earlier this month. In 2016 alone, he lobbied for 10 organizations — all related to health care. Alere Inc, for example, manufactures diagnostic tests and spent nearly $900,000 lobbying last year. Other clients included hospitals and a medical trade group.

Leggitt deregistered as a lobbyist in January, because he was on his way to HHS even before being made chief of staff. In the early days of the administration, Leggitt was a member of President Trump’s “beachhead” force, a temporary cast of characters brought in to keep the government running and lay the groundwork for Trump’s agenda. With key jobs in the administration being filled at a slower-than-average pace, these individuals can have a big impact on their agencies.

In response to a Freedom of Information Act request filed by ProPublica, the names of 400 of the more than 520 members of beachhead teams were released by the Office of Personnel Management — including several dozen individuals who have been federally registered lobbyists, a review by OpenSecrets confirmed.

Their positions can last 90 to 120 days, depending on the level, with one contract extension permitted — although many expect to be later hired on to full-time positions. That’s what happened with Leggitt, for example, and with Jack Kalavritinos, who was brought in on a beachhead assignment to help run FDA; that agency’s commissioner wasn’t named by Trump for close to two months. Kalavritinos worked at HHS in the mid 2000’s but more recently spent eight years lobbying for Covidien Ltd, an Ireland-based pharmaceutical and health products company. This week, Kalavritinos was named associate commissioner for external affairs at FDA.

While past administrations have used some temporary personnel, they didn’t seem to do so at the same scale as Trump’s, said Max Stier, president and CEO of the Partnership for Public Service, which helps advise new administrations. Most pushed to have officials in place much more quickly.

“There wasn’t a notion of a group of people that were only there for a limited period of time, but more of an expectation that the secretary and team would get in and be using the career folks,” Stier said. “The beachhead team creates another step in the process.” (The term “beachhead” was first used by Mitt Romney’s 2012 campaign; he didn’t get the chance to implement the concept.)

It also creates “minders” of a sort who aren’t always appreciated by agency chiefs or civil service employees trying to do their work. According to the Washington Post, these temporary figures often act as eyes and ears for the White House, making sure the agencies are loyally hewing to the administration’s agenda.

Now, some of the beachheaders with lobbying backgrounds did that work many years ago and went on to other careers. But even for more recent practitioners, Trump’s executive order on ethics, unlike President Obama’s, allows lobbyists to join the administration, even in the agencies they previously lobbied, though they are not supposed to work on specific issues on which they lobbied in the last two years. There are also restrictions on the lobbying that administration employees can do after they leave the public payroll, but there are a number of loopholes in the rules.

It’s unclear if all the beachhead employees are bound by the Trump policy. Still, even if they are, there are a number of ways that former lobbyists can flourish in the administration. For instance, Trump could waive the executive order’s requirements for certain appointees, and now doesn’t even need to make those waivers public, like Obama did. (There is a section of the White House site that says “Ethics pledge waivers will be published as they become available,” but there weren’t any waivers posted when we published.)

The placement of all these lobbyists as de facto — or actual — high-level agency staffers “raises the appearance that you could be attempting to influence public policy in favor of your former client,” said Meredith McGehee, chief of policy, programs and strategy at Issue One. “This isn’t saying that lobbyists are bad or evil, it’s simply saying the reason that you should have rules governing lobbyists in government is because they have been paid by private interests to promote the interests of their employer.”

It makes a difference whether an individual lobbied last year of 10 years ago, McGehee said. Revolving door restrictions are written with time limits, because it’s understood your relationships with clients and freshness of information cool over time.

One former for-profit college lobbyist has already resigned from his beachhead position at the Department of Education, where he worked for about a month. Taylor Hansen lobbied for Career Education Colleges and Universities until July 2016, where he focused on trying to weaken the “gainful employment” rule that puts for-profit schools’ federal funding at risk if their graduates don’t earn enough to pay back their student loans.

ProPublica reported that soon after Hansen started working at Education, the agency began delaying deadlines for the gainful employment rule and is reviewing the implementation of the rule. Hansen told ProPublica he didn’t work on gainful employment while at the department.

OpenSecrets Blog contacted the federal agencies with former lobbyist beachhead members about their ethics policies. The Department of Homeland Security was the only one to get back to us, and its response was vague:

“Ethics training, consistent with U.S. Office of Government Ethics regulations, is provided to all political appointees,” said DHS spokesman David Lapan in an email. “DHS ethics attorneys conduct reviews for potential conflicts of interest and provide guidance to employees.”

Nine beachhead members were registered lobbyists as recently as last year; eight of them have filed forms with the Senate deregistering from that work. General Mills has not filed paperwork that shows Erika Baum ending her lobbying gig at the food company, although she is now an executive assistant to the Secretary of Transportation, according to ProPublica‘s data and lobbying records.

OpenSecrets Blog contacted all nine firms, and confirmed at least four beachheaders had formally resigned from their lobbying jobs, as opposed to taking temporary leaves of absence. Two firms said they could not divulge personnel information, and two did not reply by publication. (The ninth was General Mills.)

Among the former cohorts on K Street:

John Barsa, who is installed at DHS, has lobbied for the Aerospace Industries Association of America, a trade group for the aerospace and defense industry. He’s also represented MRIGlobal, a research organization that touts its security and defense program and runs facilities for the Department of Energy and the Department of Defense. He deregistered in 2013, though he stayed at his lobbying firm until 2015.

Pete Giambastiani, in his role as special assistant at the office of the secretary of defense, might visit one of those facilities. He, too, has a history of lobbying on behalf of defense interests. His past clients, through 2014, include the Defense Venture Group, Finmeccanica SpA and the Navy League of the US. Giambastiani also served in the Department of the Navy and the offices of Reps. Jeff Miller (R-Fla.) and, most recently, Tom Rooney (R-Fla.).

Mark Maddox‘s clients as a lobbyist included General Synfuels International, Calcasieu Refinery Co. and Cline Resource and Development. Now, fittingly, he’s a key beachhead figure at the Energy Department. He deregistered in 2015, though he continued working at The Livingston Group/Maddox Strategies.

Then there’s Geoff Burr, who is at the Department of Labor. Until 2015, he was the top lobbyist for the Associated Builders and Contractors, which is always fighting wage standards in federal contracts and is on the other side of labor unions when it comes to exposure to hazardous materials. He then went on to run the lobbying shop at Cablevision. Burr previously put in time at Labor, from 2006 to 2008.

Other departments have smatterings of staff who have lobbied on behalf of issues that are intensely political. Julie Kirchner, a Homeland Security adviser, represented the Federation for Amer Immigration Reform, a nonprofit that seeks to reduce immigration levels. (She deregistered in 2015.) At the Department of Agriculture, special assistant George Dunlop brings with him his experience lobbying for the Tobacco Quota Warehouse Alliance, which advocated in support of tobacco producers from 1999 to 2001.

So far, the links between lobbying and the beachhead team have been pretty direct: Health care lobbyists at HHS, defense lobbyists at Homeland Security, and so on. But what about the Department of Commerce, which is tasked with the broad goal of expanding economic growth? Earl Comstock, director of the Office of Policy and Strategic Planning at Commerce, has demonstrated the flexibility befitting the nation’s multifaceted economy. In his 18 years of lobbying until 2015, he represented firms from Swiss International Air Lines to the Alaska Eskimo Whaling Commission to the Teamsters Union. He can now apply that diverse experience as he makes his way back to government — he was a staffer on the Senate Commerce, Science, & Transportation Committee from 1988-1991.

In some cases, the revolving door made a complete 360 swivel: At least 14 of the beachheads have previously worked in the same agency where Trump has now placed them.

One of them is Marcus Peacock, now adviser for Office of Management & Budget, who worked in that office for eight years under GOP Presidents Ronald Reagan and George W. Bush (R). Peacock worked for Jellinek, Schwartz & Connolly as a program manager in the early 1990’s. Most recently he was the environment & energy consultant for dark-money nonprofit Right to Rise Policy Solutions, which supported Jeb Bush.

Here are the rest of the former lobbyists on Trump’s beachhead team:

• Patricia Adkins – Executive director at the Consumer Product Safety Commission. Lobbying client was the Home Safety Council until 2010, after which she worked at Safe Kids Worldwide. Has worked at CPSC since 2014 under Obama, and was temporarily hired to stay on under the Trump administration.
• Byron Anderson – Dept. of Labor. Lobbying clients included American General Corp and Transamerica Companies. Deregistered 2016.
• Deidre Bass – Dept. of Housing and Urban Development. Lobbying client was the Stark Area Transit Authority. Deregistered 2008.
• Scott Cameron – Dept. of Interior. Lobbying client was Chep USA. Deregistered in 2001, then worked at Interior and Grant Thornton LLP.
• Mauricio Claver-Carone – Dept. of Treasury. Lobbying client was the Cuba Democracy Public Advocacy Corp. Deregistered 2016.
• Martin Dannenfelser – Dept. of Energy. Lobbying client was the Family Research Council. Deregistered 2000, worked at the Energy Innovation Reform Project.
• Lynda Davis – Dept. of Veterans Affairs. Lobbying clinets included Florida State College at Jacksonville and Valencia Community College, as well as Lockheed Martin, Raydon Corp and BAE Systems. Most recently, was executive director of a group called the Military and Veteran Caregiver Network.
• Sheila Greenwood – Dept. of Housing and Urban Development. Lobbying clients included Prudential Financial and Wal-Mart. Deregistered 2014, continued working at Prudential Financial.
• Scott Hommel – Dept. of Interior. Lobbying clients included American Defense Systems, Avalex Technologies and the National Guard Association of the U.S. Deregistered 2010, served as now-Secretary Ryan Zinke’s chief of staff.
• Russell Laird – Dept. of Agriculture. Lobbying clients include the National Cooperative Services Corp. and the National Rural Utilities Cooperative Finance Corp. Deregistered 2016.
• Keagan Lenihan – Dept. of Health and Human Services. Lobbying client was McKesson Corp. Deregistered 2016.
• Marianne McInerney – Dept. of Transportation. Lobbying client was the American International Automobile Dealers Association, a lobbying group for foreign car dealers, where she was also president. Joined beachhead team from electric car maker Cenntro Automotive.
• Justin Mikolay – Office of the Secretary of Defense. Lobbying client was Palantir Technologies. Deregistered 2016.
• Wayne Palmer – Dept. of Labor. Lobbying clients included the Alliance for Healthcare Competitiveness and AstraZeneca Pharmaceuticals. Deregistered 2015, continued working at AstraZeneca Pharmaceuticals.
• Alex Pryor (or Campau) – Dept. of Health and Human Services. Lobbying clients included AmeriHealth Caritas, Blue Cross/Blue Shield and Fresenius Medical Care. Deregistered 2014, worked at the House Budget Committee and Senate Republican Policy Committee.
• Lora Ries – DHS. Lobbying clients included General Dynamics and Boeing. Deregistered 2010, worked with two technology companies that had contracts with DHS.
• Heidi Stirrup – Dept. of Health and Human Services. Lobbying clients included the National Association of Spine Specialists and Aurora Organic Dairy. Deregistered 2008, worked at Faithful Catholic Citizens, then the Department of Commerce followed by the House Ways and Means Subcommittee on Health.
• George Sugiyama – Environmental Protection Agency. Lobbying clients included the National Mining Association, Southern Co. and Solargenix Energy. Deregistered 2013, worked at the Senate Environment and Public Works Committee.
• Cathy Tripodi – Dept. of Energy. Lobbying clients were Abound Solar and the South Coast Air Quality Management District. Deregistered 2012, worked at the North Carolina Department of Transportation.
• Laura Clay Trueman – Dept. of Health and Human Services. Lobbying clients included Aetna, Coalition for Affordable Health. Deregistered 2007, worked at the UnitedHealth Group and then the Heritage Foundation.
• Brooks Tucker – Dept. of Veterans Affairs. Lobbying clients included Management Solutions and Air Comm Corp. Deregistered 2016.
• Stephen Vaughn – U.S. Trade Rep. Lobbying client was U.S. Steel. Deregistered 2015, worked at King & Spalding LLP.
• Chad Wolf – Dept. of Homeland Security. Lobbying clients included Harris Corp. and Boeing. Deregistered 2016.
• Mark Zelden – Dept. of Labor. Lobbying clients included Birmingham Water Works and the cities of Foley, Jackson and Mobile, Alabama. Deregistered 2014, worked at Adams and Reese.