President Donald Trump’s former campaign manager, Corey Lewandowski, is the latest person to face ethical questions surrounding his status as a special government employee.

As an SGE, Lewandowski is supposed to work no more than 130 days in any given year, yet he may be working far more than that without fully logging his time, according to a report from Axios.

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Lewandowski acts as a de facto chief of staff to Homeland Security Secretary Kristi Noem, the outlet said, yet he is officially working far less than full-time.

DHS says Lewandowski’s time sheet is accurate.

“Mr. Lewandowski’s time is kept by a career DHS employee who submits the paperwork on a bi-weekly basis. He has served 69 days,” DHS spokeswoman Tricia McLaughlin told the Washington Examiner. “Mr. Lewandowski is a Special Government Employee.”

A White House official confirmed that a government-wide memorandum outlining the parameters of SGE status had been issued, but added that it was “not directed to any specific individuals.”

Lewandowski was the first campaign manager of Trump’s 2016 presidential run and has worked as a political commentator and lobbyist in the years since.

But, per Axios, he has been working remotely or letting another employee swipe their badge when entering DHS headquarters to avoid being detected at work and running down the clock on his 130-day tenure.

Lewandowski’s case is not unique, as SGEs have drawn plenty of controversy over the years.

Tesla CEO Elon Musk avoided having to file ethics disclosures earlier this year because he, too, was listed as an SGE, though Musk did leave government service almost exactly 130 days after he began.

SGEs work for no more than 130 days in any 365-day period, and can be paid or unpaid. They are supposed to provide important but limited services to the government that might be unavailable among an agency’s regular employees.

The Trump administration is not alone in having SGE controversies.

Former President Joe Biden brought in top communications adviser Anita Dunn as an SGE twice before she finally joined the administration full-time ahead of the 2022 midterm elections. Dunn was paid just below the salary threshold for disclosure obligations, keeping her client list private along with a substantial asset portfolio.

Jeff Zients, Biden’s chief of staff and one of the richest members of his administration, was also brought in as an uncompensated SGE ahead of the 2022 midterm elections.

Looking further back, former Secretary of State Hillary Clinton raised eyebrows during her tenure in the position for bringing in her top aide, Huma Abedin, as an SGE, allowing her to continue working at the Clinton Foundation while advising her at the State Department.

The controversy surrounding Lewandowski is a bit different than that of Musk, Dunn, or Zients, however.

In Lewandowski’s case, the problem is his apparent underreporting of work days to preserve his SGE status for far over 130 days.

Richard Painter, the chief ethics lawyer for former President George W. Bush from 2005 to 2007, said it’s normal for SGEs not to work every day in a given week, as they are often members of boards or commissions that meet infrequently.

But if Lewandowski really is working without reporting it, that would be a problem.

“The issue you get into is whether someone should be slotted into a special government employee position when they’re performing a function that’s essentially the same as a full-time government employee,” Painter said. “The Anita Dunn thing, I think, was slick. I thought the Elon Musk thing was slick. And you may have the same problem here.”

If Lewandowski is acting in a supervisory role, that could be particularly problematic, Painter added.

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“If you supervise other people, I don’t think you really are a legitimate special government employee,” Painter said. “And that’s one question to ask about Corey Lewandowski.”

A longtime Trump adviser, Lewandowski is now being monitored by White House officials, according to reports. Trump earlier this year denied him an official role in the administration, per The Atlantic.