but this prohibition is only for when the little dears are on the govt clock.
I see nowhere there that it draws a distinction between being on, or off, the clock. I see where it says "a participant" may not engage..now, if you join (or are forced to), are you now a full participant whether or not you're on the clock?? This would be a question that definitely WOULD require clarification IMHO..but from what we've seen, the government isn't adverse to changing their minds and rules AFTER the fact when it comes to legislation (witness the AIG bonuses which were allowed, then retroactively taxed at x%)
These kinds of rules, when in the federal employment package, mean 24/7.